We've talked with hundreds of long-term care and post-acute care providers as they prepare for Payroll-Based Journal (PBJ) submissions – many in various stages of readiness.
Here are a few things to keep in mind. When you staff your facilities, it's important to keep your Five-Star Rating in mind and proactively schedule staff to meet your desired rating.
After all, Five-Star Ratings can make or break your reputation and carry long-lasting financial implications. First, they determine your per patient, per day Medicare reimbursements.
Brookings Institute: a nursing home that receives three stars in an on-site inspection may only expect a $10.44 profit from treating one patient for one day.
However, if an operator gains two additional stars after self-reporting and achieves an overall rating of five stars, the profit can increase to 16.88 per patient per day. Five-Star Ratings also influence referrals, lending and insurance rates.
Compared to other federal reporting requirements, creating Payroll-Based Journal reports is considered very challenging, often taking days to compile. Completing PBJ reporting requirements is labor-intensive and error prone, with mistakes jeopardizing a facility's Five-Star Rating. Long-term care and post-acute care providers face dueling challenges. Meeting federal staffing requirements is extremely difficult considering the nursing shortage, which the pandemic exasperated. Even before the pandemic hit, 75% of nursing homes failed to meet the CMS requirement to have a registered nurse onsite 8 hours a day.
The Payroll-Based Journal reporting requirement is especially challenging for facilities that try do it manually or try to piece it together from different systems.
Payroll-Based Journal software was designed to simplify and streamline long-term care operators' efforts to track and prove that their staffing meets government requirements.
Not all Payroll-Based Journal software is the same though. Many PBJ reporting software applications simply help skilled nursing administrators pull historical payroll-based journal records to make it easier for them to piece together reports.
More proactive ones constantly collect and store staffing and attendance data. They provide real-time compliance tracking instantaneously and simply.
Here are our must-have tips for Payroll-Based Journal Reporting
1. Streamline and automate whenever possible
As you gather data from systems such as payroll, HR and time and attendance and third-party systems for contractors or agencies, it's always a good idea to consider how to streamline automate the reporting process to help save time and money.
2. Avoid manual data entry, which can be costly
Manual Payroll-Based Journal data entry has many drawbacks. When you factor the labor costs for manual data submission, system access and potential for human errors, automated submission can offer significant advantages.
3. Mind the gaps in your data reporting
There are a few key data collection points to keep in mind as you prepare your PBJ report.
Accurately report direct care – Organizations need to map their positions and job descriptions to the CMS list. That's right there are about 40 of them and they need to match. Ensure you properly account for all agency and contract staff. This data will be combined with staffing data and it's important to have a process in place for collecting auditable data for these groups.
Accommodate staff with different roles throughout the day. Your system of record and process should divide time by role throughout the day and break work hours into each category of work (for example, CNA hours vs. dietary aid hours for same employee in a shift)
4. Beware of the midnight divide
CMS requires that hours must be split at midnight at the end of a calendar day. So, when collecting Payroll-Based Journal, remember to ensure the data is accounted accurately for the correct day.
5. Make it auditable and verifiable
Data should tie back to payroll, invoices, a contract or time and attendance system. The hours must be based on payment. It's important to report work hours that contribute to direct care — not vacation, sick or other non-work time. So, keep detailed records, preferably in electronic format.
Proactive Payroll-Based Journal systems promote business goals by boosting your reputation and employee engagement. Other reactive Payroll-Based Journal functions simply pull historical records with a lot of manual intervention.
To generate compliance reports in minutes rather than days, you need a Payroll-Based Journal software that integrates fully with the workforce management system. When it integrates with nurse scheduling and attendance management functions, the PBJ reporting system can immediately track and prove compliance for any day and time.
You should be able to check the app to keep track of the status of your employee staffing so you will always know within moments if you're in danger of falling out of compliance. This is both for general staffing requirements as well as the mandate for RN coverage.
For example, an integrated workforce management and Payroll-Based Journal system can alert administrators of scheduling gaps that jeopardize CMS compliance, such as days without a registered nurse onsite. Then they can fill the open shifts before they become compliance violations threaten their ratings.
The integrated workforce management system should also help identify and notify qualified staff, enabling them easily to sign up to fill open shifts. And by making it easy for employees to gain access to schedules and swap shifts, SmartLinx can help avoid scheduling gaps from happening in the first place.
