A CMS survey and certification memo published April 10, 2015, notified long-term care facilities that Section 6106 of the Affordable Care Act, enacted March 23, 2010, will be implemented. As such, these providers will be required to electronically submit direct care staffing information, including agency and contracted staff, based on auditable and verifiable data, such as payroll data. This submission of data includes, but is not limited to, the number of hours worked each day by each staff member. The information must also include resident census data for the last day of each month.
The first required quarterly submission covers the period July 1, 2016 through September 30, 2016 and is due to CMS by November 14, 2016.
This data collection and submission process has been titled the Payroll Based Journal (PBJ). Until the implementation of the PBJ, this data had been provided to CMS through Form 671 during the annual licensure and certification surveys. Nurse staffing data is to determine the staffing component of the CMS Five Star Quality Rating.
The mandatory PBJ submissions are required at least quarterly and initiate on the quarter beginning July 1, 2016. The first required quarterly submission covers the period July 1, 2016 through September 30, 2016 and is due to CMS by November 14, 2016. There will be enforcement actions for inaccurate and untimely submissions of PBJ data.
Providers have the option of submitting PBJ data to CMS at any frequency during the fiscal quarter. However, the accepted submission will be the last submission prior to the deadline. Submissions will be accepted after the deadline by CMS, however these submissions will not be considered timely. Providers may submit staffing data electronically or manually but must follow CMS guidelines and instructions for each method.
CMS is allowing providers to voluntarily submit staffing data now. Submission of PBJ data prior to November 14, 2016 for periods prior to July 1, 2016 provides an opportunity to “test” the interface between provider payroll systems and the CMS system. These “test” submissions will also not be considered in the CMS Five Star Quality Rating. Each provider, however, must register in the system to submit the required PBJ data.
Many payroll and timekeeping vendors have been working on interfaces for the PBJ submissions. We recommend that providers contact their payroll and timekeeping vendors to inquire about how they can help facilitate compliance with the PBJ requirements.
We recommend that providers review the Frequently Asked Questions and PBJ Manual on the CMS website, as well as PBJ Training Modules for an introduction to the PBJ system and step-by-step registration instructions.
For more information on this topic, or to learn how Baker Tilly healthcare specialists can help, contact our team.