When the Affordable Care Act (ACA) passed in 2010, the law had three primary goals—increase access to health insurance, expand Medicaid coverage, and support methods of medical care that would lower the cost of health care. Another part of the ACA was a provision requiring long-term care facilities to submit payroll-based journals as a way to standardize how quality of care is measured. Under Section 6106, long-term care facilities need to submit census information, which is now optional, and staffing information periodically. This information is submitted via a report called a payroll-based journal, or PBJ.
The goal of the payroll-based journal reporting requirement is to collect frequent and regular information from facilities to verify the quality of care and ensure standards are being met. The Centers for Medicare and Medicaid Services (CMS) also posts the information to their CMS Nursing Home Compare website, and it is used in the Nursing Home Five Star Quality Rating System to help consumers understand the level and differences of staffing in senior living facilities. This means getting a strong PBJ reporting strategy in place is critical for organizations hoping to maintain a high-quality rating to drive consumer confidence and interest in their services.
Falling out of compliance could hurt your consumer reputation and cost you money in the way of fines and resources needed to resolve any compliance missteps.
PBJ reporting was voluntary as of 2015 and became mandatory for all long-term care facilities as of 2016. In this article, we break down the basics of PBJ reporting and how you can ensure your facility remains compliant with the ACA.
CMS developed the payroll-based journaling system so that long-term and skilled care nursing facilities can regularly submit staffing information. Facilities should submit payroll-based journals to CMS on a set schedule, using an electronic format. The information submitted needs to be accurate and complete and should include information on agency and contract staff. A PBJ should also include information on the residents of the facility.
With a PBJ, it is easy to see how well-staffed or under-staffed a facility is. The journal also provides insight into the turnover rate of a facility. Usually, the higher the turnover rate, the lower the quality of care residents receive, as there is limited consistency. Facilities that have long-tenured staff and lower rates of turnover typically earn higher rankings and provide higher-quality care. This is just one of the many reasons it's important to give your staff the flexibility and tools they need to feel committed to your organization and increase your ability to retain your best employees.
CMS offers a Nursing Home Compare tool that lets consumers compare the quality of senior living facilities. The tool uses a five-star rating system that's based on three categories:
A facility that earns a five-star rating is "much above average," while a facility with a one-star rating is "much below average." A facility with a three-star rating is "average." The rating system accomplishes several goals. It lets consumers make informed decisions about where to send their loved ones or where to move themselves. It also gives senior living facilities an idea of what they need to do to improve their rating. Additionally, regulators use the rating to determine whether or not to approve a facility for renovations. Hospitals use the rating system when deciding where to refer patients.
Payroll-based journals play a crucial part in determining the staffing component of a facility's rating. Per CMS, two factors determine the staffing rating. The first is the total staffing hours, and the second is the number of registered nurse (RN) hours per day. Given the complexity of these two factors, submitting accurate PBJs can help your facility earn or maintain five-star status.
Facilities that need to submit a PBJ to CMS have two options for doing so. They can submit their data manually or upload data from an automated system. Whether your facility uses the manual submission method or an automatic upload, you need to include certain pieces of information in the reports. It's critical that you include the required information to maintain your facility's star rating.
The information you submit in a PBJ report should focus on the activities of direct care staff. CMS classifies direct care staff as workers who contact residents or management of resident care interpersonally. Direct care staff offer services that help residents achieve mental, psychosocial, and physical well-being as much as possible. People who primarily focus on maintaining the environment of a facility, such as the housekeeping team, do not count as direct care staff.
The report should categorize the type of work individual direct care staff members perform. For example, a person might be a therapist, licensed practical nurse, or registered nurse. Additionally, the report should provide information about how long each staff member has been working for the facility and the turnover rate. For each staff category, it should also include details on the providers' number of care hours per resident per day.
Resident census data can be part of the report. A PBJ should list the number of residents who receive Medicare or Medicaid and those who pay through other means. Providing detailed information about your direct care staff's activities, how much they work, and how long they've worked at your facility provides valuable data about your facility's turnover rate and overall quality of care.
When you submit a PBJ, CMS expects you to include specific information about each member of your facility's direct care staff. The employee information you need to include in a PBJ is:
The number of job title codes and the need to give every employee a unique ID can make manually inputting PBJ data an overly complex chore. Software that streamlines the data entry process and that automatically calculates hours worked and work dates makes the process smooth and painless.
Facilities have the option of including resident census data when they submit a PBJ. If you decide to include census data, you can input the number of residents whose primary payer is Medicaid, Medicare, and Other on the last day of each month.
You can submit a PBJ using manual submission, meaning someone from your facility inputs the relevant data by hand into the CMS system. Manual submission takes a considerable amount of time and can lead to data entry errors. Another option is to use an automated time tracking and payroll system to format the data to meet CMS standards and requirements for you.
Using an automated software program minimizes the risk of human error or data entry mistakes. It also saves your team time and energy, allowing them to focus on more important issues, such as providing the best care possible to residents. If you decide to automate the submission process, make sure you choose a software program that fully complies with CMS regulations and specifications.
