Payroll Based Journal- What?
Is your nursing home PBJ compliant?
And, why did Payroll Based Journal become law?
The decision to put a loved one into a nursing home is a difficult and emotional decision. Fortunately, there are facilities that provide the loving care and treatment needed for short term recovery, or long term care.
If your facility provides medicaid or medicare services, then you are familiar with the Five Star rating system and the surveys sent to care facilities.
The Centers for Medicare and Medicaid Services (CMS) provides a Five Star rating system so that consumers can compare nursing homes in three categories. These categories are: Nursing Staffing, Annual Inspection Results, and Quality Measures.
Did you know?
Critics of the system have pointed out that much of the data used for the ratings are based on information that is self reported.
The CMS has long believed that the quality of care is directly related to a nursing home’s staffing. It is considered so important that it has a one-third weight of the rating calculation for the Five Star rating system.
As a result, The Affordable Care Act (ACA), Section 6106, now requires skilled nursing facilities (SNFs) to electronically submit direct staffing information based on payroll and other auditable data.
The purpose of this is to standardize recording requirements and to collect information more regularly. This includes staffing information, which includes agency and contract staff, and facility census. PBJ allows for not only transparency in the ratio of caregivers to patients, but also provides information on employee turnover, which also affects care.
- Standardize reporting to audit verifiable information
- Collect information more regularly
- Provides information on the ratio of caregivers to patients and the turnover of the caregivers
CMS named their reporting system Payroll-Based Journal (PBJ). Because the reporting information is verifiable and and auditable, it should reduce fraudulent reporting. This helps to keep competition fair among long-term care facilities.
This is great for both providers and residents.
Facilities That Are Required to Use Payroll-Based Journal Requirements
Who has to comply with PBJ?
Long term care facilities that are required to meet the Requirements for Participation as specified in 42 CFR Part 483, Subpart B.
This means that, any skilled nursing facility that participates in Medicaid is required to participate in PBJ requirements.
Which Staff Members are Direct Care Staff Required by Reporting to the CMS?
Direct Care Staff are staff members who provide care and services to residents that allow them to attain or maintain the highest well being. This includes the highest physical, mental, and psychological well-being.
In addition, Direct Care Staff includes those individuals who care for staff personally through contact with residents and those in resident care management.
Yet, it does not include housekeeping and maintenance staff.
Often staff members have more than one role. Some of their roles would not qualify them as Direct Care Staff and other roles would.
Although this often happens, the CMS requires that jobs be reported according to the faculties primary job role. Faculties should report the total number of hours based on their primary role.
It is important to note, that this is based on primary role during their shift, not the employee’s primary role overall.
The CMS states that; “CMS recognizes that staff may completely shift their primary role in a given day. For example, a nurse who spends the first four hours of a shift as the unit manager, and the last four hours of a shift as a floor nurse.”
In other words. . .
This scenario describes, not a nurse who spends a few minutes on various roles, but a nurse whose primary work is as a manager and then a concentrated amount her shift occurs doing another primary work of directly caring for residents.
Fortunately, the CMS explains what should happen in this scenario; “In these cases, facilities can changes the designated job title and report four hours as a nurse with administrative duties, and four hours as a nurse (without administrative duties).”
PBJ Reporting Frequency
While CMS previously collected information annually vía surveys, PBJ now requires quarterly reporting. Mandatory reporting started on July 1, 2016. All long term care facilities can access the system at no cost to the facility. Facilities must report by the 45th day after the quarter ends.
- Quarter 1 January – March: Due May 15
- Quarter 2 April – June: Due August 15
- Quarter 3 July – September: Due November 15
- Quarter 4 October – December: Due January 15
If a facility misses the deadline, the PBJ system will still accept a submission, but the reports will not be considered timely and will not be used to calculate a facilities staffing measures.
Therefore, facilities should upload reports with enough time to verify that it has been received. The Final File Validation Report can be accessed through the CASPER (Certification and Survey Provider Enhanced Reports).
This takes 24 hours so facilities should upload their reports at least a few days prior to the deadline.
