Answers to lingering questions about PBJ
As you hopefully know by now, the Centers for Medicare & Medicaid Services' required Payroll-Based Journal reporting is upon us.
Even though the kick-off date was last Friday, it's understandable that questions still cloud this new process. It behooves providers to get up to speed and become better informed as soon as possible.
An initiative from the Affordable Care Act requires that nursing facility staffing data be reported electronically to CMS starting July 1, 2016. One mechanism for reporting staffing data is via the Payroll-Based Journal (PBJ) upload process.
CMS is now requiring nursing facilities to submit staffing data quarterly. Data is to be submitted electronically and will be used to update the facility's Five-Star Nursing Staffing rating on a quarterly basis. Additionally, CMS will use the data to monitor and report on staff retention and staff turnover. Staffing data can be entered manually or uploaded electronically to the CMS site.
Q & A on PBJ:
There have been many questions and clarification requests posed in recent weeks. Here is information to address some common points of confusion:
Is there a way for a facility to have more than two staff with access to the QIES system to submit data?
The facility staff with access to the PBJ submission website share access rights to the QIES MDS submission website. Therefore, the facility is likely to already have two staff with approved access. Edward Mortimore, technical director for CMS, stated in a recent webinar that facilities can request one additional access by contacting the QTSO help desk.
Is education time to be included in PBJ staffing hours when education is provided during working hours or hours that the employee is paid?
Education time is excluded from PBJ time submission. Meal and break time is also excluded from PBJ reporting.
If the therapy company is contracted to the nursing facility, do they submit their own PBJ reports or are those hours included on the facility report?
Staff employed directly by the facility or contracted to provide direct care to facility residents should have their paid direct care hours reported as part of the facility's PBJ submission. This includes any staff paid directly by the facility such as the medical director and consulting dietitian. CMS requires an auditable allocation method to account for regular contracted hours.
What is the definition of "direct care hours"?
CMS defines direct care as time spent with the resident and time spent charting, completing assessments, attending care conferences and care planning meetings.
How should staff time be accounted for when a person has multiple roles in their shift, such as universal workers?
CMS asks us to identify the staff member's primary role and allocate their hours to the primary role for reporting purposes.
Need Additional Information?
• You can send you questions directly to CMS at: NHStaffing@cms.hhs.gov
• For technical questions regarding the data specification send your questions to: NursingHomePBJTechIssues@cms.hhs.gov
• More information about the technical data requirements and the submission process can be found in the PBJ User's Manual.
Karolee Alexander, RN, RAC-CT, is Director of Reimbursement and Clinical Consulting for Pathway Health.