Don Feige


Now that PBJ data has officially replaced the 671 for calculating the staffing section under the Five-Star Quality Rating System, what are the early returns we’re seeing in the industry?

The Centers for Medicare & Medicaid Services has evolved Payroll-Based Journal reporting rules and continues in their quest to create a standardized, consistent measure of staffing across the industry.  Loopholes are closing and gray areas being clarified.

Some changes ease the complexity of PBJ reporting, but make it harder for SNF’s to monitor and adjust their actions to improve staffing quality. Other unique PBJ concepts remain that leave facilities struggling with record-keeping and staying compliant with both CMS and other regulators. Major CMS changes for PBJ include:

  • Less data required. Various updates to the PBJ Policy Manual (now at version 2.4) have removed some reporting requirements — yet many facilities are unaware of these changes and continue to compile and submit everything they always have. Census data, Hire/Termination Dates and 8 out of the 40 PBJ job codes are now optional.
  • Census calculated from MDS. Remedying an early flaw, CMS has started using MDS data to calculate an average daily resident census for the facility rather than rely on self-reported data. While easing the reporting requirements, facilities now struggle to replicate the PBJ calculation of resident census and analyze Per Resident Day staffing patterns.  
  • Focus on meal breaks. Recent audits and CMS communications are emphasizing the removal of meal breaks from PBJ reported time — regardless if staff worked through lunch or actually took the break. PBJ reporting was always premised on the ease of simply reporting already existing payroll data. Yet this particular rule (and the “midnight split”) creates two sets of books – the live payroll used to pay employees, care for residents and stay compliant with labor laws and the “standardized” payroll reported to CMS for PBJ.  

Researchers are digging into publicly available PBJ data (soon to expand) and skilled nursing facilities are exploring how to achieve their targeted Five-Star staffing rating. With the initial PBJ-based staffing rating now published on Nursing Home Compare, we are seeing early signs that Payroll-Based Journal reporting is evolving from a reporting task to a strategic tool to analyze and make changes in staffing quality.  

What facilities need to know:

  • The deadline is the deadline. The dog cannot eat your PBJ homework!  Late or inaccurate submissions are what they are after PBJ submission deadlines have passed. The good news is that mistakes only stick with you for a quarter, and you can quickly fix problems and get your deserved staffing rating back by properly filing the next quarter’s PBJ report.
  • Avoid the one star. Adequate RN staffing now has a double whammy – non-compliance can trigger an F-Tag during survey AND too few reported hours can trigger an automatic staffing one star. Other ways to default to a one star include not responding to or failing an audit. PBJ hours must be provable – always be prepared to demonstrate that you paid for the hours you reported.
  • The MDS matters to PBJ. CMS calculates the census based on the MDS. Facilities not completing MDS Discharge Assessments on a timely basis risk overcounting residents and harming their PBJ-based Five Star rating. Keep on top of your PBJ census.

Not only is PBJ here to stay, the quest for staffing quality is ongoing – and no longer just an annual event during survey. Validate your PBJ reports to ensure you are awarded the staffing rating you’ve earned.

Don Feige is CEO of ezPBJ software, which provides free PBJ benchmarking. You can contact Don at [email protected] or 585-582-5186.