The first Payroll-Based Journal deadline is approaching and CMS is taking some time to clarify their expectations for providers as they prepare their first submission files.
In a recent Skilled Nursing Facility Open Door Forum, CMS addressed providers’ questions regarding the upcoming deadline of November 14, 2016 (by 11:59pm). This is when providers must submit all staffing data for the period between July 1 to September 30.
According to a McKnight article about the forum, providers who submit data by the deadline will not be penalized. CMS said that they don’t expect the data to be perfect, but they do expect all providers to submit data.
And for those that submit data late, or don’t submit data at all? CMS says they will face consequences. The McKnight’s article reported, “Nursing homes that fail to submit electronic staffing data by the first required deadline may face sanctions and could see their Five-Star rating suffer as a result.”
So how can you make sure you’re ready for November 14th?
Ideally, your first data submission should be done well before Nov. 14th so you can take advantage of the time between now and then to work out any kinks. You should also establish a regular workflow and cadence for your submissions that will set you up to successfully meet the deadline.
Over the past few months we’ve offered many PBJ best practices and answered many of your PBJ questions to help you get prepared. But as I’ve spoken with various groups across the country regarding PBJ, and I’ve continued to follow the news and updates from CMS, I’ve identified a few more lessons learned that can help as you navigate your first PBJ submission.
- Be aware of exceptions when reporting census data. PBJ requires that census information be provided for the last day of each month, by payer type (i.e. Medicaid, Medicare, or Other). However, if you have residents insured with Medicare Advantage (Part C), those beds should be reported as Other. Also, residents covered under Medicaid Managed Care or Medicaid Pending should be reported as Other.
- Correctly allocate shift hours that span two days. Shifts that span two days (because they go over the midnight hour) must be reported accurately. This means that hours must be attributed to the day they are worked. A shift that starts at 11pm and goes until 7am will have 1 hour reported on the first day and 7 hours reported on the second day.
However, most systems are not set up to report hours in accordance to the PBJ requirements. Providers have shared with us some of their strategies to address the issue. Some are changing shifts to start at midnight, some are manually adjusting hours to meet regulations, and others are contracting with vendors that can automatically allocate these hours.
- Know how to report boomerang staff. It’s not uncommon for a senior care employee to leave their job and then be rehired at the same community soon after. When submitting PBJ reports, be aware that CMS only allows for one hire and one termination field per submission. If there are multiple hire and termination dates for the same employee in one submission, you will see errors or lost data.
Providers have shared a couple of ideas for dealing with this issue. One idea is to submit separate files for rehired staff. Others have said they will submit PBJ reports more frequently to reduce the odds of rehires overriding. Which strategy you choose will depend on the number of rehires you typically see and your overall PBJ workflow.
- Understand how PBJ will impact 5-Star ratings. Providers should be aware that eventually (in 2017 or 2018) staffing data collected from PBJ will drive Five-Star staffing ratings, which will impact your overall Five-Star Quality rating. Providers should have a plan in place to ensure all direct care staffing hours are collected and submitted. Take special care to track and collect contractor hours to make sure you are getting all the credit you deserve for the great care you offer to your residents. You can track this manually, but many providers are utilizing technology to streamline the process.
Providers that begin submitting data now will have the advantage when November rolls around. Those that wait until the last minute may find themselves dealing with errors and failed submissions with little time to correct any mistakes.
The first Payroll-Based Journal deadline is approaching and CMS is taking some time to clarify their expectations for providers as they prepare their first submission files.
