Payroll-Based Journal (PBJ)

Mandatory Electronic Staffing Data Submission

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Electronic submission of Payroll-Based Staffing Information

• Section 6106 of the Affordable Care Act

• Funding provided by the IMPACT Act of 2014

• Report staffing levels, turnover, and tenure

• Auditable back to payroll data

• Collected more frequently than 671/672 forms

• Finalized through FY16 SNF PPS Rule as 42 CFR 483.75(u)

(https://www.federalregister.gov/articles/2015/08/04/2015-

18950/medicare-program-prospective-payment-system-and-consolidated-

billing-for-skilled-nursing-facilities)

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Electronic submission of Payroll-Based Staffing Information

Submission of data through Payroll-Based Journal (PBJ):

• Exported file (XML) from automated systems, or

• Manual entry directly through system

• Voluntary submission period: October 2015 to June 30, 2016

• Mandatory submission begins July 1, 2016

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Submission Deadlines

• Direct care staffing and census data will be collected for each fiscal quarter. Staffing data

includes the number of hours each staff member is paid for working each day within a

quarter. Census data includes the facility’s census on the last day of each of the three

• 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.

The PBJ system will accept submissions after the deadline. However, these submissions will

not be considered timely and will not be used to calculate a facility’s staffing measures.

FISCAL QUARTER

REPORTING PERIOD DUE DATE

1 October 1 – December 31 February 14

2 January 1 – March 31 May 15

3 April 1 – June 30 August 14

4 July 1 – September 30 November 14

The deadline for the first required submission is November 14th, 2016

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Registration and Training

Electronic submission of staffing data through the Payroll-Based Journal (PBJ) is required of all Long Term Care Facilities in 2016. ALL nursing homes will need to register to submit data in order to meet this requirement and maintain compliance.

Please follow the below instructions to register:

Step 1: Obtain a CMSNet User ID for PBJ Individual, Corporate and Third Party users, if you don’t

already have one for other QIES applications (https://www.qtso.com/cmsnet.html ) (many users

may already have this access for MDS submission).

Step 2: Obtain a PBJ QIES Provider ID for CASPER Reporting and PBJ system access

(https://mds.qiesnet.org/mds_home.html )

Training: PBJ Training Modules for an introduction to the PBJ system and step by step registration

instruction are available on QTSO e-University, select the PBJ option

https://www.qtso.com/webex/qiesclasses.php

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Employee Entry Screen

Note: Pay Type Code will be moved to Staffing Hours screen prior to July 1

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Staffing Hours Entry Screen

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Census Data Entry Screen

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Staffing Submission Frequently Asked Questions

Q: “Who are direct care staff?” (Who do we submit data for?)

A: Direct Care Staff are those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well-being. Direct care staff does not include individuals whose primary duty is maintaining the physical environment of the long term care facility (for example, housekeeping). Please refer to Table 1 in the Policy Manual for a complete list of direct care staff that should be included.

Q: How are we expected to report for staff who perform different roles or duties throughout their day? For example, a Director of Nursing (DON) who comes in and does administrative work for a couple of hours, and then provides some direct care to residents because of an acute change in condition.

A: Reporting should be based on the employee’s primary role and their official categorical title (for example, as indicated in a Human Resources system). It is understood that most roles have a variety of non-primary duties that are conducted throughout the day (e.g., helping out when needed). Facilities should still report just the total hours of that employee based on their primary role.

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Staffing Submission Frequently Asked Questions

Q:How do we report hours for consultants such as our medical director, other physicians, pharmacist, and other practitioners?

A: Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent conducting primary responsibilities, based on payments made for those services. Reminder: Hours for services performed that are billed to FFS Medicare or other payer, should not be reported. For example, physician visits to residents, hospice staff, or private duty nurses hours should not be reported.

Q:Are facilities required to report hours paid or hours worked?

A: The information must be auditable back to payroll data. Facilities (SNF/NF) must report hours paid for services performed onsite for the residents of the facility, with the exception of paid time off (e.g,. vacation, sick leave, etc.). For example, if a salaried employee works 10 hours but is only paid for 8 hours, only 8 hours should be reported.

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Staffing Submission Frequently Asked Questions

Q:Are we required to submit hours for contract staff? If so, please outline how hours for contract staff who are not in our payroll system or time and attendance system are to be submitted.

A: Yes, contract staff hours are required to be reported and each contract staff must have a unique identifier. Facilities have several options for including contract hours including: • Facilities can include contract staff hours in their attendance system (e.g., have contractors “swipe in

and out”), or enter contractor hours manually through the PBJ online data entry process. • Facilities can have the contract staff enter hours as a designee of the facility in the PBJ system. • The vendor can provide the facility with an XML file that meets the technical specifications, and the

files can be uploaded and merged.

Q:How will the data be posted or used in the Five-Star Rating System

A: CMS has not developed the methodology for an eventual quality measure nor determined how the Five-Star Rating System will be adjusted. We will provide more information prior to posting and using the data.

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Enforcement

• CMS retains enforcement authority (e.g., civil money penalties (CMPs))

for noncompliance with all requirements for participation, including this

new requirement (§483.75(u))

• However, it is not CMS’ goal to impose enforcement remedies

• We will provide feedback mechanisms to providers that will help facilitate

compliance with this requirement

• CMS may refrain from imposing enforcement remedies while providers

adjust to the new requirement (e.g., for good faith effort)

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Who Should I Contact with Questions?

• Questions regarding PBJ policy issues should be directed to NHStaffing@cms.hhs.gov

• Questions regarding the PBJ Data Specifications should be directed to NursingHomePBJTechIssues@cms.hhs.gov. Software developers or vendors that provide services such as automated payroll or time and attendance systems that will support electronic submissions should use this address.

• More Information: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Staffing-Data-Submission-

PBJ.html

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Questions and Answers

Questions can also be sent to: dnh_triageteam@cms.hhs.gov

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Thank You

Thank you for your participation.