A new baseball season is under way, and players are once again ranked by their stats: batting average, RBIs, strikeouts, wins and more. In long-term care, facilities also are judged by the stats that make up their Five-Star Rating from the Centers for Medicare & Medicaid Services (CMS): health inspections, staffing, and quality measures.
In terms of staffing, Payroll-Based Journal (PBJ) reporting contributes data that CMS uses to rank facilities. Potential residents and investors are like scouts, looking for all-star facilities. So how do you ensure that your facility achieves major-league status?
Know the PBJ Playbook
As of April, CMS began using PBJ data to determine each facility’s staffing measure on the Nursing Home Compare tool on Medicare.gov, and to calculate the staffing rating used in its Five-Star Quality Rating System. CMS released an official memo, dated April 6, detailing the transition. Previously, CMS used staffing measures derived from the CMS-671 form and case-mix based on Resource Utilization Group data or RUG-III. In fact, beginning June 1, CMS will no longer require providers to complete the staffing portion of CMS-671.
Note that CMS is not relying solely on staffing reported through the PBJ system. It is combining this data with resident census derived from Minimum Data Set (MDS) assessments, and the case-mix based on RUG-IV.
Be Aware of Changes in the Lineup
Think of CMS as a switch hitter. It has switched up its annual Long-Term Care Survey Process (LTCSP). Previously, the format involved summary-level reporting by position every two weeks. Now, reporting is by employee by day. The data is much more granular.
Just as baseball players face fines or being benched for infractions of league rules, nursing homes can face sanctions for PBJ noncompliance. Last year, CMS threw the industry a curveball when it initiated a pilot PBJ audit program. Today, audits are a reality, and facilities with significant inaccuracies between the hours reported and the hours verified will receive a one-star staffing rating. This, in turn, will reduce the facility’s overall (composite) rating by one star for a quarter.
Following are common errors you should avoid when submitting PBJ data:
- Failure to exclude time for meal breaks
- Failure to assign each employee must a unique identifier (ID)
- Failure to submit MDS assessments in accordance with 42 CFR §483.20 and the resident assessment instrument (RAI) 3.0 User’s Manual
- Failure to exclude hours for staff providing care to individuals in non-certified areas of a larger institution or institutional complex that houses the certified facility
- Failure to respond promptly to the audit contractor if contacted for an audit
Train in the Off-Season
Baseball players in training don’t see immediate results. In terms of performance, the payoff for athletes comes after months of training. Likewise, you won’t see an immediate impact on your Five-Star Rating when you submit PBJ data. Next week — May 15, to be exact — is the next submission deadline. Here’s what to expect:
While you obviously can’t change the data you’ve submitted in the past, you can make sure that the data you submit in the future is clean, accurate, complete and timely. In other words, don’t drop the ball. Now is the time to take advantage of predictive analytics and predictive scheduling to ensure that you will not be under-staffed.
The Problem of Free Agents
In baseball, team loyalty is not a given, at least not from the players’ perspective. It’s common for players to jump from one team, even one league, to another. So too in long-term care. Turnover is a huge problem in the industry, and CMS is attempting to address this, as consistency of staff directly impacts quality of care.
CMS previously mandated that facilities provide term dates for staff, later making this optional. At first glance, it would appear that CMS is easing up on data related to turnover. However, the opposite may actually be the case. Instead of relying on turnover data provided directly by facilities, CMS might move to pull such data from sources outside providers’ control. In any case, providers would be wise to keep their rosters intact.
Betting on the Odds
It’s a good bet that CMS will step up its PBJ audits, given the fact that they have moved from pilot stage to the real thing. Just look at changes that occurred with the LTCSP. Instead of a single, two-week annual audit, CMS might decide to conduct a year-round validation process.
Based on current trends, it’s safe to predict that CMS will continue to diversify its sources of data. For example, it previously relied on census data and now is incorporating MDS.
When it comes to PBJ, you can’t afford a swing and a miss. Every strike against you can possibly result in one less star for your Five-Star Rating.
That means one thing: You’ve got to up your game.
Put SmartLinx on your PBJ team. Keep an eye out for an invitation to our upcoming webinar in July, which will take a deeper dive into PBJ. And check out our PBJ solution, which makes simplifies reporting to CMS.
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