CMS issues S&C memo related to Electronic Data Staffing Collection

Nancy Leveille in Clinical & Quality

AHCA sent out this updated message on Payroll Based Journal this morning:

On Friday March 18, CMS released an S&C memo entitled Payroll Based Journal (PBJ) - Implementation of required electronic submission of Staffing Data for Long Term Care (LTC) Facilities. The memo reminds providers of the mandatory submission period beginning July 1, 2016. Further, the memo notes CMS may use its enforcement authority for noncompliance with the requirement to submit data. The memo also states "The contents of this letter supports activities or actions to improve resident safety and increase quality and reliability of care for better outcomes."

Although the bulk of the memo reiterates information that CMS has already distributed or that appears on their Payroll Based Journal website, there is a paragraph about enforcement.  Of greatest interest are the following two sentences:  "As providers are adjusting to this new requirement, we may refrain from imposing enforcement remedies (e.g., for good faith efforts). Additionally, we will provide feedback mechanisms to providers, such as warnings, that will help facilitate compliance with this requirement."

Finally, they reference the updated and "final" version of the Payroll Based Journal policy that was added to their website last week.

The S&C memo is attached and has not yet been added to the CMS website.


Nancy Leveille, RN, MS
Sr. Director, Member Operational Support
518-462-4800 x20