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Payroll-Based Journal(PBJ)

WHITE PAPER

Payroll-Based Journal (PBJ)

Helping you prepare for CMS NEW Payroll-Based Journal. There is a well-established link between facility staffing levels and quality of care. Staffing ratios and stability have clearly been recognized as a key component of positive resident outcomes. In studying staffing levels, Centers for Medicare and Medicaid Services(CMS) identified staff to nursing ratios, below which quality issues will affect resident quality of life.i CMS also included staffing levels within the Five-Star system, making that data publically reportable and a marker of quality care provision. Starting July 1st, 2016, electronic submission of staffing level data aims to improve the accuracy and transparency of the care provider ratios reported.

Staffing ratios and stability have clearly been recognized as a key component

of positive resident outcomes.

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These mandatory compliance measures are being undertaken in connection with Section 6106 of The Affordable Care Act, Ensuring Staff Accountability.ii

The data, when combined with census information, can be used to not only report on the level of staff in each nursing home, but also to report on employee turnover and staffing stability, which can impact the quality of care delivered. This further supports quality directives such as AHCA’s Quality Initiative on Staff Stability, whose goal is to “decrease turnover rates among nursing staff (RN, LPN/LVN, CNA/LNA) by 15% or achieve/maintain turnover rates at or below 40% by March 2018.” iii

The collection of staffing data in a standardized format evens out the playing field for providers, as it relates to consistency in the reporting of direct care workers.

The new requirements ensure a comprehensive picture of all care providers – not just those on the payroll – that have an overall impact on the quality of care provided to clients. Staffing represents the single largest operating cost in the long-term care industry.iv The mandate will focus providers’ attention on staffing, scheduling and the related costs of labor.

Since staffing is used in the Five-Star Quality Rating and also reportable through Nursing Home Compare, accurate reporting is important for your brand and reputation.

The staffing measure is a complex calculation, but at its heart is the resident care contact hours the facility provides. Expanding the picture to include all direct care providers, regardless of employment status within the facility, paints a much better picture of the type and frequency of care provision within each home. On full implementation of PBJ, homes will be measured on both staffing ratios and staff stability understanding consistency in care is as important as staffing ratios to support person-centered care.v

Standardize reporting requirements, and

Collect information related to direct care staffing (including agency and contract staff) and facility census on a more frequent basis, in an electronic format.

The goals of the Payroll-Based Journal (PBJ) Staffing Data Submission Program are to:

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Terraces of San Joaquin Gardens (employees)

Payroll-Based Journal (PBJ)

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Currently, all full time and part time staffing data used on Nursing Home Compare and in the Five-Star calculations are derived from the CMS-671 submission form.vi

The current calculation relies on homes annually recording total nursing and RN hours worked (not scheduled), per resident per day over a 14-day time period.Total hours include RN, Directors of Nursing, Assistant Directors of Nursing, LPN/LVN, and Aides (Nursing Aides, Aides in training, Medication Aides and Technicians). Contracted staff hours and non-payroll staff were not included and depending on the stability of your staffing mix, could represent a significant amount of care provider time with clients.

As of July 1, 2016, all of that changes.

With the new PBJ submissions, homes will no longer be simply submitting data on employees, but on all facility based and external staff affecting care provision. The new guidelines require that homes track time for all direct care staff or “those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well-being.” vii

This now includes direct care providers, employees, contracted staff and agency employees as well as medical professionals – all of whom will need to have hours tracked and reported.

Submission of reports will be required quarterly instead of annually and homes will need to submit hours paid for services performed onsite or “direct care staff” hours which are auditable or trackable through some mechanism (for example payroll, invoices, or contracts). For the first time, facilities must be able to prove the direct care hours reported. For most providers, this will mean a process change, which requires immediate attention in order to implement systems in time for the July 1, 2016 mandate.

There is also a change to how the census is reported. Homes will now be required to submit their full census as of the last day of the month with each quarterly staffing submission, sorted by payer mix.

CMS requires all payers to be funneled into one of three buckets; Medicare, Medicaid and other. This may differ from how you are currently tracking your payers, so understanding which residents fall into which category will help in providing the right information back to CMS.