CMS uses the data found in a PBJ as part of its facility evaluation and ranking process. Staffing is one of the measures CMS uses to determine how to rank a facility. If the data in a PBJ reveals that a facility is consistently understaffed, it could drop down in the rankings. Facilities that rely on contract workers or higher turnover rates can also see their rankings drop.
PBJ reporting helps keep a facility accountable, as the information it submits needs to be accurate for the facility to remain in compliance with CMS. Along with being accountable, using a PBJ can also lead to an improvement in the quality of care your facility provides. By aiming to reach CMS' scheduling measures, your facility can see a dramatic improvement in the care it provides. Using an automated software solution helps ensure the journal data is accurate, allowing a facility to maintain a high-quality rating from CMS.
Since the payroll-based journal requirement was first introduced, many in the industry have had questions about how it works, who needs to use it, and how to streamline the process. Here are some answers to a few of the most commonly asked questions about payroll-based journal reporting:
Under section 6106 of the ACA, all long-term care facilities need to submit quarterly PBJs. A long-term care facility is an organization that offers skilled nursing to patients or residents who need help with everyday activities. Facilities for older adults, long-term chronic care hospitals, rehabilitation centers, and behavioral health facilities that provide inpatient services are all examples of long-term care facilities that need to submit a PBJ. Part 483, Subpart B of the Code of Federal Regulations further defines a long-term care facility.
A PBJ needs to contain certain pieces of information. Notably, it should contain employee identification in the form of unique employee ID codes and a coded description of their job title. It should also include information on the number of paid hours performed by an employee and the work dates.
The journal should include information regarding employee tenure, such as their hire or start date and the termination date, if applicable. You can also include information on the number of residents at the facility at the end of each month.
You can report paid hours in the PBJ, which might not be the same as the total hours an employee works. You should also subtract the length of time for meals taken by an employee each day. Use decimals, rather than hours and minutes, when reporting paid time.
For example, instead of reporting that an employee worked 7 hours and 15 minutes, record 7.3 hours paid. When calculating decimals, every six minutes counts at 0.1 hours. Round up to the nearest tenth when reporting. An employee who worked 7 hours and 45 minutes should be recorded as having worked 7.8 hours. Keeping track of hours this way can get incredibly mind-numbing and is prone to a myriad of inaccuracies, which is another reason many in the industry are turning to software to automate the process.
Use a PBJ to report paid hours of direct care staff. CMS codes 1 through 40 include both direct care and nondirect care staff. Examples of direct care staff are nurses, nurse assistants, occupational therapists, and physician assistants. Examples of nondirect care staff, who don't need to be reported in a PBJ, include clinical laboratory service workers, housekeeping service workers, and diagnostic X-ray service workers.
You should submit a PBJ every quarter. The reports are due by the end of the day on the 45th day after the last day of the fiscal quarter. For example, you should submit the PBJ for quarter 1 no later than 11:59 p.m. on February 14. Missing a deadline can mean a drop in your facility's star rating.
Below is a list of CMS fiscal quarters and their corresponding PBJ report due dates:
How you format PBJ data depends on your submission method. If you use an automated software program to submit data, you should upload an XML file to the CMS website. The XML file needs to meet the requirements of CMS. Using software allows you to quickly enter and submit your PBJ data, meaning there will be one less thing on your to-do list.
If you input data manually, you will enter it using the CMS interface. The system is user-friendly and will walk you through the process of inputting data. As you enter data, save the information to avoid having it get lost if your system crashes or there's an issue with the computer you're using.
CMS expects long-term care facilities to include paid hours for contract workers who provide direct care, even if the workers are employees of a third party, such as a staffing agency. CMS offers three options for reporting contract worker hours. They can be included in the attendance system your facility uses, they can be entered as designees of the facility, or the staffing agency or vendor can provide your facility with an XML file that includes hours for contractors.
If your organization is operating in good faith in attempting to accurately submit and report employee hours, CMS will likely work with you to correct any missed deadlines or incorrect information reported. If you miss a deadline and don't take steps to correct it, your facility's rating can fall to one star on CMS's Five Star Rating system, which can mean fewer potential residents consider your facility.
Although manual entry is an option for PBJ reporting, it can be time-consuming and ripe for errors. If your staff is very busy, it's easy to overlook manual reporting, leading to missed deadlines. One way to streamline the submission process is to fully automate it. SmartLinx centralizes data on your employees and automatically collects the information you need in one place, producing accurate journal reports with just the click of a button.
If you change the process you use to submit your PBJ, there is a chance that the new system will create new employee IDs for each staff member. While it's preferable to maintain staff IDs, you can try to link the old identifiers to the new ones if it's not possible. The new software you use will need to align with CMS's technical specifications.
Make sure your facility remains compliant with the ACA by submitting your payroll-based journals online and with accurate data. You don't need to rely on outdated manual reporting methods to get the job done. SmartLinx offers workplace management tools designed specifically for the needs of long-term and skilled nursing care facilities. Our software platform delivers everything you need to effectively manage your staff and maintain compliance. To learn more, schedule a demo of our software today.