CMS S&C memo – Payroll Based Journal update

The Centers for Medicare & Medicaid Services (CMS) issued a S&C letter on April 21, 2017 providing an update on the Payroll-Based Journal (PBJ). There are some interesting details in this update beyond just the data specification updates that CMS made on the PBJ website last week.

CMS notes that 91% of LTC providers submitted staffing data by the last deadline of February 14, 2017, and the Nursing Home Compare website has been updated with icons to reflect whether a facility submitted data or not. The next deadline for data submission is May 15, 2017, and the website will be updated after this deadline as well. Providers who miss two consecutive deadlines will have their overall star rating and staffing star rating suppressed on Nursing Home Compare until the data is received.

Providers are thus encouraged to submit data frequently throughout the quarter rather than waiting until right before the deadline. Providers need to check their Final Validation Report to ensure their data was submitted successfully. Since it can take 24 hours to receive a validation report, waiting until right before the deadline to submit data may not leave the necessary time for correction and resubmission.

CMS has been providing feedback reports to facilities on the data submitted from October 2016-December 2016, which includes some areas that CMS is emphasizing may be important moving forward:

  • Nurse staff information reported for each day in the quarter – if this is missing, then CMS may think that data submitted overall is incomplete, because, of course, a nursing facility would have nursing hours each day
  • Reported work hours of 80+ hours in 1 week for a single staff member (or 300+/month) – if this is reported, CMS believes there may be reporting errors
  • The reported census compared to a census calculated using MDS data – CMS may use this data to pull its own information on a facility’s census going forward so they have a census for each day of the quarter, rather than just the last day of each month in a quarter.

CMS is continuing to develop its auditing process for staffing data, but no details have been provided yet. The S&C memo states that the audit process will include both onsite and offsite audits to verify the accuracy of the staffing data that has been provided by nursing homes.

Read CMS S&C “Electronic Staffing Submission – Payroll-Based Journal Update” (Ref: S&C 17-25-NH).


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