Requirements for PBJ
Payroll Based Journal Reporting requires many pieces of information. First, each direct staff care provider needs an individual ID number. Reports cannot use social security numbers.
For example, if a facility is using a system like SwipeClock’s TimeWorksPlus, then each employee can easily be assigned a specific number for timekeeping and payroll purposes. This means that a new ID number won’t have to be created for PBJ reporting.
This means that, it is vital that facilities keep and maintain an accurate record for each facility location that identifies their direct care staff and medical personnel. This includes registered nurses, physical therapist, licensed nurse practitioners, and other medical staff that participates in direct care.
Facilities can to maintain a record of direct care staff start and end dates of employment. Inputting this information into the PBJ system is optional.
In addition, tenure also needs to be recorded. , a record of the start and end days and the hours worked for each faculty must be kept.
It is optional for facilities to enter the resident census into the system.
Facilities need to maintain records of hours of care by category per direct staff member, each day.
Categories can be include physician, nurse, pharmacy, dietary, therapeutic, dental, podiatry, mental health, vocational, clinical laboratory, diagnostic x-ray, and other services.
- Category of work for direct care staff member
- Resident census data
- Information on direct care staff turnover and tenure
Who is Responsible for Payroll Based Journal?
Admin staff at the facility, usually those responsible for payroll should be the ones to input the reports for PBJ.
This can include Human Resources or Payroll staff.
Plus, it can also include vendors or accountants that provide payroll services for the facility.
Getting Registered to Report PBJ
The system for PBJ reporting is called Quality Improvement and Evaluation System (QIES). Facilities must register and obtain ids. Each facility is allowed 2 logins.
While using QIES, the user must have a file to upload or they will have to manually enter the data. It must be an XML file.
It does not allow users to copy and paste information.
However, if facilities using SwipeClock’s timekeeping software, can simply upload PBJ reports directly to QIES.
It is also important for the PBJ administrator to map job titles to the CMS defined codes to ensure they are in sync for reporting.
Common Compliance Issues
There are several common practices that the CMS has found to be out of compliance. One of these practices includes the use of manual timesheets.
That’s is because of the non-specific nature of manual timekeeping. Studies have found that manual time cards have the greatest amount of error.
Another mistake that facilities are making is to count hours that exempt employees spend in direct care.
Exempt employees can provide exempt care for residents, but it is important that they be paid a reasonable amount for those hours.
If an exempt employee provides care that is overtime care and they are not paid a “bonus” for the service, then those hours cannot be counted for PBJ.
Lastly, facilities that use contract or temporary workers often mis-document direct care hours. For contract workers, there is often a contract and various employees perform the work provided. There are several ways that contract direct care hours can be counted.
First, facilities can provide contract employees with logins so they can log in and out for work performed.
Second, contractors can provide an invoice with documentation for the specific hours that were direct care.
Third, contract staff can enter hours as a designee of the PBJ system for the facility.
Fourth, the contract staff can provide a XML file that meets the technical requirements of PBJ for submission.
Making Payroll Based Journal Simple and Affordable.
Unfortunately the requirements of PBJ require a certain amount of data entry (creating IDs for each employee, categorizing job functions, and preparing the files for upload).
However, much of the cost of PBJ can either be offset of reduced.
Facilities that use a timekeeping system, such as SwipeClock’s TimeWorks or TimeWorksPlus, can have PBJ reports automatically formatted and ready for upload to the CMS system.
Plus, facilities can use geo-timekeeping to track when direct care providers are at various locations. This makes it seamless to track hours per location for PBJ.
And, SwipeClock’s timekeeping suite comes with an Employee Self Service Portal, plus the tools you need for other employment law compliance!
Let SwipeClock Help
As a manager or administrator of a long term care facility, your main concern is to ensure the best care for your employees. This includes hiring and training the best talent and creating the right kinds of policies and the right mission.
Compliance with Payroll Based Journal shouldn’t be something that steals hours of your time or costs in administrative or software costs.
Written by Annemaria Duran. Last updated on March 5, 2018