Data Accuracy Influences Changes to Payroll-Based Journal Reporting
Since version 1.0 of the payroll-based journal (PBJ) reporting policy manual was issued in 2015, nursing home providers have struggled to both interpret the requirements and create a process to properly and completely capture the required data. The Centers for Medicare and Medicaid Services (CMS) has recently instituted a host of modifications to the requested data, and has also implemented changes for the PBJ submission process.
PBJ data to affect staffing ratings in 2018
According to CMS, PBJ data will begin to affect the five-star staffing rating in early 2018. A reduction of the overall five-star rating of a nursing home can cause a provider to lose referrals from discharging hospitals or lose eligibility with key managed care contracts. If the five-star rating falls below a three, a facility will not be eligible to participate in CMS’s bundled payment programs and will not receive incentive payments related to the Medicare skilled nursing facility (SNF) value-based purchasing (VBP) programs that will be instituted on October 1, 2018.
Beginning in 2018, Medicare per diem rates will be reduced by 2 percent as part of the VBP program, and a portion of these withholdings will fund the incentive payments. Another 2 percent can be deducted if a facility does not submit quality reporting data. Lower staffing ratings may affect the reputations of facilities as consumers become more aware of the data being reported through Nursing Home Compare.
While many providers understand the submission process, challenges are often related to the proper tracking and reporting of certain types of staff and payroll hours, including:
- Direct care staff overtime
- Paid time off for salaried personnel
- Contract staff hours that are not entered into the facility’s payroll system
- Staff that had previously worked for the organization who are rehired
- Staff who work both within the nursing facility and in another area, such as assisted living, in a single shift
- Staff that perform work under two different job classifications
Submitted data drives changes and updates to PBJ policies
After analyzing the voluminous data that has been submitted over the past year, CMS has started notifying providers if data appears to be erroneous. CMS also made changes to the reporting process based on this analysis. These changes provide an indication of how CMS may use the data, so providers should ensure that the staff collecting or entering the data is considering the future impacts that may occur.
A summary of the major changes made to the system and process over the past year include the following:
- Nursing Home Compare now indicates whether providers have submitted data by the required deadline, as well as whether the data was complete, incomplete, or inaccurate. If a provider either does not submit data or provides inaccurate data for two quarters, both their overall and staffing star rating will be taken down from their Nursing Home Compare page.
- CMS is issuing a provider rating report highlighting potential errors in data submission, such as an employee working more than 80 hours in one week.
- Minimum data set (MDS) submissions will now be used to calculate and accumulate census for calculating hours per patient-day statistics, rather than the census that is reported with the PBJ data each quarter. Census reporting in PBJ is therefore optional.
- The following three job codes that were previously required for reporting were designated as optional:
- 32 — Dentist
- 33 — Podiatrist
- 35 — Vocational Service Worker
- Hire and termination dates are optional. CMS will calculate turnover and tenure statistics based on the staff ID’s submitted each period.
- CMS is updating the data submission specifications to give providers the ability to link employee IDs for an employee that has changed IDs within a facility.
- In 2018, PBJ data will begin replacing staffing data reporting on form CMS-671; however, this reporting will still be required until providers are instructed otherwise.
- In June 2017, CMS distributed information related to PBJ pilot audits. A sample letter and request for information were sent to state surveyors announcing that auditors contracted from Granite Dolphin and Myers and Stauffer will initiate these pilot audits.
- CMS will begin posting PBJ public use files, which will be accessible on November 1, 2017. The first data released will be for the quarters ended 3-31-17 and 6-30-17.
Changes will help improve data quality
These changes are intended to improve the quality of the data and make it easier for providers to report data. Certain processes such as the PBJ pilot audits were instituted to test new procedures that had not been developed at the official launch of the PBJ program. As with any large software implementation that collects billions of new data records, change is inevitable and CMS will continue to refine the PBJ process.
How we can help
While additional PBJ system modifications are expected, it is clear that CMS will continue to request more data as it evaluates the cost and quality of skilled nursing services. Monitoring the compliance and accuracy of the data collection and submission is critical to your nursing facility as you demonstrate your value in the new health care environment.
CLA's health care professionals understand the data requirements and difficulties of the submission process. Together, we can evaluate your current process and the data you are submitting to determine if you are in compliance with PBJ requirements, and confirm you are getting appropriate credit for the care you are providing. Additionally, we can help your organization understand the changes that CMS has made to the PBJ process. If your organization is struggling with PBJ requirements, we also provide full outsourcing of the PBJ submission process and can help you determine if this approach could be beneficial to your organization.