The first deadline for Payroll-Based Journal (PBJ) is looming. Mandatory collection of PBJ data begins July 1st. Submissions must be received by the end of the 45th calendar day (11:59 PM Eastern Standard Time) after the last day in each fiscal quarter in order to be considered timely – making the due date for the first PBJ submission November 14, 2016. As the deadline approaches, CMS and skilled nursing providers are still trying to clarify some of the policies associated with this new process.
In April 2016, an update to the Payroll-Based Journal Long-Term Care Facility Policy Manual was released. The major change in the CMS’ PBJ reporting policy manual was that two job title codes previously required to be reported are now considered optional: Clinical Laboratory Services Worker and Diagnostic X-ray Services Worker. There are now a total of 35 required job codes that must be reported. The policy manual update also provided clarity on other issues including how to report hours for physicians and medical directors, therapy providers, corporate staff, and staff in training.
The process of submitting Payroll-Based Journal data is certainly complex, and as the PBJ deadline gets closer, the pressure mounts for providers to implement solutions and processes that will ensure a successful submission come October. Here are a few items providers should be thinking about now to be ready for collecting data July 1, 2016.
Mapping Job Codes
For every hour that is reported in Payroll-Based Journal, CMS job codes must be attached. Each shift and position should be assigned a job code. Often times, providers’ job codes don’t directly align with those provided by CMS.
Providers should work to map internal job codes to those that CMS provides by position and shift. This job code should be used and paired with the direct care staff, including agency and contract workers, which work those shifts.
Collecting Agency/Contractor Hours
While many of the Payroll-Based Journal reporting requirement’s direct care hours can be collected within a provider’s time and attendance system, often contractor and agency hours are not.
Providers should look to implement a process to collect those hours as they occur to help ensure their submission is complete. Larger therapy contractors we work with have indicated they will supply providers a report of the direct care hours provided to each facility. However, smaller contractors and most staffing agencies cannot. Providers should collect these hours as they occur by checking in and checking out each worker and recording their time for proper submission.
Reviewing for Data Accuracy
Accuracy is crucial when collecting and submitting data for PBJ. CMS has indicated it intends to audit the information that providers submit. Submitting inaccurate data might even lead to citations or fines in the future.
It is important for providers to gather all direct care hours into a centralized location in a format that can be easily consumed. We recommend establishing a regular cadence for submitting data, such as a week or two after payroll. Rather than waiting until the end of each quarter, regularly submitting PBJ data to CMS will help you recognize and address discrepancies more quickly.
CMS Payroll-Based Journal Reporting Success
Several skilled nursing sites are ahead of the game. In fact, multiple OnShift clients were able to successfully collect and submit Payroll-Based Journal reporting information using OnShift’s new PBJ reporting software.
Lancaster Rehabilitation Center is one OnShift client that has completed a Payroll-Based Journal submission. With 293 licensed beds, they are Nebraska’s largest skilled nursing provider. Using OnShift’s Payroll-Based Journal Reporting software, Lancaster was able to collect and classify the needed staffing data and successfully submit a PBJ report to CMS.
“OnShift has been an ideal partner helping us meet the Payroll-Based Journal reporting requirement,” stated Amy Fish, Administrator, Lancaster Rehabilitation Center. “OnShift has simplified a very complex process. Their expertise in PBJ combined with user-friendly software has made the process much easier for us. I would highly recommend the use of OnShift to my fellow skilled nursing providers across the country to help them comply with the new PBJ reporting requirements.”