Navigating health reform
PBJ Reporting – What Might Be Missing From Your Nursing Facility's Data?
Payroll-Based Journal Reporting (PBJ) is the latest example of the Centers for Medicare & Medicaid Services (CMS) trend requiring more robust data to substantiate the quality of a skilled nursing facility (SNF). This direct-care-hours data is now required in voluminous detail on a continuous basis rather than simply a snapshot in time, as previously required. Executive leadership of many nursing facilities thought this would be a simple process of pulling a file from their payroll systems and sending it on to CMS. Those same leaders are now learning that PBJ isn’t so simple.
Appropriately gathering, reporting, and understanding staffing data is imperative and can provide significant opportunities.
The data required by CMS is not easily converted to the format required by CMS. Executives are also realizing that only about 80 percent of the data is in systems under the control of their organization, so some data is currently not captured at all. For example, the number of hours a registered pharmacist or medical director spends performing their direct care tasks as defined by CMS is not typically gathered or tracked.
The task of obtaining all data from disparate systems and formatting it properly has been difficult, but this is not the end of the challenges associated with PBJ. Once the data is gathered, it is critical to determine if it is complete, accurate, and auditable as required by the PBJ regulations. Many executives have found that the aggregation of this data is taking longer than they expected, which places more pressure on their already busy, and often understaffed, back offices.
PBJ in real life
CLA has been working with clients to verify and document their decisions and processes related to PBJ. We have reviewed the data gathered by our clients and reconciled it to various sources in order to help clients submit information that is both auditable and accurate. During our review process of client data, we have found certain anomalies that elicit additional questions. We have also noticed patterns in software configuration that were not intended, which could possibly result in additional costs for these SNFs.
For example, in analyzing the punch clock data for one client, we found that the rounding feature was not set in accordance with federal statutes. Correcting this rounding feature brought them into compliance and resulted in a change in the hours worked data, which had not been included in their current staffing calculation.
Another client’s data analysis and reconciliation indicated that several software configurations were counteracting each other. For instance, when an employee punched in and out after working more than six hours, the software was set to automatically deduct a 30-minute lunch period as required by the organization’s policies. If the employee worked through their lunch period, the half hour was added back through payroll, but was not included in the time reported on the CMS 671, and therefore not included in the CMS PBJ system. The same client also found that when an employee forgot their ID card to swipe in and out, the procedure required the supervisor to manually input their approximate punch in and punch out times into the time keeping system. However, the system was configured to view this manual entry as an override, which did not deduct the 30-minute lunch period. Adjusting the system will, of course, affect the total hours paid and worked by various staff members.
PBJ data could affect Five Star Ratings
PBJ is cumbersome and data intensive; however, it is now providing CMS with a significant amount of detailed labor data related to all SNFs. This data includes hours related to almost all operational and care staff including nursing staff as well as therapists, administrators, medical directors, and pharmacists. While this data was collected through the CMS 671 form on a manual basis in the past, it is unclear whether it was analyzed or reviewed by CMS. Now that it is in an electronic format, CMS may eventually develop even more metrics to validate the quality of care. Employee and contractor turnover and tenure data is also being aggregated through the PBJ process, so it is likely that CMS will be analyzing it for correlations related to the quality and cost of care delivery, and possibly connecting the data to the Five Star Rating.
As organizations began submitting their data for PBJ, few truly understood how the data impacted their Five Star Rating. This rating system, which has been in place since 2008, is becoming increasingly important under new payment models such as the Comprehensive Joint Replacement model and the bundled payments initiative that CMS is testing in select markets. As alternative payment models continue to expand, and the significance of the Five Star Nursing Rating increases, the importance of accurate PBJ reporting cannot be overstated. Appropriately gathering, reporting, and understanding staffing data is imperative and can provide significant opportunities. Conversely, organizations that lack this ability will have difficult challenges as CMS moves away from traditional fee for service reimbursement.
How we can help
Nursing facilities need to ensure that all of the components required by PBJ are addressed. CLA can help you understand your options by providing PBJ readiness and reporting assessments, as well as recommendations that can help you make the PBJ data collection and submission process more efficient and accurate. CLA professionals can also review your PBJ submissions and processes for accuracy and auditability in order to help you provide the best metrics possible regarding your organization’s quality of care. In some situations, organizations have opted to outsource their entire reporting process.
Managing your data processes well is necessary for the success of your SNF. The PBJ process is likely to become an even larger and more important piece of daily operations in the future.