Need-to-Know Details on the Payroll-Based Journal

The Affordable Care Act (ACA) mandates that skilled nursing facilities (SNFs) electronically submit direct care staffing information based on payroll and other auditable data. CMS began collecting data from nursing homes on a voluntary basis on October 1, 2015, and nationwide mandatory reporting began on July 1, 2016.

But while the July 2016 date has passed, we continue to receive questions from providers about how to report payroll hours. There's a lot information on the internet regarding the Payroll-Based Journal (PBJ) reporting process, and sometimes too much information only adds to the confusion. The best resource for guidance on PBJ is the source itself, CMS. You'll find some helpful links below, but let’s chat a little about some of the FAQs.

What You Need to Know about Payroll-Based Journal

What is PBJ for?

While PBJ seems like another regulatory mandate (as if the SNF sector doesn’t have enough regulation), it's actually a process of slicing and dicing staffing data using a consistent, methodical process across the entire sector. The goal of this process is to improve transparency as the PBJ system requires staffing data to be “verifiable and auditable.” Hopefully, this will reduce the risk of over reporting (fraud) and help keep competition fair among long-term care communities.

Keep in mind, staffing is one of the three categories that determine your star rating. Do you want your neighboring community to be inflating their RN hours and ultimately improving their star rating? Probably not. The PBJ process limits this risk.

PBJ evaluates staff turnover

Another area to be aware of is that the long-term plan for the PBJ system is to allow CMS to evaluate staff turnover rates by center. Although there has been no announcement about how this data will be collected and used, it's probable that they aren't asking for information that they don't intend to use. It might be a good idea to consider: do you think there's a plan to use this information going forward?

What is your current annual turnover rate? Is it higher than your neighboring communities? If so, it may be a good time to look at the reasons that you have high turnover rates. It could provide you with the focus to improve performance in this area.

When was the last time you completed a validated, nationally recognized employee satisfaction survey? Can’t afford it? Maybe you can’t afford not to! Turnover rates often go hand in hand with falls, pressure injuries, and substandard care. Remember, we can’t expect residents to receive consistent care if the staff are continuously turning over. So, will the regulatory agencies will be looking at this? You bet!

Capturing accurate staffing hours

So how do you capture accurate staffing hours if you use agency staff, part time/contingent employees, medical directors, skilled therapists, etc.? What about that nurse manager who works Monday through Friday doing administrative duties but is called in on Sunday to cover a shift on the unit? CMS provides an FAQ report that will help answer these questions. 

So back to basics. When you operate long-term care communities, many things happen that are out of your control. Staffing shouldn’t be one of them. Take a good look at your staffing numbers and star rating. If you're below average, it's time to do something about it. Remember, your staff are your most important customers.

Maybe it is time for a new mindset on staffing and to start focusing on retention versus recruitment. We all have those staff members who need some growth, but they're worth the effort if it allows for more continuity of care. Forget the staff pizza parties and maybe share a pat on the back and a thank-you as you walk your halls. It's amazing how staff respond to a positive comment from someone they respect.

Now get out there and do what you do best!

Additional Resources

• Staffing Data Submission PBJ
• PBJ Policy Manual 
• HealthCap has additional resources on Customer Service and inservice opportunities

Next Steps