Three Steps to Prepare for Payroll-Based Journal Submissions
Author: Jessica Cullen
The Centers for Medicare & Medicaid Services (CMS) has introduced the Payroll-Based Journal (PBJ) system allowing providers to electronically submit staffing information. CMS already has started collecting this data from providers on a voluntary basis and mandated that all skilled nursing facilities start electronically inputting staffing information effective July 1, 2016.
Facility census data and total direct care hours worked, including hours for agency and contract staff, must be included in the submission. CMS defines direct care staff as individuals who—through interpersonal contact with residents or resident care management—provide care and services allowing residents to attain or maintain the highest practicable physical, mental and psychosocial well-being. Direct care staff doesn’t include individuals whose primary duty is maintaining the physical environment of the long-term care facility, i.e., performing housekeeping tasks. Each direct care employee must have an employee record within the PBJ system that contains a unique employee ID, hire and termination dates and pay type code, e.g., nonexempt, exempt or contract classification.
Providers will be required to submit their staffing and census data quarterly and will have 45 days after the last day in each fiscal quarter to do so. Therefore, the due date for the first PBJ submission for staffing data from July 1, 2016, to September 30, 2016, is November 14, 2016.
Step 1: Enroll in the program as soon as possible to begin keying all required information and practicing quarterly submissions.
CMS has defined 37 job codes to be properly identified and assigned to employees for each shift when reporting direct care hours worked. A job code must be attached for every hour submitted, which can be difficult as job responsibilities fluctuate throughout a shift. To streamline the collection and reporting of hours, facilities should report hours worked based on an employee’s primary role for each shift. To facilitate this, direct care hours should be scheduled and reported by an employee’s shift job code. Facilities should start by assigning each position and shift a job code to be paired with direct care staff. This process is complicated and should be discussed with staff scheduling personnel, time and attendance personnel and software vendors to allow for appropriate setup and automation where possible.
Step 2: Begin working with software providers early to determine how to automate data collection and coding processes so accurate information can be uploaded versus manually submitted.
Knowing what hours should and shouldn’t be reported in the PBJ will help compile a complete and accurate file for submission.
- Hours paid for any type of leave or nonwork-related absence from the facility
- Unpaid overtime
- Hours for services billed to fee-for-service Medicare or other payor
- Hours providing services to residents in noncertified beds, i.e., if nursing home staff is shared with an assisted living facility, only report hours dedicated to the nursing home
- Contract and agency work
- Corporate staff at a facility performing activities fitting into a CMS job category
- Salaried staff who don’t clock in or out
It’s each provider’s responsibility to develop a process to document, track and verify staffing information so all care hours are accounted for within PBJ requirements. CMS has stated the hours reported should be based on payments made for services and verified through payroll, invoices or contracts.
It’s important providers start working now to accumulate the information for all direct care workers as well as contracted employee data from contract labor providers. This data needs to be collected from multiple sources and systems and will take time to assemble. Once assembled, it should be stored in a centralized location that can be easily accessed and updated for PBJ submission.
Step 3: Begin identifying hours not tracked by the time and attendance system and implement a process to accurately capture those hours and verify all direct care hours to payroll or expense records.
Providers should start working now to set up a process allowing staff information to be easily accessed and summarized in a dashboard format. This will help establish staffing requirements based on census and analysis against budgeted hours so providers can identify any gaps and make adjustments to ensure ongoing compliance and quality of care.
If you have any questions, contact your BKD advisor.