As debates on Medicaid cuts continue in the Legislature and on the public stage, it’s an interesting coincidence that the Centers for Medicaid & Medicare Services (CMS) released a memo this week with a major announcement on changes to Payroll-Based Journal (PBJ) reporting and accessibility to that data.
We’ve said it before and we’ll say it again: CMS is not backing down from its position on PBJ reporting. In fact, according to the memo, PBJ reporting is not only here to stay, but the data that long-term care facilities submit has consequences today and even more in the future.
CMS is taking its Star Rating System a step further and will begin posting PBJ data for public use on Nov. 1. The files will be available on the Data.CMS.gov site, and the first public-use file posted will include data submitted by facilities for the quarters ending March 30 and June 30, 2017. This is a wake-up call for facilities that may have submitted inaccurate or incomplete reports; their data will be on display for public viewing. Data files for subsequent quarters will be posted as they are available.
From the looks of it, CMS intends to keep LTC facilities on their toes. According to its memo, releasing the data is “the first step of many to come.”
The publicly available data will include the total number of hours submitted for nursing services job categories (such as registered nurse, licensed practical nurse, and nurse aides) for each day in the quarter, in addition to each facility’s census for each day in the quarter as calculated using minimum data set (MDS) submissions.
The use of MDS data
That’s the catch: CMS will use census data from MDS submissions, not PBJ census data, as the source of patient census. This means that patient counts will be calculated on a daily basis, not merely once per month as with PBJ or once per year as in the annual survey report. (Expect changes to the annual survey process in 2018 as PBJ data becomes more relevant than 671 data.) The result? Much more accurate census counts upon which staffing hours will be based.
The silver lining is that LTC facilities can likely expect CMS to make census reporting on PBJ optional, as it will be a duplication of reporting. The downside is that this will elevate the need for accurate, timely MDS reporting. Providers that do not submit data by the required deadlines will have their overall and staffing star ratings suppressed (that is, removed) on the CMS Nursing Home Compare site.
In the memo, it states that CMS “may update the methodology used to display icons or ratings to encourage more complete and accurate submissions.” So it’s safe to say that we can expect updates on the site regarding facilities that do not comply or provide inconsistent data.
So why did CMS make the switch from PBJ to MDS census data? Our take is that CMS wanted to create checks and balances in an effort to better prevent manipulation in the data submitted to PBJ. Public access to data adds a new level of transparency and an extra layer of scrutiny for LTCs. This data will be used by prospective residents and employees, investors, vendors, and competitors.
But wait, there’s more…
In the memo, CMS also hints at upcoming changes in the PBJ reporting requirement, including employee IDs and calculating staff turnover. CMS will add the ability to link employee IDs across multiple records for the same employee in the same facility. It also will add functionality to link employee IDs if a facility needs to assign a new employee ID. This move is intended to give CMS a clearer picture of staff tenure and turnover.
In its original policy statement, CMS planned to use staff tenure and turnover as a quality rating. However, the fact that CMS made hire and termination dates optional earlier this year was viewed a sign that it was moving away from this as a quality measure. Now, given the high turnover rate in the industry, CMS appears to be back-pedaling.
In the upcoming months, the need to attract, engage and retain the right talent will become more important than ever for LTC facilities. Keeping staff turnover in check will be a challenge due to the already constrained and increasingly competitive pool of nursing staff candidates.
Five-Star Ratings & the future
For CMS, it’s all a buildup to PBJ data being used for the Five-Star Ratings later in 2018. CMS appears to be flaunting — and strengthening — its power regarding Medicaid funding. As funding cuts escalate, there will be increased competition over the limited remaining funds. By publicizing PBJ data, CMS is helping to ensure that PBJ will be taken into consideration when funds are awarded.
Updates to the PBJ submission spec are expected in the next few weeks, and CMS plans to publish an updated policy manual by Oct. 1.
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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