On March 18, 2016 the Centers of Medicare & Medicaid Services (CMS) issued an S&C memo entitled "Payroll-Based Journal (PBJ) – Implementation of required electronic submission of Staffing Data for Long Term Care (LTC) Facilities," to reiterate that the mandatory collection period of Payroll-Based Journal staffing information begins on July 1, 2016. What this means to skilled nursing providers is that the new PBJ reporting requirements are not going away or even being postponed, despite the relatively low number of organizations currently participating in the Payroll-Based Journal voluntary submission program.
CMS also reiterated that the electronic Payroll-Based Journal staffing information is a condition of participation and as such failure to submit, or reporting inaccurate data can be costly, potentially leading to citation and civil money penalties. The good news is CMS also understands that supplying this data is a big undertaking for providers and made the following statement on initial enforcement, “As providers are adjusting to this new requirement, we may refrain from imposing enforcement remedies (e.g., for good faith efforts). Additionally, we will provide feedback mechanisms to providers, such as warnings, that will help facilitate compliance with this requirement." However, the state of Washington recently committed to using submitted Payroll-Based Journal staffing information to measure their minimum 3.4 hours per day of resident care beginning July 1, 2016.
The recently published outline of Washington’s new SNF Medicaid reimbursement methodology states, “Using payroll and census data for the CMS Payroll Based Journal, the Department will extract data and conduct a quarterly review. This compliance analysis would be done on a quarterly basis and would look at a staffing per day average for that quarter. The Department will be checking the numbers reported to ensure that they are averaging out to actual daily staffing and that the staffing is not varying wildly throughout the quarter.”
And if history has taught us anything, when one domino falls others will soon follow, making it likely that other states will use the required PBJ information to measure staffing compliance. This amplifies the importance for providers to get PBJ reporting right.
I’ve recently had the opportunity to educate and share Payroll-Based-Journal best practices for numerous state and national industry associations. At the beginning of each presentation I ask the audience to rank how prepared they feel they are for the upcoming PBJ deadline. Time and time again, over 90% of the audience doesn't feel like they are fully prepared and more often than not they feel very unprepared to meet the reporting requirements. With a quickly approaching July 1st start date, providers need to prepare now.
As an industry partner, we are here to help. PBJ success goes beyond which hours should be counted or the format of the data to be submitted. Download this free whitepaper to learn five steps you should take now to ensure you are prepared for the new regulations.