The Office of the Inspector General (OIG) released a new report on June 18, 2026, “CMS’s Processes Were Not Effective in Ensuring the Accuracy of Staffing Information Reported in the Payroll-Based Journal.” The report reviewed Registered Nurse (RN) staffing hours submitted by nursing homes to the Payroll-Based Journal (PBJ) system in March 2024. While the report only identified reported issues which were not supported by Federal requirements in about 5% of the submissions, the numbers that make up the 5% are pretty big – more than 900,000 hours for approximately 3000 RNs. The error trends are worth discussing further – could these be a problem in your facility’s reporting that you’re unaware of?
Key Issues Not Meeting Federal Requirements for PBJ Submission
The report identified several PBJ trends of concern – while also knocking the Centers for Medicare & Medicaid Services (CMS) for not sharing more trend information with providers to help avoid these issues. CMS, for its part, indicated that it does conduct audits to ensure nursing homes submit complete and accurate staffing data to the PBJ, but did not conduct follow-up audits to determine if nursing homes took corrective actions based on the audit findings. The report identified that nursing homes:
- Reported RN hours when RNs weren’t working
- Reported hours that RNs were not paid for
- Failed to report hours that RNs worked and were paid for
- Did not report RN hours by calendar day (shifts running more than one calendar day)
- Reported hours for RNs who were attending training and were not available to perform their primary role as an RN
- Reported hours for RNs who were not working on site
- Did not deduct meal breaks from hours worked
The last bullet may be one of the most significant to be aware of – meal break deductions. According to the PBJ Policy Manual, nursing homes cannot include meal breaks (paid or unpaid) in staffing time. This is the case even if the nurse does not actually take the break. If staff work a double, two 30-minute breaks must be deducted – even if they aren’t taken. Per the report, when facilities were asked about deducting meal breaks, several concerns were raised. First, some facilities stated that because the Department of Labor requires nursing homes to pay employees for time worked, that they did not deduct time for missed breaks for meals. Others indicated varying issues with their timekeeping systems. The problem with those concerns is that it seems many facilities weren’t even aware of the problem until OIG identified it and queried them.
OIG’s Conclusion
OIG concluded that many nursing homes did not fully understand or had misinterpreted Federal requirements for data reporting to PBJ. While OIG was completing this report, CMS issued updated Payroll-Based Journal FAQs (June 2025) which addressed some of the concerns, but OIG feels there’s more work to be done. OIG inspectors recommended that CMS shared audit trends and data to help nursing homes understand where they can pay closer attention to avoid errors.
Read the June 2026 OIG Report (A-09-24-02005) here or check out the highlights here.
