Industry Insights

Nursing Facilities May Feel Burden of CMS Staffing Data Submission Requirements

June 2015
Author:  Lori Brunholtz

Lori Brunholtz

Managing Director


Health Care

Two Warren Place
6120 S. Yale Avenue, Suite 1400
Tulsa, OK 74136-4223


The Affordable Care Act (ACA) requires the Centers for Medicare & Medicaid Services (CMS) to begin collecting direct care staffing information from all nursing facilities, including agency staff and contract staff, in an auditable, uniform format. The ACA mandates the data include the following:

  • Category of work performed, e.g., RN, LPN, CNA or therapist
  • Census data
  • Resident case mix
  • Staff turnover & tenure information
  • Hours of care provided per resident per day (CMS interprets this to mean hours worked)

To comply with the ACA requirements, CMS has developed the Payroll Based Journal (PBJ). Details were outlined in a State Survey and Certification Memo in early April as well as the SNF PPS proposed rule published April 20. The proposed PBJ Policy manual can be downloaded at the CMS website.

We strongly encourage all nursing facilities to review the CMS draft policy manual and proposed requirements, as the level of detail is daunting. For example, the staff categories CMS is requiring to be reported extend to all facility staff, not just direct care staff as mandated by the ACA. In addition, hours worked will need to be recorded for every employee, every day. Each employee is to be assigned a unique identifier and the following details reported:

  • Hire date
  • Termination date
  • Full-time or part-time status
  • Pay type—exempt, non-exempt or contract
  • Labor category (time must be split if multiple roles are performed)
  • Hours worked per day

Resident census information by payor source also will be required, though only as a snapshot on the last day of the month.

All the data is to be entered into the PBJ system and submitted electronically on a quarterly basis and is due within 45 days following the end of each quarter. CMS proposes making compliance a condition of participation in the Medicare and/or Medicaid program.

Unless requirements change, voluntary submission begins October 1, 2015, with mandatory participation starting July 1, 2016.


The requirements CMS proposes to collect staffing data via PBJ will quite likely create a significant administrative burden for many facilities. CMS believes software vendors will be able to diminish the workload on facilities, but that may require purchasing a new scheduling, timekeeping and payroll system. That also assumes there actually are vendors who can accurately capture and submit the required PBJ elements. Software systems still will not alleviate the daily manual data entry requirements for nonpayroll staff, such as contracted workers and therapists.

Furthermore, the CMS new staffing data submission requirements could require duplicate effort. Staffing salaries and hours already are reported in summary format on Medicare cost reports. With some minor revisions, the cost report data could be modified to conform to all ACA requirements without significant additional reporting effort.

There are many unanswered questions and concerns related to PBJ. If CMS does not receive feedback and some providers begin submitting data voluntarily this October, the requirements of PBJ as proposed likely will be implemented and all nursing facilities will be required to comply. We encourage providers to voice their concerns by directing questions to CMS via email at or submitting comments to the CMS proposed rule by Friday, June 19.

If you have any questions, please contact your BKD advisor.

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