As of today (Nov. 20), the Centers for Medicare and Medicaid Services (CMS) is updating its submission requirements for Payroll-Based Journal (PBJ) reporting. Several significant changes take effect today but, in many ways, there will be very few day-to-day changes for facilities submitting PBJ data to CMS. Here’s a rundown of what you need to know about the changes and what they could reveal about the future of the Five-Star Rating system.
Linking Employee IDs
- With this release, CMS will introduce a second file into the PBJ submission process: the new PBJ Administration Submission File.
- CMS expects that all facility staff will be issued a single unique employee ID. In cases where an employee has been issued multiple IDs, the new PBJ Administration Submission File is designed to link these records.
- CMS published an Excel template for facilities to use when creating the Administration Submission File.
- Facilities will not be required to submit an Administration Submission File with each PBJ submission, but the CMS is encouraging facilities to use the file as needed to link multiple employee records.
- The employee IDs submitted in the PBJ Administration Submission File must already exist in the PBJ database.
- Employee records must be added using the standard PBJ file before linking them with the PBJ Administration Submission File.
- Only two employee records can be linked with the current model.
- Expect an update in the future to add additional linking functionality.
CMS will calculate employee turnover without employee hire and termination dates
- CMS plans to introduce additional turnover and tenure metrics for measuring the quality of care in future updates to the Nursing Home Compare site.
- CMS expects the new feature linking employee IDs will assist in measuring turnover and tenure for facility staff.
- CMS will estimate tenure based on staffing statistics submitted with PBJ data.
Reporting census data in the PBJ submission is now optional
- Entering resident census for the last day of each month on PBJ Submission is now optional.
- Going forward, CMS will use Minimum Data Set (MDS) data to calculate a daily resident census for each facility.
- The census calculated based on MDS data will be used in Five-Star Rating determinations when the CMS moves to PBJ data for the source of staffing hours.
- See question 19 in the CMS Policy Manual FAQ (Sept. 26) for additional details on how the census will be calculated based on MDS submissions.
Despite multiple announced changes, the PBJ XSD file and File Spec version will not change from fiscal Q4 submissions
- PBJ entries on or after Nov. 20 will use PBJ XSD file V2.00.3 and File Spec Version 2.00.3
- A separate XSD file and Excel template were published for use with the PBJ Administration Submission File.
So what does this mean for long-term care facilities?
While CMS has removed the requirement to submit employee hire and termination dates in the PBJ, it is clearly interested in tenure and turnover as measures of the quality of care. And, while CMS removed the requirement to submit patient census in the PBJ, this data is key to calculating the staffing ratios used in the Five-Star Rating. In both cases, CMS is moving away from data supplied directly from facilities in their PBJ submissions to calculating this data independently.
The data used for calculating Five-Star Ratings on the Nursing Home Compare site will be derived from various sources. This means it will be more important than ever to ensure consistency in the data used to track employees, staffing hours and patients. In addition, it will become even more difficult to reconcile inconsistent data in the event of an audit.
Learn more about our Payroll-Based Journal software solution, which includes reporting on direct care staffing information, including agency and contract staff, and census information.
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