PBJ Reporting Update

The Affordable Care Act (ACA) placed new requirements on long term care (LTC) facilities as part of its outcomes-based reimbursements. Nursing and skilled nursing facilities must now report staffing and census information quarterly through a new software application, Payroll-Based Journal (PBJ).

The Centers for Medicare and Medicaid Services (CMS) has long recognized the connection between facility staffing and quality of care, as a key component related to beneficiary outcomes. The goals of the PBJ Staffing Data Submission Program are to 1) standardize reporting requirements and 2) collect information related to direct care staffing (including agency and contract staff) and facility census on a more frequent basis, in an electronic format. These mandatory compliance measures are being undertaken in connection with Section 6106 of The Affordable Care Act.  As currently structured, reporting will be mandatory effective July 1, 2016. 

What Are the Goals for the Payroll-Based Journal Requirement?

1. Allow the CMS to collect more regular and more frequent data from nursing homes
2. Ensure accuracy of data by providing an auditable method of data collection
3. Standardize data collection
4. Inspect the quality of care delivered at nursing homes by using data such as:
   1. The level of staff in each nursing home
   2. Nursing home employee turnover and tenure
   3. Census data

Once the new requirements are in place, affected employers will need to file staffing and census data within 45 days of the close of each fiscal year.

The Required Information

In addition to census data, Centers for Medicare and Medicaid Services (CMS) require detailed accounts of each employee’s daily activity:

1. Employee ID – Facilities must assign each employee a unique ID in PBJ.
2. Hire Date – The first date the employee starts work.
3. Termination Date – If applicable, the last date the employee worked.
4. Pay Type – Direct employee or contract staff. CMS defines contract staff as individuals working under contract and individuals working at the facility through a staffing agency.
5. Hours – Number of hours worked by the employee each day of the quarter. If the employee works more than one job at the facility, daily hours need to be separated out according to the services performed.
6. Job Title and Labor Code – Job title(s) and services according to a list of defined job codes and descriptions.

Payroll-Based Journal reporting can be a big administrative task for long-term care facilities, and can present some challenges. For example, the CMS requires employees’ hours to be reported from midnight to midnight. This means that overnight shifts (which are common at many long-term care facilities) must be split between two days for compliant PBJ reporting. Also, if an individual worker is working two different jobs at the same facility, the employer has to report data separately for both jobs. Accuracy is very important with PBJ reporting; the CMS has stated that it will audit these reports, and will take noncompliance action on long-term care facilities that upload incorrect data. Do you and your company have a handle on what's to come? If not or you have questions feel free to contact us.