Payroll-Based Journal Requirements
In accordance with Section 6106 of the Affordable Care Act (ACA) skilled nursing facilities are required to electronically submit staffing information to drive accountability and consistency in reporting throughout the industry. Total direct care hours worked, including agency and contract staff, employee hire and termination date, and facility census must be included and auditable. This information will be used to report the level of staff (hours per patient day) plus employee tenure, retention and turnover – all of which have been found to impact the level of care provided to residents.
To facilitate this effort, the Centers for Medicare and Medicaid Services (CMS) has developed a system for facilities to submit staffing and census information – Payroll-Based Journal (PBJ). This system will allow staffing information to be collected on a regular and more frequent basis than currently collected. It will also be auditable to ensure accuracy.
Note: Only long-term care facilities that are subject to meeting the Requirements for Participation as specified in 42 CFR Part 483, Subpart B are subject to the PBJ reporting requirements. This requirement does not apply to swing beds.
Why PBJ Is Critical For Providers To Get Right
CMS has stated that the electronic Payroll-Based Journal staffing information is a requirement of participation and as such failure to submit, or reporting inaccurate data can be costly, potentially leading to citation and civil money penalties.
CMS, along with major provider associations, have long identified staffing as a key component in delivering quality care and ultimately positive resident outcomes. So much so, that CMS uses staffing information in the CMS Five-Star Quality Rating System to help consumers and referral sources understand the level and differences of staffing in nursing homes when selecting a facility.
For the time being, CMS will continue to require that providers submit Forms CMS 671 & CMS 672 at the time of survey to calculate the Staffing Domain of the Five Star Rating System. The switch to use submitted PBJ information for the Five Star staffing ratings will likely occur in late 2017 or early 2018.