Don't overlook this new mandate in the PBJ manual

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John O'Connor
John O'Connor

The Centers for Medicare & Medicaid Services inserted an important new requirement in the latest version of its Payroll-Based Journal manual. It's one of those innocent-looking provisions that are fairly easy to skim over.

But your facility might quickly find itself in hot water should it be ignored.

Specifically, the PBJ manual now requires facilities to check the Final File Validation Report. Operators must do this “to verify that the data was successfully submitted.”

The manual adds that it may take up to 24 hours for the government to receive the validation report, “so facilities must allow for time to correct any errors and resubmit, if necessary.”

The new manual has a few additional changes, but they are relatively minor by comparison. For example, CMS noted that it's no longer mandatory to report the hire and termination dates of employees. It also made the following positions optional for recording: dentists, podiatrists and social service workers.

For those who may think Obamacare has not really affected long-term care, think again. For the PBJ reporting mandate, we can thank Section 6106 of the Affordable Care Act. That part of the statute requires facilities to send staffing information electronically to the government, based on payroll and “other auditable data.”

This information eventually finds its way into the Five Star system, and can affect the rating your facility receives on the government's Nursing Home Compare website.

So it's clearly in your best interest to forward accurate information to the government — on time and in the manner it's required. If this all feels a bit overwhelming, the American Health Care Association has developed a helpful compliance checklist. You can access it here.

A PDF of the government's latest PBJ manual is also available here.

We are hearing a lot these days about a push toward less regulation. But given the keen interest that consumers and the government are placing on staffing, you can bet that PBJ reporting requirements will probably not be going away anytime soon. 

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McKnight's Daily Editors' Notes features commentary on the latest in long-term care news and issues. Entries are written by Editorial Director John O'Connor, Editor James M. Berklan, Senior Editor Elizabeth Newman and Staff Writer Emily Mongan.

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