An integrated compliance and workforce management system should also give you at-a-glance views of compliance across your business, as well as automated data collection and reporting. In addition, it provides detailed reporting and checks to ensure you meet every CMS criterion.
For example, the PBJ reporting software should track agency workers the way it does regular employees. It must also account for shift variations, such as overnight shifts, also known as the midnight divide, and meal breaks. It's comparatively minor details, like failing to track and include meal breaks that can lead to big penalties. The right PBJ reporting technology and partner can help cover all the bases.
This on-demand reporting can be a reputation saver when auditors unexpectedly show up at your door. To pass a surprise inspection, you need a Payroll-Based Journal system that incorporates real-time scheduling and attendance, enabling operators to know about changing conditions and generate compliance reports on the fly.
To give one example of how this works, an integrated PBJ reporting system helped an Illinois operator to meet the challenges presented by a surprise inspection from the state's Department of Public Health.
Inspectors demanded instantaneous proof that Greek American Rehabilitation & Care Centre complied with the state's staffing regulations. They understood the compliance challenges providers face and often assume non-compliance.
The health department survey team demanded the front desk produce proof immediately that the facility was properly staffed.
Fortunately, the facility was using SmartLinx's workforce management suite. So, the administrator could immediately open a chart that showed the facility maintained proper staffing levels.
Auditors also requested proof of staffing compliance to PPD census values for multiple random dates. The administrator used SmartLinx to instantly produce reports and screen shots that demonstrated the facility was compliant on those requested dates.
Workforce management applications also promote full staffing by enhancing employee engagement and making it easier for them to fill staffing gaps. A mobile workforce management app does this by empowering staff to set their schedules and facilitating communications between management and staff.
Maintaining sufficient staffing levels is crucial to enabling facilities to meet Payroll-Based Journal requirements. Proving you did so is critical to passing a surprise inspection and achieving your desired Five-Star Rating.
Five-Star Ratings can make or break a facility's reputation and thereby ability to successfully maintain its business. This is because a facility's Five-Star Rating serves as a guide for residents and families who are looking for the best facility to meet their needs. The pandemic accentuated the need to review Five-Star Ratings by limiting in-person visits, tours, and interviews.
Medicare also bases its reimbursements on facility ratings, which can have an enormous impact on the operator's income stream. Potential investors likewise pay close attention to facility ratings.
Of all the factors that influence these prized Five-Star Ratings, staffing is the most challenging, particularly in an age with chronic staffing and nursing shortages.
Staffing ratings affect per-patient Medicare reimbursements, as well as insurance and a facility's reputation and ability to get new residents. The U.S. Department of Housing and Urban Development also uses ratings to assess risk when it makes decisions about lending.
It's not difficult to the growing influence of Five-Star Rating and how a reduction in a facility's rating can have a devastating impact on that facility's finances.
In conjunction with integrated workforce management software and analytics, the right technology can even help predict and improve Five-Star Ratings. When operators maintain a good Five-Star Rating, they're better positioned to improve their quality care and their bottom line.
Payroll-Based Journal software has helped skilled nursing operators demonstrate compliance for nearly six years. Now when combined with new analytics and an integrated workforce management platform, the PBJ reporting system can put five stars within an operator's reach.
Until recently, operators couldn't proactively manage their Five-Star Rating. Although they knew what staffing levels were required to achieve their desired rating, they lacked the technology to proactively monitor and improve their Five-Star Rating.
Now, you have access to Five-Star Predictor technology that can predict your next Five-Star Rating for staffing at each of facilities and tell you how to improve it by:
You can also track trends for your entire enterprise at-a-glance and then dig further to lower-level data.
No matter where you are in the PBJ preparation process, now is the time to take a closer look at your process and drive a process that is simple, accurate, automated and auditable.
Talk to the Payroll-Based Journal Experts at SmartLinx: Regardless of your approach to CMS Payroll-Based Journal compliance, it's imperative to make a plan, and start implementing that plan as soon as possible. SmartLinx has been helping clients produce and submit PBJ reports since CMS initiated the voluntary reporting period started in October 2015. Let us share what we've learned with you to make life easier for your employees and your organization.
Request a personalized demonstration.