Payroll-Based Journal Reporting – Are You Prepared for an Audit?

November 17, 2016 Tom Jegou

As mandatory reporting of Payroll-Based Journal Reporting (PBJ) goes into effect, many long-term care facilities are evaluating their PBJ reporting process. In addition to reporting, it is important to prepare for potential future audits from Centers for Medicare & Medicaid Services (CMS) and to ensure that PBJ submissions meet the requirements.

Now is a great time for organizations to consider whether or not their PBJ submission is audit-ready. If not, it's time to consider a reporting solution that can withstand an audit.

Watch out for these red flags when preparing for a PBJ audit:

  • Non-integrated workforce management systems
  • Manual data entry that can introduce human error
  • Audit records that are difficult to create and manage

Really, A PBJ Audit? - Well, there is good news and not so good news when it comes to a PBJ audit. The good news is that CMS has indicated that they are working on the audit process. The not so good news …there will be an audit process.

The details of that process aren’t available yet.  But CMS stresses that long term care facilities have well documented systems and that they make the data auditable and traceable back to payroll, time and attendance or another verifiable source

When someone from CMS does potentially come on site to check the accuracy of the data there are a few things to keep in mind. They will want to see a clear audit trail back from the reports submitted to the source data and documentation that the hours submitted in PBJ were indeed for hours paid and worked.

What are the Penalties? - Let’s start with the good news again. CMS may refrain from imposing enforcement remedies while providers adjust to the new requirement (i.e. for good faith effort).

On the flip side, CMS retains enforcement authority (e.g. civil money penalties) for noncompliance with all requirements for participation, including this new requirement for reporting staffing data. The CMS provided this info. in a Survey and Certification memo entitled Payroll Based Journal (PBJ).

It’s all About Quality Care - CMS focuses on staffing as one of the vital components of a nursing home’s ability to provide quality care. Over time, CMS has utilized staffing data for a myriad of purposes in an effort to more accurately and effectively gauge its impact on quality care in nursing homes.

The CMS also posts this information in the CMS Nursing Home Compare website. It also uses it in the Nursing Home Five Star Quality Rating System to help consumers understand the level and differences of staffing in nursing homes. That’s all good news for quality care – and the reason behind the need to verify data.

What are Some of the Gotcha’s with Payroll-Based Journal Reporting? - Manually entering payroll-based journal data can be expensive, time consuming. A bigger challenge is that it can introduce errors and require paper trails that lead to future headaches when it comes time for an audit.

There is a bit of a silver lining here for organizations ramping up their Payroll-Based Journal Reporting -- CMS will provide individualized reports to providers that will help facilitate compliance with this requirement.

A Good Faith Effort Helps - During the initial reporting periods, CMS indicates they will look for good faith efforts from an organization submitting data.  CMS will expect organizations to register and submit data and they will work with organizations to improve data quality going forward.

How will CMS audit the data? - CMS has not disclosed how they will be auditing the data collected through the Payroll Based Journal. The CMS does reference the need for accuracy. Staffing information is required to be an accurate and complete submission of a facility’s staffing records. CMS will conduct audits to assess a facility’s compliance related to this requirement.

Parting thoughts - It’s always good to prepare. In this case, laying the foundation for an accurate and auditable PBJ submission is a good first step.  Third party system integrations can add to the complexity and the difficulty in submitting an automated and auditable data submission.  A single, unified workforce management solution from SmartLinx with Payroll-Based Journal Reporting is designed to reduce risk and complexity while adhering to CMS requirements.

When streamlining the Payroll-Based Journal Reporting process, we suggest eliminating manual data entry whenever possible to reduce human error, and ensuring all data is auditable and always tied back to payroll, time and attendance and other verifiable sources.

Now is the time to work towards an automated and auditable solution to save time, eliminate errors and prepare your organization for any potential future audit.

For information on how SmartLinx can help your organization with Payroll-Based Journal Reporting, contact

Helpful Tools

  • Replay the SmartLinx webinar in conjunction with Advancing Excellence & the CMS:
    View the Webinar

About the Author

Tom Jegou

As Compliance Expert at SmartLinx, Tom Jegou oversees SmartLinx innovations in our payroll and compliance systems. Tom is focused on transforming client needs into leading-edge products. Tom leads cross-functional teams from a product's conception through to its launch. Tom led the design of the 1095-C and Payroll-Based Journal reporting features in the WorkLinx<sup style="font-size: 60%;">TM</sup> suite. Since 1996, Tom has worked with every aspect of Human Capital Management Systems. He has defined, supported, implemented and managed Payroll, Time and Labor and HR systems. Tom is a Certified Payroll Professional through American Payroll Association.

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