What’s new?

As of July 1, 2016 new regulations will be in effect.For most providers, this will mean a process change, which requires immediate attention in order to implement systems in time.

Payroll-Based Journal (PBJ)

The deadline is drawing near and homes need to be ready now. The first submission deadline is November 14, 2016 and having the right data collected is the key to a smooth transition. Communicating changes to all involved parties will ensure consistent and accurate auditable documentation. EHR and Time and Attendance vendors

have thought through the hiccups and have developed processes, making them invaluable partners in meeting that deadline. Managing the business of care is vital to your brand, your reputation and most importantly, your residents. Keeping your stars and reputation aligned means preparing now for future changes.

iKramer AM, Fish R. “The Relationship Between Nurse Staffing Levels and the Quality of Nursing Home Care.” Chapter 2 in Appropriateness of Minimum Nurse Staffing Ratios in Nursing Homes: Phase II Final Report. Abt Associates, Inc., Winter 2001. iihttp://www.hhs.gov/healthcare/about-the-law/read-the-law, iiihttps://www.ahcancal.org/quality_improvement/qualityinitiative/Pages/Staff-Stability.aspx ivhttp://www.ltlmagazine.com/article/new-payroll-based-journal, vhttps://www.ahcancal.org/quality_improvement/qualityinitiative/Pages/Staff-Stability.aspx vihttps://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/downloads/CMS671.pdf, viihttp://www.staffschedulecare.com/payroll-based-journal.htmlviiihttps://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Downloads/PBJ-Policy-Manual-FAQ-4-27-16.pdf ixhttps://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Downloads/PBJ-Policy-Manual-Final-V21.pdf xhttps://www.qtso.com/cmsnet.html

Providers need to be acting now. Before July 1, 2016, providers need to analyze their facility’s current reporting and data collection processes related to staffing and begin to plan, redesign and formulate a new process that will ensure the complete and accurate reporting of staffing information for both employees of the organization as well as contract staff who serve in the roles defined by CMS.

Don’t be fooled – it isn’t as simple as just recording the comings and goings of your workforce. All Contract and Agency Staff must each have a unique Employee ID when entered into the systemviii

– something that may not be happening now. Employee roles need to be mapped to one of 40 specific labor codes for reporting. In the absence of the ability to capture and submit the data electronically in the home, the data needs to be entered manually into the QIES CMS-PBJ input screen; a process which has been conservatively been estimated at 2 FTE’s for every 100 staff.ix

Homes should be reviewing staff mix now to properly identify labor categories and pay types for submission and ensure they are registered with the QIES system for submission.x Challenges will lie in a system’s ability to accurately capture time of contract and agency staff with the proper information.Sign-in and out sheets are hard to monitor. Homes should be reaching out to vendors and external service providers on how they will manage this data capture and submission. Providers should consider partnering with time and attendance/scheduling software vendors to plan the methods of collecting, assembling, storing, and reporting staffing data to CMS in a timely and efficient manner.EHR vendors will be instrumental in extracting, aggregating and submitting the census data appropriately as well.

Act NOW!

In a nutshell.

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Staffing information for employees of the

organization as well as contract staff who serve inthe roles defined by CMS.

Employee roles need to be mapped to one of 40

specific labor codes for reporting.

All contract and agency staff must each have

a unique Employee ID when entered into

the system.

The data needs to be entered manually into the

QIES CMS-PBJ input screen if electronic data submission

is not in place.

Before July 1, 2016, providers need to prepare for:

Terraces of San Joaquin Gardens, Patty Olino (employee)

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PointClickCare has helped over 12,000 skilled nursing and senior living facilities meet the challenges of senior care by enabling them to achieve the business results that matter – enriching the lives of their residents, improving financial and operational health, and mitigating risk. PointClickCare’s cloud-based software platform takes a person-centered approach to managing senior care, connecting healthcare providers across the senior care continuum with easy to use, regulatory compliant solutions for improved resident outcomes, enhanced financial performance, and staff optimization. For more information on PointClickCare’s ONC certified software solutions, please visit www.pointclickcare.com.