By now, most long-term care providers recognize that the Center for Medicare and Medicaid Services (CMS) Payroll-Based Journal (PBJ) submissions are here to stay. And with experiences gained during the voluntary reporting period, some organizations are thinking about ways to streamline the reporting process going forward.
We’ve talked with hundreds of providers as they prepare for PBJ submissions – many in various stages of readiness. In this post, we’ve identified some of the most important tips to keep in mind as you manage the PBJ submission process.
Our “must-have” payroll-based journal tips:
1) Your Five-Star Quality Rating depends on this
We know that staffing is one of the vital components of a long-term care facility’s ability to provide quality care for its patients.
- It’s important to test the resident to direct care hour ratios compared to the new CMS standards because this data is going to have an impact on your CMS Five Star Quality Rating.
2) Streamline and automate whenever possible
As you gather data from systems such as payroll, HR and time and attendance and third party systems for contractors or agencies, it’s always a good idea to consider how to streamline automate the reporting process to help save time and money.
3) Manual data entry can be costly
Manual payroll-based journal data entry may sound easy – but it has many drawbacks. When you factor the labor costs for manual data submission, system access and potential for human errors, automated submission can offer significant advantages.
4) Mind the gaps [in your data reporting]
There are a few key data collection points to keep in mind as you prepare your PBJ the submission:
- Accurately report direct care – Organizations need to map their positions and job descriptions to the CMS list. That’s right there are 40 of them and they need to match.
- Ensure all agency and contract staff are accounted for. This data will be combined with staffing data and it’s important to have a process in place for collecting auditable data for these groups.
- Assign a unique ID for employees and agency staff. This ID cannot contain personally identifiable information and can’t be duplicated or used for multiple employees (exempt, non-exempt, contractor).
- Accommodate staff with different roles throughout the day. Your system of record and process should divide time by role throughout the day and break work hours into each category of work (for example, CNA hours vs. dietary aid hours for same employee in a shift)
5) Beware of the midnight divide
The CMS requires that hours must be split at midnight at the end of a calendar day. So, when collecting PBJ data it is important to ensure that data is accounted accurately for the correct day.
6) Make it auditable and verifiable
Data should tie back to payroll, invoices, a contract or time and attendance system. The hours must be based on payment. It’s important to report work hours that contribute to direct care — not vacation, sick or other non-work time. So keep detailed records, preferably in electronic format.
7) Leverage Workforce Management solutions
PBJ requires tracking data from a variety of systems including HR, Payroll, Time and Attendance and third-party data sources for agency and contractors. Don’t rely on payroll alone to provide all of the needed data.
The Bottom Line
No matter where you are in the PBJ preparation process, now is the time to take a closer look at your process and drive a process that is simple, accurate, automated and auditable.
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. Let us share what we’ve learned with you to make life easier for your employees and your organization.
To learn more about the WorkLinx PBJ solutions visit:
SmartLinx Payroll-Based Journal Solution
Replay the SmartLinx webinar in conjunction with Advancing Excellence & the CMS:
View the Webinar
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