The latest communications from the Centers for Medicare & Medicaid Services indicate mandatory PBJ submission will not be delayed. Most skilled nursing facilities are starting the work to prepare for the first Payroll-Based Journal submission that is due no later than November 14.
We’ve talked with hundreds of providers, all at different stages of preparation. A few have already submitted PBJ reports during the test periods. Many are exploring how to ensure their staffing data is PBJ compliant. Most are digging into CMS’ latest PBJ Policy Manual and starting to interpret what the PBJ rules and definitions really mean for their facilities.
Here’s some of the trickier parts of the PBJ reporting rules that you will need to either validate or make changes to your systems and processes to ensure your staffing data is PBJ compliant.
The “Midnight Split”
CMS requires that all direct care hours be recorded on the calendar day they occurred. This reporting rule means that any of your overnight shifts will need to be split for PBJ submissions. For example, a shift running 11 p.m. to 7 a.m. would need to be reported as one hour (11 p.m. – midnight) on Day 1, and seven hours (midnight to 7 a.m.) on Day 2. Make sure your payroll or timekeeping system can report your hours by calendar day.
- Pay Type and Job Title on Staffing Hours
Version 2 of the PBJ data specifications clarified that PBJ reports must have Pay Type (exempt, non-exempt or contract) and Job Title (one of the 40 PBJ Job Title Codes) describing the Paid Hours instead of the Employee. This was done to ensure accuracy for staff who might work multiple roles. You need to ensure your payroll or timekeeping system will give you reports with data organized this way:
- Employee Record: Employee ID, Hire Date, Termination Date
- Staffing Record: Employee ID, Date Worked, Paid Hours, Pay Type, Job Title
Capturing ALL Direct Care Hours
What comprises Direct Care for PBJ Reporting? CMS spells it out – and notes that Direct Care reporting must include not just your internal employees but any agency or contract staff whose primary duty is providing care and services to your residents.
Additionally, if you have any staff that provide some Direct Care even though their primary role is not Direct Care, CMS says you can now use a reasonable, auditable methodology to calculate and report these incremental Direct Care Paid Hours. This is good news for SNFs since it means a better, more accurate representation of ALL direct care provided by staff at your facility. Identify for which staff you will report partial Direct Care Paid Hours and the reasonable auditable methodology for doing so.
Tracking Agency and Contract Hours
Everyone understands that CMS requires direct care hours of agency and contract staff be submitted…now what? How do you capture those hours in such a way they are “auditable through time tracking, invoices or contracts” per PBJ requirements? This is proving to be a difficult challenge for most facilities. You need to capture those contract and agency hours somehow, and submit them either manually or in a zipped XML file to CMS. Some options for tracking vendor data include:
Obtain the information from your vendors – contact the agencies and contractors you use and request that they electronically provide you the staff and paid hours data needed for PBJ reporting. Remember – you’re paying them to provide you services.
Capture the data in your timekeeping system – require your agency and contract staff to swipe in and swipe out, just as you do your internal employees. If you try this approach, create a unique badge and ID for each person.
Remember that employees are motivated to swipe because it affects their paycheck. Vendors are not, so make sure you have a verifiable method to capture missed swipes. More options include:
Manually record the hours: Use an internal employee to log and/or verify the “time in” and “time out” of each agency or contract worker.
Use a vendor management system – Vendor Management software can administer the scheduling, tracking and auditing of your contract and agency staff, and create the PBJ reports you need.
With the “beat the deadline” rhetoric escalating, just what is essential and when? Let’s work backwards.
November 14: LAST day by which you MUST SUBMIT your MANDATORY PBJ Reporting submission.
September 30: Last day of collecting your 4th Quarter reporting data. You have 45 days to submit your first mandatory PBJ Reporting submission per CMS rules.
July 1: First day of collecting your 4th Quarter reporting data. By July 1, you should have the processes and systems in place to begin capturing the data that will be reported to CMS.
Between now and July 1? This is the time to evaluate your current systems and processes, make sure the data you collect will work for PBJ and even do a test submission to CMS.
Of course the biggest “gotcha” is how to stay PBJ compliant while effectively managing your costs! CMS is providing some tools to help you manually report, which limits your costs to internal labor. Many workforce software vendors are coming out with tools to create PBJ reports from their systems but usually require purchases or upgrades. Ultimately, the best way to manage your costs is by figuring out what combination of internal resources and software you need to stay PBJ compliant, while minimizing any major upgrades or conversions.