PBJ Requirements for Nursing Facilities Continue to Demand Attention

While the Centers for Medicare & Medicaid Services (CMS) have provided an updated manual (Version 2.1) for implementing their payroll-based journal (PBJ) ruling, nursing facilities have questions on certain situations that were given minimal guidance. For instance, specific PBJ reporting programs for time and attendance and payroll systems may not be available or efficient to properly create the files needed to upload to the CMS PBJ entry tool. Similarly, therapy and other outsourced care providers have struggled to create tools that will automate the proper reporting of their time to their nursing customers. These situations have left nursing facilities uncomfortable about meeting the PBJ requirements.

Nursing facilities face software challenges

Reporting software is a common hurdle for many providers. Some facilities have received PBJ file creation programs from their time and attendance systems that have allowed them to successfully submit a practice submission for employee hours. A handful of third-party software providers have also tried to meet the market need with innovative programs that can accept a multitude of file formats from timekeeping systems for both employees and contracted care providers. A few of these programs can even calculate the proper time split between calendar days for those who work over a midnight cutoff. While there are some signs of progress, most nursing facilities still have work to do.

Successful implementation requires planning

PBJ implementation requires planning and executing a fairly long to-do list that will include tasks such as:

• Plan in detail now for an immediate implementation, rather than focusing on the November 14, 2016, deadline for first quarter PBJ submissions.
• Develop and document reasonable allocation methods for specific hours worked. This will alleviate the potential burden of daily time tracking for staff who do not spend 100 percent of their time working in the nursing facility.
• Review and amend contracts with outsourcing firms to enhance the auditability of hours reported in PBJ.
• Request contractors (especially therapy providers) to provide readable backup files of hours worked along with XML file formats and test the upload of these electronic files to the CMS PBJ tool.
• Update job position codes and job descriptions to reduce errors in PBJ reporting.
• Determine frequency of PBJ payroll data collection and upload (after each payroll, monthly, quarterly) and create a process that allows for easy reconciliation and auditability of payroll and contract records.

As nursing facilities move forward, several key concerns can be closely monitored by asking the following questions:

• Are the files produced by your PBJ reporting solution accurate, and do they coincide with your latest CMS 671 reports?
• Are you getting the proper credit for all the care and services you provide, and do you have tools that allow you to review your inputs and calculate your staffing ratios each time you upload PBJ data?
• Do you have a backup plan for easily capturing and uploading time from contracted and outsourced medical or care staff if your providers will not be able to provide an electronic file?
• Have you accounted for all time spent in your community providing care, including staff who may spend time among several locations and do not appear on your community’s payroll?
• Is the PBJ data you can currently provide auditable back to the proper documentation that connects to payroll (not just timekeeping systems) as required by CMS?
• Will you provide the optional information requested by CMS PBJ regulations?

How we can help

Nursing facilities need to ensure that all of the components required by PBJ are addressed, and this requires consistent project management. If you are struggling with some of the questions above, CLA can help you understand your options, including how to outsource the reporting process. We provide PBJ readiness assessments and recommendations that can help organizations prepare for the PBJ data collection and submission process.

CLA professionals can help you:

• Obtain a QIES log in
• Obtain registration for PBJ
• Review labor categories for direct care staff
• Establish a unique ID for every facility and contracted employee
• Assess and document the organization’s PBJ reporting systems for compliance
• Establish a record of all direct care hours for the skilled nursing facility or nursing facility compliance
• Evaluate outsourced solution(s) to fulfill this regulatory requirement

The PBJ requirements will require the time and attention of nursing facility leadership.