Payroll Based Journal:  Ready or not here it comes!

Payroll Based Journal (PBJ) is the mandatory submission of staffing information which includes:

• employee hire dates
• employee termination dates,
• direct hours worked (including agency and contract hours) and
• census data. 

Data will be collected in a uniform format and on a quarterly basis. It will also be auditable to ensure accuracy. All long term care facilities will have access to this system at no cost to facilities. 

The mandatory reporting deadline is no later than 15 days from the end of the quarter therefore the first mandatory reporting deadline is November 14, 2016.  This will include the data collected for the period from July 1, 2016 – September 30, 2016.  The goal of PBJ is to establish:

      1.  consistency,
      2.  transparency, and
      3.  validation for future baseline data for pay for performance.

Money could be tied to higher staffing and retention. A request was made to postpone the implementation of PBJ. CMS denied the request to delay. Failure to comply with the submission of data could potentially result in civil money penalties. Data is scheduled to be used for the staffing component in the Five Star Rating System in 2018.

The PBJ Policy Manual was updated in April 2016. The updated policy includes minor edits to the PBJ submission guidelines based on questions received from providers. Updates include clarification on which providers are subject to the new PBJ reporting requirements, who should be reported under Administrative Services, and how facilities may report hours for staff who switch primary roles within a day.

Successful submission of staffing data includes the following tasks:

• Identifying direct care staff
• Coding staff according to CMS title and category
• Verifying contract/agency staff hours
• Gathering hours and census data
• Submitting the data to the system

Census data submission is based on the resident census for the last date of each month for the fiscal quarter which is being reported. (Read our blog post on Census - click here).  The categories for census are based on who is the primary payer (Medicare, Medicaid, Other). 

Currently, facilities should be evaluating current systems and processes, ensuring that the data being collected will work for PBJ, and doing a test submission with CMS. Staying PBJ compliant and effectively managing costs will certainly pose a challenge for many facilities.

If you have questions about Payroll Based Journal, please contact Harmony Healthcare International by clicking here or calling our office at 1.800.530.4413.