The transition to using Payroll-Based Journal (PBJ) data for Nursing Home Compare and the Five Star Quality Rating is finally upon us. In a new QSO memo dated April 6, 2018, the Centers for Medicare & Medicaid Services (CMS) announced that this month the Agency will being to use Payroll-Based Journal data (which was originally announced in 2015) to determine the staffing measure for Nursing Home Compare and to calculate the staffing rating used for the Nursing Home Five Star Quality Rating System.
Staffing measures and staffing star ratings will be calculated based on data submitted for Calendar Quarter 4 2017 that was received prior to the February 14, 2018 deadline. CMS had mentioned this change in a S&C memo in November 2017 when it announced upcoming changes to the Five Star rating and Nursing Home Compare based on the switch to the LTCSP. Additionally, the Staffing domain ratings methodology will be updated to use the RUG-IV system for calculating adjusted staffing levels. Prior to April 1, 2018, this adjustment was made by multiplying the actual staffing measure by the expected nursing hours measure that was based on each facility’s resident distribution based off RUG-III groups. CMS notes that it expects that the number of nursing homes in each rating category will be the same, but with the change to the risk adjustment methodology that some facilities will see a change in their ratings based on differences in the data submitted by the old process vs. the new process.
More facilities may see a 1-star rating in staffing
The memo outlines several situations that may result in a 1-star rating for staffing. First, nursing facilities that have been audited and “significant inaccuracies” identified between hours reported and hours verified will be presumed to have low levels of staffing. This same assumption will also be made for facilities that fail to submit PBJ data by the required deadlines. These facilities will see a one-star rating on their staffing domain, which results in an overall star rating reduction of 1 star for that quarter. Additionally, there is a third instance that relates to nursing homes that report 7+ days in a quarter with no RN hours. Facilities that do not have these RN hours will see a one-star rating on the staffing domain beginning July 2018 (after the May 15, 2018 PBJ submission deadline). Before July 1, 2018, those facilities will have an icon placed next to their facility names on Nursing Home Compare to indicate their status related to RN staffing. According to the memo, facilities in rural areas with an RN waiver will still be subject to the staffing rating methodology even though they aren’t required to have an RN onsite 8 hours day/ 7 days a week.
Say goodbye to the CMS-671 Form
Providers will probably be excited to hear that as of June 1, 2018, CMS will no longer be using the CMS-671 form to collect facility staffing data. Information that is requested on the 671 form that is not related to facility staffing will still be required, such as address and ownership type, for the time being.
Public Use Data Files and Future Measures
CMS notes that the public use staffing data files continue to be available for use. In future quarters, other data elements will be included in the files. The Agency also notes that additional measures for reporting on Nursing Home Compare will be developed, including Staff Turnover.
PBJ Audits Underway
The QSO memo also includes a Q&A section with several pages of useful information as well as a list of commonly identified issues found on PBJ audits. CMS and a contractor have been conducting audits to verify if facility-submitted hours are aligned with the hours that their employees were paid to work over the same timeframe. The memo states that nursing homes will be contacted via email and certified mail sent to the administrator if they have been selected for an audit and that they need to respond to the auditor promptly to verify compliance.
As mentioned previously, facilities that are audited and where significant inaccuracies are identified will be presumed to have low levels of staff, resulting in the facility receiving a one-star staffing rating, which will lower the facility’s overall star rating by 1 star for the quarter.
View the April 6, 2018 CMS QSO memo, “Transition to Payroll-Based Journal (PBJ) Staffing Measures on the Nursing Home Compare Tool on Medicare.gov and the Five Star Quality Rating System” (Ref: QSO-18-17-NH).
