If you’re a long-term care professional, it’s very likely you’ve heard a time or two that Payroll-Based Journal (PBJ) starts July 1st. PBJ represents a large shift in the way staffing data is collected and reported to CMS. For most providers it will require implementing some new processes to ensure all data is collected. So, you know July 1st is important, and you know it is coming (soon!). But what really happens on July 1st? And what does your organization need to do to be prepared for PBJ reporting?
A Little Payroll-Based Journal History
To understand what will happen in the future with staffing data collection, let’s look at what the process is right now. Currently, staffing data is reported annually during survey using forms 671/672. During survey you report the
hours for the most recent complete pay period or 14 days prior to survey.
Things began to change in 2010, when the Affordable Care Act was signed into law. Section 6106 of the Affordable Care Act required skilled nursing communities to electronically submit staffing data. The purpose behind the electronic submission of PBJ staffing data was to bring consistency, transparency and validation to the process. In 2014, the IMPACT Act was passed which brought an additional $11M of funding to help implement PBJ. In 2015, voluntary submission of PBJ data began.
What happens on July 1st, 2016?
On July 1, 2016, mandatory collection of PBJ data begins. With PBJ, data will be reported electronically on at least a quarterly basis, using the Payroll-Based Journal QIES system. PBJ accounts for all direct care hours – including contractor and agency – for each day of the year and includes employee tenure information.
Why should you care about the July 1st collection of PBJ data?
July is coming quickly. You don’t want to wait until your PBJ data is due (November 14, 2016 is the final day to submit data) to try and gather all of your staffing data. Failure to submit or reporting inaccurate data can be costly, potentially leading to citations and civil money penalties. The staffing information you provide will also be used on Nursing Home Compare and is believed to be used in Five Star Quality Ratings starting in 2017 or 2018.
What can you do to prepare your Payroll-Based Journal data?
The Centers for Medicare & Medicaid Services (CMS) wants to track direct care hours, and providers must offer that information in the correct format and in a way that is auditable. To prepare your organization for collecting PBJ data, you will want to get a few things done before July 1.
1. Map job codes. In order to report direct care hours, your organization’s unique job codes/descriptions should be correlated to the 35 CMS job title codes. This includes all agency and contract workers. Now is the ideal time to mark this task off your to-do list so that all direct care workers are properly labeled before you start collecting PBJ staffing data on July 1.
2. Update employee data. Each staff member, including agency and contract workers, must have a unique ID in order to report their direct care hours in the PBJ system. Each staff member must also have hire date, termination date, and pay code status information loaded into the PBJ system. To streamline this process in the future, implement a system for this data to be collected for new hires. Tenure data is required for contract and agency workers as well, so work with your agency and contract providers to request a list of active staff with the initial date each employee worked in your community.
3. Implement your staffing data collection process. You will need staffing data for any direct care workers--hourly staff, contract workers, salaried staff and corporate staff. Hourly in-house staff should be captured in your own payroll and/or time keeping system. For those not captured within a system, set into motion your process to track contractor data, whether that is a sign-in sheet, or a check-in app that will keep track of the data for you. Your agency and contractor vendors should be prepared to provide a CMS ready report of those hours worked. If you’re not sure if your vendors are ready to provide you with needed data, now is the time to have that conversation.
4. Make a decision on PBJ submission options. Providers essentially have two options to submit PBJ data: manually on your own, or adopt a software solution to automate the process for you. Uploading data on your own will require vigilance on your part to manually gather all needed information at the time of submission, and to meet the technical specifications set forth by CMS. Because the process is onerous, many providers are enlisting a PBJ vendor to help them. The assistance of a vendor can simplify the PBJ reporting process and create an auditable document trail that you will need in the event of an audit.
While the short term goal is to be ready for collecting PBJ staffing data on July 1st, the deadline for submitting Q3 data is not far off (November 14, 2016). Remember that your organization is ultimately responsible for the data you submit to CMS. Getting ready now for PBJ will save you time, money and frustration in the long term.