Brady Dalrymple

The Payroll-Based Journal (PBJ) electronic data submission sneaks up on us every quarter, but due to the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services is waiving the deadline to report the 2020 Fiscal Quarter 2 PBJ data (Jan 1-March 31) by May 15. CMS will provide further information as soon as possible but are encouraging facilities to still report data as they are able.  There will be no penalties or negative impacts to staffing ratings for not submitting by May 15.

As facilities work to gather the necessary information, here are some reminders to help perform a successful submission:

  1. Registered Nurse (RN) Coverage – this is the biggest reason skilled nursing facilities (SNF) are downgraded to a 1-Star in the staffing component of the Five-Star rating system. SNFs that submit staffing data indicating there were four or more days in the quarter with no RN staffing, but on which there were one or more residents in the facility, regardless of reported staffing levels, will receive the rating downgrade.

  2. Nurse Aide Coverage – SNFs that submit staffing data with any day in the quarter with no aide staffing, but on which there were one or more residents in the facility, regardless of reported staffing levels, will receive the 1-Star downgrade as well.

  3. 400+ Hours in a Month – CMS will be monitoring the PBJ data to identify if an individual employee has worked more than 400 hours in a single month. Likely, this will only be investigated during an audit, but could imply the employee is being overworked or the SNF is overstating hours.

  4. 1,200+ Hours in a Quarter – In addition, CMS will be monitoring if an individual employee has worked more than 1,200 hours throughout the quarter. Again, this will likely only be investigated during an audit and carries the same implications as the monthly threshold above.

  5. Weekend Coverage for Direct Care Staff – CMS will also be monitoring weekday vs. weekend hours per resident per day (PRD) coverage for direct care staff. CMS is now notifying state agencies and CMS regional offices with a list of facilities that report low staffing during the weekend, which could potentially raise audit concerns or trigger state surveyors to commence a health inspection survey during the weekend.

  6. Meal Break Policy – CMS requires the deduction of meal break time for all staff (i.e. exempt, non-exempt, contract).
    1. For staff paid and/or unpaid at meal-times who work 8 hours shall deduct 30 minutes for meal-time
    1. For staff paid and/or unpaid at meal-times who work 16 hours shall deduct 1 hour for meal-time

  7. Universal Care Workers – some facilities employ universal care workers who are typically certified nurse aides performing a number of duties, including direct resident care, food preparation and housekeeping services.  Prior to this update, CMS has broadly explained how to report hours for staff performing these roles.  CMS has now added language stating the following items:
    1. Facilities must use a reasonable methodology to allocate the appropriate number of hours related to performing certified nurse aide duties.
      1. Please note, employees who work across different levels of care (i.e. SNF, assisted/independent living) need to be allocated appropriately to only include SNF-related hours.
    1. Other duties, such as time related to dietary and housekeeping, shall not be reported as certified nurse aide hours.
    1. Hours related to other duties above can be reported to housekeeping or other services, but are not required to be reported per PBJ guidelines.

  8. Reasonable Staffing Levels – The most important step throughout the PBJ process is to check the PBJ data for reasonability.  SNFs should assess the direct care hours PRD being reported and compare it to the SNF’s budget and/or actual staffing levels.

  9. New XML File Layout – There is a revised version of the PBJ Data Specifications (Version 4.00.0) available to Users.  XML files submitted with versions other than 4.00.0 on or after June 2, 2020 will be rejected. Census tags have been removed from the 4.00.0 version due to CMS no longer collecting Census data from PBJ. 

  10. Check the Validation Report – Once SNFs submit their PBJ data into the QIES system, they should return to the QIES website to obtain the validation report, which will indicate whether the submission was “accepted” or “rejected.” If rejected, the SNF should find the cause of the rejection, correct it and resubmit the PBJ information until it is accepted.

The PBJ Policy Manual and FAQ document can be utilized as additional resources to attain further guidance related to PBJ compliance.

As always, we highly recommend reviewing the PBJ information before submitting it in the QIES system. This will alleviate any uncertainty around the data’s level of completeness, mitigate the risk of duplicating or omitting data and provide insight on how to be proactive with staff positioning going forward.

Brady Dalrymple, MBA, is the owner of Squared Business Solutions. He has over fifteen years of experience in the senior care and living industry.  He spent much of his career in public accounting, where he served as a trusted adviser for skilled nursing facilities, assisted living, independent living, home health and hospice agencies. As owner of Squared Business Solutions, he provides support to a large number of providers through operational reviews, reimbursement strategy, Medicare and Medicaid cost report preparation, budgeting and forecasting, Five-Star compliance and Payroll-Based Journal. For more information, please call Squared Business Solutions at (614) 448-1822 or email Brady Dalrymple at [email protected].