March 29, 2016
If you are a long-term care provider, it’s time to get serious about something called the “Payroll-Based Journal.” Introduced under the Affordable Care Act, the Payroll-based Journal, or “PBJ” is a new, mandatory report required by the Centers for Medicare and Medicaid (CMS) of long term care providers that receive their reimbursements. While SmartLinx has already helped several clients submit PBJ reports to CMS using our WorkLinx ACA Director product, our recent survey puts this group in the proactive 1% of facilities who have actually submitted PBJ data to CMS. It’s certainly time for all facilities to dip their toes into PBJ waters before the tsunami of mandatory reporting hits the beach.
Start preparing now — PBJ compliance is mandatory for Long-Term Care facilities
If you are like most nursing homes in the US and reimbursed by CMS, you are required to report direct care staffing data as a Payroll-based Journal. Hoping that the mandatory reporting deadlines, starting July 1st 2016, will be pushed back could backfire. Some facilities have already taken advantage of the optional reporting period that started October 1st 2015 to initiate work on the processes and data required for PBJ compliance. Facilities that receive CMS reimbursements and do not currently have a PBJ plan, may be in for a potentially nasty surprise if they delay further.
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PBJ is not just another 671 Report
PBJ reports are much more than the 671 reports many facilities submit today. Where the 671 report is bi-weekly and based on aggregated data, the PBJ is far more granular. The Payroll-based Journal details hours worked providing direct care by person, by position, and by hour. You’re also expected to report using the CMS-provided job codes, so you’ll need to spend time up-front understanding how these map to the job titles and codes you actually use at your facility.
Adding to the PBJ angst, you’ll need to submit start dates for everyone providing reimbursed direct care, including agency staff. CMS also requires that you provide a unique ID for everyone –PBJ reports refers to staff by ID, not by name. Already using SSN to ID your staff? Think again – the CMS does not allow personally identifiable data, such as SSNs, to be used for the staff ID.
Prepare for PBJ-related process changes
To adequately capture and verify the data you need to submit, process changes should be expected, particularly with regard to agency staff. You’ll need to know much more about contract staff sent to you by the agency. Also, if you currently count shifts that overlap dates toward the start date of the shift – you’ll have to report on each portion of the shift on the actual day worked for CMS. And, as mentioned, you’ll need to report using CMS job category and title codes, not your own. PBJ data must be verifiable and auditable, so reviewing your processes sooner rather than later to meet this requirement will be important.
Understand the cost of the “free” CMS QIES Manual Data Entry system
CMS announced in April 2015 that it would be providing a “portal” where PBJ data may be entered. This now-operational system, the “Quality and Improvement Evaluation System” aka. QIES, offers a manual PBJ data entry capability. Early reports indicate you’d better have your data ready to go before you start the data entry. The system will disconnect you from the Internet, email and any other connected computers and laptop. There is no cut and paste here – this is manual data entry at its most basic. With a maximum of two CMS users and frequent system times out, we estimate an organization with just 200 staff will need over 40 hours to manually enter PBJ data for a quarter. The time and effort required to actually gather and verify the data prior to manual data entry, is additional.
Try the SmartLinx PBJ Calculator – find out what the CMS QIES data entry approach might cost your organization.
Building your own PBJ solution is not without pitfalls
THE CMS also allows organizations to submit PBJ reports in XML file format. In a recent survey conducted by SmartLinx Solutions, during its Payroll-based Journal compliance webinar, 25% of respondents intended to build their own PBJ compliance system. If you have the IT resources to construct and maintain an –in-house PBJ solution this certainly help you avoid time-consuming manual data entry. Just make sure you are able to monitor and implement chances as CMS updates its PBJ-related policies.
Integrated, automated processing will simplify PBJ compliance
Leveraging a vendor solution that tracks hours worked across all types of staff and can produce a PBJ report with accurate, real-time information in just a few clicks, makes a lot of sense, especially for medium and large sized organizations. 44% of the SmartLinx survey respondents agreed, stating they plan to purchase a PBJ compliance solution.
SmartLinx has helped a number of its clients already submit PBJ reports to CMS using the WorkLinx ACA Director product. Available since the beginning of the optional PBJ reporting period, October 2015, ACA Director enables users to configure staff, making on-demand PBJ reports available in just a few clicks.
Regardless of your approach to CMS PBJ compliance, it’s imperative to make a plan, and start implementing that plan soon. Make the most of the remaining optional reporting periods, October 1 to June 30, 2016, to prepare. Mandatory reporting starts July 1st!
About the Author
As Compliance Expert at SmartLinx, Tom Jegou oversees SmartLinx innovations in our payroll and compliance systems. Tom is focused on transforming client needs into leading-edge products. Tom leads cross-functional teams from a product's conception through to its launch. Tom led the design of the 1095-C and Payroll-Based Journal reporting features in the WorkLinxTM suite. Since 1996, Tom has worked with every aspect of Human Capital Management Systems. He has defined, supported, implemented and managed Payroll, Time and Labor and HR systems. Tom is a Certified Payroll Professional through American Payroll Association.More Content by Tom Jegou