CMS Payroll Based Journal Reporting – Preparation and Practice is Crucial

The regulatory burden for long term care facilities to report payroll data to CMS was introduced under Section 6106 of the Affordable Care Act. It is generally accepted that quality of care is directly correlated to direct care staffing levels. PBJ was designed to create consistency of reporting between all providers by requiring documented, auditable records to support all information filings and eliminate the shortcomings of past self reporting.

Known as Payroll Based Journal Reporting (PBJ), the name is a misnomer in that reporting is required by worker, by day so aggregated payroll data will not be useful.

Specifically, long term care (LTC) facilities must electronically submit direct care staffing information (including agency and contract staff) based on actual hours worked for each calendar day along with census data for the last day of the quarter. A roster of all active employees will be maintained by the PBJ system. PBJ will collect employee hire and termination dates to be used to identify turnover and calculate employee stability for inclusion in facility star ratings.

What are the filing requirements?

CMS mandates that all direct care hours provided by employees, agencies or contractors are recorded and reported on a quarterly basis broken out by worker, by calendar day, by one of 40 CMS-PBJ labor codes. “Calendar day” will create complexity for most 24/7 operations that have the night shift start before midnight and end the following morning. Generally, shifts that cross a day divide have the total shift hours allocated to either the day the shift starts or the day the shift ends. PBJ requires that the shift hours be divided and reported for the day of work.

CMS requires each reporting facility to submit hours as separate filers. For organizations that have multiple facilities, each facility will need to file separate reports. There are two methods for filing: Manual entry of information into the CMS PBJ web portal or submission of an XML format file that meets specific PBJ specifications. It is acceptable to use both methods in the same filing period. A provider may file all employees by file but file agency and contract activity manually. Ideally, processes are created to file all required workers in an automated fashion.

There are two XML file versions; Merge files will append included data to any data filed previously in the quarter; Replace files will overwrite any data submitted previously in a quarter with the data within the file. Submitting a Replace file will erase any prior manual data entries and should be used with caution.

A facility is free to choose the frequency of filings. It is acceptable to submit periodic files ongoing though the quarter or file once at the end of a quarter. All data must be submitted before midnight of the 45th day following quarter end.

CMS is now in the Voluntary Period designed to allow reporting facilities to practice creating and reporting data without penalties or any adverse impact on the Provider’s star rating. CMS highly encourages all reporting facilities to take advantage of the Voluntary Period to insure that the facility is creating accurate and compliant reports.

Effective July 1, 2016 all reporting facilities will cross into the Mandatory Reporting Period and the CMS-PBJ system will be fully live with reports impacting the star rating and any failures triggering potential penalties.

Check list for Preparing for PBJ

  1. Create a project team to plan for PBJ compliance.
  2. Go to CMS.gov for directions on registration and training. In addition, there is a PBJ policy manual and document on XML file specifications. Pay particular attention to the frequently asked questions.  This section provides clarifications that are not detailed in the policy manual.
  3. Using the resources from CMS, initiate discussion internally on best practices for allocating hours by job code, determining which pay designations to include, maintaining an auditable record, and creating an XML file to automate the filing process.
  4. Initiate discussions with agencies and contractors on how to collect and file direct care hours. The facility is responsible for the accuracy of all filings. Determine how to control the 3d party information or verify and audit the accuracy of provided data. Unique employee ID numbers and reporting of tenure are important issues to resolve.
  5. Review existing time & attendance systems to assess for suitability and efficiency. The ability to create the required XML file is an important capability. Pay particular attention to the ability to handle shifts that cross the day divide and the requirement to allocate hours to each day worked.
  6. Test, test, test the collection of employee, agency and contractor data. Go through the steps of filing 1Q2016 data with PBJ. Amend any systems or processes that require changes before the expiration of the voluntary period.