PBJ Electronic Staffing Submission Update: Information Going Public

Nancy Leveille and Carl Pucci in Clinical & Quality, Finance & Reimbursement

CMS has updated the Payroll-Based Journal (PBJ) electronic staffing submission public use file.

Three major changes to this system are:

  • Effective 11/1/17, PBJ data will be accessible to the public
  • CMS will access census data directly from the MDS and therefore will no longer require providers to submit their census data for PBJ
  • In 2018, CMS plans to post tenure and turnover ratesĀ 

Following is the AHCA analysis with further details and related CMS links.

On September 25, 2017, the Survey and Certification Group (S&C) at the Centers for Medicare & Medicaid Services (CMS) issued a memorandum, "Electronic Staffing Submission - Payroll-Based Journal (PBJ) Public Use File."

The S&C memo states that beginning on November 1, 2017, PBJ data will be accessible to the public at large through public use files posted here. These files will contain data submitted for the reporting period calendar quarters one and two from 2017, and data submitted by the May 15 and August 14, 2017 deadline, respectively. CMS will continue to post data for subsequent quarters. Any provider that either did not submit data prior to these deadlines or submitted data that failed to pass quality checks will not have its data posted in the public use file. These providers will be flagged on Nursing Home Compare (see below).

The published data will include the total number of hours submitted for nursing services job categories for each day in the quarter and the facility's census for each day in the quarter as calculated using Minimum Data Set (MDS) submissions. Since CMS will be able to calculate census from MDS submissions, it is no longer required for providers to submit their census data for PBJ.

AHCA has advocated for moving away from simply utilizing census on the last day of each month since patient/resident census in a skilled nursing facility (SNF) or nursing facility (NF) can vary dramatically during the month. AHCA believes daily census is a better reflection of the number of patients/residents served. CMS plans to expand the type of data available in the public use files in the future.

CMS has also included information on how the PBJ data is different from the CMS-671 and CMS-672 forms and the two should not be compared. Furthermore, CMS notes that states, CMS Regional Offices (ROs) and stakeholders should not interpret the data in the PBJ public use files to indicate noncompliance with other requirements for long term care facilities.

On behalf of members, AHCA has been advocating for any publicly reported PBJ data to include explanatory language on how the data is different from the CMS-671 and CMS-672 forms and what the data should and should not be used for.

The memo also reiterates providers that do not submit the data by the required deadline or have submitted incomplete or inaccurate data will have their overall and staffing Five-Star ratings suppressed on Nursing Home Compare.

In addition, CMS plans on posting tenure and turnover measures on Nursing Home Compare in 2018. AHCA will continue to monitor this and will provide CMS feedback on the calculation methodologies.

Lastly, to help with tenure and turnover calculations, CMS has provided a method for facilities to link an old employee ID with a new one. More information on this method can be found here.

Providers are encouraged to visit the CMS PBJ website here to download the PBJ manual and FAQs, which will be updated and available for review by October 1, 2017.

AHCA will continue to advocate on behalf of our members and provide updates on PBJ as they become available.

Please contact the AHCA PBJ Mailbox with any questions.

NYSHFA CONTACTS:

Nancy Leveille, RN, MS
Executive Director
518-462-4800 x20

Carl J. Pucci
Chief Financial Officer
518-462-4800 x36