New staffing rules redux

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Steven Littlehale
Steven Littlehale

The Centers for Medicare & Medicaid Services' proposed rule for skilled nursing facilities in fiscal 2016 contains some “must read” information about new staff reporting requirements. 

In order to increase confidence in the accuracy of staffing numbers, CMS wants to move away from the self-reported at annual survey collection of skilled nursing facility staffing data. Instead, the agency has proposed quarterly, electronically submitted payroll data as a new requirement for participating in the Medicare and Medicaid programs.

While the new requirements may appear fairly straightforward, there are some significant implications for providers:

• The CMS Payroll-Based Journal (PBJ) has more job categories listed than currently collected during the survey process. The PBJ asks specifically about LPN/LVN with Administrative Duties, Pharmacist, Nurse Practitioner and Physician Assistant hours. This level of specificity may impact Five-Star as LPN/LVNs with Administrative Duties currently count toward your RN calculation. Teasing out LPN/LVN may lower your Five-Star RN Staffing score. 

• These quarterly staffing reports must identify agency or contract staff, include staff category of work, turnover, tenure and resident census. These details also include employees' start dates and end dates. 

• Currently, you capture hours worked by corporate staff, or exempt staff working overtime in roles identified on the 671. These hours may not appear in your payroll system. Consider how you'll verify your staffing data prior to submission to capture this time. 

• With staffing now reported quarterly, as opposed to at time of survey, the door is open for more frequent updates to Five Star staffing scores. The “go live” date is July 1, 2016. Now is the time to work with your vendor and other stakeholders in implementing systems that meet reporting requirements and accurately capture staffing. n