Ask the Payment Expert about ... the new Payroll-Based Journal system
Ask the payment expert ... about the observation stay loophole
Can you explain the new Payroll-Based Journal system?
In 2015, as part of the SNF Final Rule, the Centers for Medicare & Medicaid Services issued rules for the SNF Payroll Based Journal implementation. A draft manual was issued at that time and the first update to that manual was issued in March of 2016.
You can find the manual here. On this website you can also find the technical specification and other references to the overall process. It is somewhat of a complex process, but it all starts with you acquiring a CMSNet ID and a PBJ User ID.
The important aspect of this process is to be prepared by July 1 to begin the submissions. You will need to decide whether you want to submit manually, electronically or a combination of both.
Those who have been voluntarily submitting since October 2015 have indicated that manual submission is cumbersome and time consuming. My recommendation is to submit both manually and electronically.
Electronic submission will, however, require you to set up the process with either your payroll or timekeeping vendor. Don't assume they will know how to do it, or even want to do it.
Make sure they can deliver an XML uploadable file.
You should take time to test it and verify it is correctly capturing all your employees and their time. You may need to manually input your salaried employees, contracted services such as medical director and consultants, and temporary staff. Each staff member needs to be entered for each day worked. For contracted or temporary staff, you will also need to develop an auditable system for tracking their hours.