Harmony Healthcare International (HHI) Blog

PBJ Staffing Domain: COVID-19 Telehealth/ Remote Hours



1.) CMS has stated that for non-nursing staff, if the “typical parameters” of working remotely or via telehealth apply to those worked hours, then the facility may include those hours on the PBJ hours.

2.) Elaborating on “typical parameters,” meaning the only hours the provider is able to include for:


  • PBJ reporting are paid worked hours, and


  • Labor Hours must be paid by the facility, i.e., not paid from Medicare, Medicaid or a third-party payor. However, this does not apply to contract therapy hours. Those hours can be paid by a contract therapy company.


  • With #6, a benefit to including optional hours in the past has been that PPE distributions and perhaps other decisions have been based on numbers that include these hours.


  • Related to telehealth hours, the end of the physician visit and physician delegation waivers May 7th (per QSO-22-15-NH) means that requirements in F712 and F714 are back and the definition that all physician visits be made personally – “actual face-to-face contact with the resident, and at the same physical location, not via a telehealth arrangement”.
  • F712:
    • 483.30(c) Frequency of physician visits.
    • 483.30(c)(1) The residents must be seen by a physician at least once every 30 days for the first 90 days after admission, and at least once every 60 thereafter.
    • 483.30(c)(2) A physician visit is considered timely if it occurs not later than 10 days after the date the visit was required.
    • 483.30(c)(3) Except as provided in paragraphs (c)(4) and (f) of this section, all required physician visits must be made by the physician personally.
      • 483.30(c)(4) At the option of the physician, required visits in SNFs, after the initial visit, may alternate between personal visits by the physician and visits by a physician assistant, nurse practitioner or clinical nurse specialist in accordance with paragraph (e) of this section.
        • DEFINITIONS §483.30(c)
        Must be seen, for purposes of the visits required by §483.30(c)(1), means that the physician or NPP must make actual face-to-face contact with the resident, and at the same physical location, not via a telehealth arrangement. There is no requirement for this type of contact at the time of admission, since the decision to admit an individual to a nursing facility (whether from a hospital or from the individual’s own residence) generally involves physician contact during the period immediately preceding the admission.


3.) If the dietician and the pharmacist performed their duties off-site (versus on-site), and the facility paid those individuals for the hours worked, these hours may be included in the PBJ submission.


4.) These hours require a “paper trail,” i.e., proof of hours worked. Be sure the facility can demonstrate and show proof of the hours rendered and paid by the facility. It is not acceptable to have a monthly invoice for services without dates, times and total hours worked by the staff person.


5.) Hours worked by non-nursing staff, regardless of whether time is remote or on-site, require proof that the hours were worked and paid by the facility.



6.) If the facility wants to include MDS RN and/or MDS LPN hours worked remotely, the facility will need to include those hours as 40 Other Service Worker (Optional) – PBJ Job Title 40.  


7.) All nursing hours included on PBJ reporting MUST be worked on-site.


Unless a waiver is in place:


8.) A facility must use the services of a registered nurse for at least 8 consecutive hours a day, 7 days a week.


9.) The facility must designate a registered nurse to serve as the director of nursing on a full-time basis (35 or more hours per week).


 10.) The Interpretive Guidance states that the DON requirement can be fulfilled by using two or more RNs, so long as the roles and responsibilities for all RN staff serving as the DON are clearly defined and facility staff understand how the responsibilities are shared.


11.) The director of nursing may only serve as a charge nurse when the facility’s average daily census is 60 or fewer residents.


12.) The QSO memo regarding the use is Payroll-Based Journal staffing data for Nursing Home Compare and the Five Star Quality Rating staffing domain emphasizes the importance of RN hours in the nursing home.


13.) Facilities that have more than 7 days per quarter where RN hours per this regulation are not met, will receive a 1-star rating for staffing for that quarter. This includes facilities that have received an RN waiver. Even though these facilities do not have to have an RN on staff 8 hours a day / 7-days a week, they will be subject to the same rating methodology applied to facilities that have 7 or more days/quarter without RN staffing submitted to the PBJ system.

Topics: Payroll-Based Journal, Regulatory, PBJ

Kris Mastrangelo, OTR/L, LNHA, MBA


Kris Mastrangelo, OTR/L, LNHA, MBA

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