CMS Payroll-Based Journal

ACA Reporting Guidelines for Long-Term Care Facilities (PBJ)

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Section 6106 of the Affordable Care Act (ACA) requires nursing home facilities to electronically submit direct care staffing information, including employees and contractors, based on payroll and other auditable data. According to CMS, the data combined with census information, can then be used to not only report on the level of staff in each nursing home, but also to report on employee turnover and tenure, which may impact the quality of care delivered. The premise of the report is to define:

  • WHO worked
  • HOW MANY HOURS
  • performing WHAT JOB (*must map to one of the PBJ defined job codes)
  • at WHAT FACILITY
  • on WHAT DAY

CMS has developed a Payroll-Based Journal (PBJ) system for facilities to submit staffing and census information, on a voluntary basis beginning on October 1, 2015, and on a mandatory basis beginning on July 1, 2016. PBJ 2.0 Submission Specs V2.00.0 was released on June 26, 2016. Facility providers will be required to file both staffing and census data no later than 45 days after the last day of each Federal Fiscal Quarter. The first submission is due no later than 11:59 pm EST on November 14, 2016.

CMS also requires hours to be reported by calendar day, from midnight to midnight. The report must be submitted quarterly based on the Federal Fiscal Quarter. The Federal Fiscal Quarter is defined as follows:

1 10/1-12/31 2/14
2 1/1-3/31 5/15
3 4/1-6/30 8/14
4 7/1-9/30 11/14

The goal of PBJ

Developed by the Centers for Medicare & Medicaid Services (CMS), the staffing data, when combined with census information, can then be used to not only report on the level of staff in each nursing home, but also to report on employee turnover and tenure, which can help determine the impact and quality of patient care.

What it means for providers

The system will focus providers’ attention on staffing, scheduling and the associated labor costs, which represent the single largest operating cost in the long-term care industry.

Collected annually during survey Quarterly electronic reporting
Reported via 671/672 Staff,contracted/agency employees, medical professionals
Typically reported staff hours only Auditable document trail

There is no better time than now to analyze your current reporting and data collection practices related to staffing and to begin to plan, redesign and formulate a new workflow for the accurate reporting of not only direct care staff members, but contractors as well who also serve in the roles defined by CMS.

What defines direct care staff?

Direct care staff are those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychological well-being. Direct care staff does not include individuals whose primary duty is maintaining the physical environment of the facility; for example, housekeeping.

Some examples include Administrator, Medical Director, Physician Assistant, Registered Nurse, Certified Nurse Aide, Medication Aide/Technician, Nurse Practitioner, Clinical Nurse Specialist, Pharmacist, Dietitian & Feeding Assistant.

Some Q&A

Q. How do we report the hours for a Medical Director who spends the entire day in the building, but some of that time is spent conducting Medical Director responsibilities and some is spent seeing residents as an attending physician?

A: CMS understands it may be difficult to identify the exact hours a physician spends performing medical director activities versus primary care activities. Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on site conducting primary responsibilities.

Q. Our physicians, therapy, respiratory, pharmacy, dietary, and contract staff also provide these services to all of our Nursing Homes, but we don’t know exactly when they are in any one center. How do we report their hours?

A: Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. We understand it may be difficult to identify the exact hours a specialist contractor (e.g., non-agency nursing staff) is in-house. However, there should be some expectation of accountability for services provided.

More frequently asked questions can be found on the CMS website by following this link.Questions regarding the PBJ Policy should be directed to nhstaffing@cms.hhs.gov.

The NOVAtime Advantage

At NOVAtime, we’ve developed a custom PBJ reporting module to accommodate CMS’s data specifications. Not only does the PBJ reporting module allow for the configuration of the necessary time and attendance details, it also allows for manual entry of the non-payroll based data required in order to generate a report that is fully compliant with Section 6106. The new NOVAtime PBJ Reporting module, which supports the PBJ Specification Version 2.0 that was released on June 26th, 2016, is available in NOVAtime 5000 SaaS. To learn more, please contact an authorized NOVAtime reseller or NOVAtime Support.

In addition to the PBJ module, NOVAtime supports general ACA reporting requirements. To learn about NOVAtime's PPACA module, click here.

Assumptions and Constraints

The NOVAtime Payroll-Based Journal Reporting Module will be available for all NOVA5000 SaaS clients. We encourage all customers who are on previous versions of NOVAtime to contact their support representatives for information and assistance in upgrading.

For additional information, please contact NOVAtime: 877-486-6682 - or - Click here