As the deadline for mandatory Payroll-Based Journal reporting by long-term care facilities approaches, many nursing homes are beginning to realize that compliance success requires capabilities well beyond payroll applications.
Payroll-based Journaling requires more than just payroll: The myth that payroll system providers can inherently provide a complete Payroll-Based Journal reporting solution has been causing a great deal of confusion. A growing number of vendors are advertising “PBJ” solutions, and it’s important to understand that most information necessary for accurate reporting won’t be available within a standalone payroll offering. Key questions to ask when considering an external PBJ solution should center on the vendor’s depth of understanding of the requirements and the ability of their solution to provide the very exact and granular data required.
Most payroll systems simply lack the detail required by the Centers for Medicare and Medicaid Services (CMS). What’s missing is the information most commonly captured in Time and Attendance and Human Resources systems.
Too Important to Get Wrong: Organizations must report not only the actual hours worked, but also provide the number of hours per day that each staff member provided direct care, for each direct care position that they worked on that day. Further complicating matters, “staff” in terms of PBJ reporting will frequently include agency and contract workers, many of whom are often not tracked through payroll systems.
Staffing hours must also be mapped to an exact and evolving list of job categories and titles defined by the CMS. Shifts that span midnight can also require process changes. CMS wants hours reported for the day that they were worked. Many nursing homes currently attribute these shifts entirely to either the starting or ending day of the shift.
The rules have also changed multiple times, and it’s expected there will continue to be updated PBJ Policy documents issued by the CMS. Your compliance will depend on the diligence your vendor has put into understanding these requirements, implementing a system that will produce a compliant report, and, importantly, maintaining that level of compliance in the face on ongoing policy updates issued by CMS.
The Bottom Line: Be sure your PBJ provider is able to ensure your compliance. PBJ Reporting requires a team, a plan, and an integrated, cross-functional data set of data. It’s important to ensure that your PBJ provider has the depth of understanding and level of detailed data required for compliance success, particularly if you’re counting on your payroll vendor to help you with mandatory reporting.
The PBJ report is centered on the number of hours nursing homes deliver direct care, and is complemented by HR-related data and Resident Census. Many nursing homes will require new processes and a means to capture employee details, especially for agency staff. They’ll also need to ensure there are unique, non-personally identifiable IDs set up for all direct care staff. The heart of PBJ reporting, the actual hours spent providing direct care, needs to be closely tracked, and logged for audit and verification purposes.
Talk to the Payroll-Based Journal Experts at SmartLinx: Regardless of your approach to CMS PBJ compliance, it’s imperative to make a plan, and start implementing that plan as soon as possible. SmartLinx has been helping clients produce and submit PBJ reports since CMS initiated the voluntary reporting period in October, 2015. Our PBJ solution component of our WorkLinx ACA Director product automatically assembles accurate information from well-integrated HR, Payroll and Time and Attendance systems. It enables organizations to administer CMS job code mappings, process shift splits across multiple days, and produce CMS-compliant XML files. Whether merging or replacing PBJ report data, with just a few clicks, SmartLinx users may report on employees, staffing and/or census, for any period within the reporting window. Talk to the experts today. Time is running out on Mandatory Payroll-based Journal reporting!
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