Caring for residents and patients is one of your top priorities as a manager of a long-term care or assisted living facility. To meet quality care standards and keep your residents comfortable and safe, you must properly staff every single shift with enough nurses. Since 2016, the Centers for Medicare and Medicaid Services (CMS) has required nursing facilities to collect and report staffing level data through payroll-based journal (PBJ) reporting.
This requirement allows CMS to track the quality of care your facility delivers and ensure the accuracy of your staffing data. In addition, CMS uses this data to determine your facility rating, which has a significant impact on your reputation and ability to attract residents and talent. To avoid falling out of compliance, you must know the ins and outs of maintaining and reporting adequate staffing levels.
Let's examine important PBJ reporting dates for 2023 and any new changes to keep in mind.
PBJ reporting is a requirement of all long-term care facilities to promote accountability and consistency. According to Section 6106 of the Affordable Care Act (ACA), CMS developed the PBJ reporting system to ensure nursing facilities provide staffing information on a regular and frequent basis. This reporting system is free to use and acts as a database with census information to assess staffing levels, employee turnover, and employee tenure.
CMS uses this staff information to develop a nursing facility's quality rating system by determining the quality of care a facility provides for its residents and patients during that quarter. CMS requires skilled nursing facilities to submit this data—for both contract and agency staff—electronically through the PBJ system. This data is auditable.
Failure to submit employee data or reporting inaccurate data can lead to citations and civil money penalties. The goal of PBJ reporting is to hold long-term care facilities accountable for positive resident outcomes and ensure they maintain proper staffing levels.
Once CMS receives the PBJ staffing information, they'll use this to provide a facility with a quality rating and post it on their facility comparison website. This source helps consumers, potential residents, potential staff members and families of residents understand the level of staffing in a nursing facility and the overall level of care.
To achieve a desirable outcome for all stakeholders, you must maintain a high level of accuracy and detail in the data your facility provides. If your current systems are falling short, it can result in significant strain on your administrative staff and care teams. Implementing a time tracking and HR management solution can help you stay up to the reporting task.
The PBJ report requires the following information for each direct care staff member from your skilled nursing facility:
In addition to this information, keep in mind that you must also describe each employee's roles and responsibilities in a very detailed manner. For instance, you may need to categorize nurses who perform various tasks throughout the day using different job codes.
The hours you record on your PBJ report must also reflect the specific day that your staff member performed them. For example, if a nurse starts their shift at 10 p.m. and ends at 6:00 a.m., you'll need to report this as separate entries for the number of hours recorded on each day.
If you have contractors at your skilled nursing facility paid by Medicare, you're not required to include them in your PBJ report. For exempt, salaried employees, however, you can only record a maximum of 40 hours. You may record overtime hours for non-exempt employees.
In 2019, CMS announced that there would be changes to their requirements for a five-star facility rating. CMS adjusted the staffing level components and mandated that facilities that report going 96 hours, or four or more days, without a registered nurse (RN) on staff is a violation of their guidelines and would receive a one-star rating. In 2020 and 2022, there were additional updates to their Five-Star Quality Rating System relating to staff turnover, weekend staffing measures, and health inspections.
All of these factors contribute to your facility rating, but your PBJ reports will primarily impact your staffing score. If you want to achieve a five-star rating for your facility, it's important to avoid fines for non-compliance when it comes to PBJ reporting. For example, failing to report at all will result in a one-star rating for the staffing category.
While CMS is generally willing to work with skilled nursing facilities to correct discrepancies in the case of a minor or obviously accidental error, numerous or significant issues can reduce your rating for the entire quarter.
A low rating can turn experienced nurses and potential residents away from your facility and prevent you from reaching your business goals. That's why it's critical to submit accurate, complete data when conducting your PBJ reporting to avoid these issues.
However, it can be challenging if you're leaving yourself open to human error. CMS allows you to enter your facility's data manually or use an automated payroll or time and attendance system that complies with their requirements to upload automated reports.
With manual entry, you run the risk of many errors if someone types in the wrong information, spells something wrong, or forgets to input data daily or weekly to stay on track. CMS looks for many different errors that fall under two types of error messages:
If your facility decides to do things manually, prepare for a labor-intensive process involving checking and double-checking to avoid any mistakes on your PBJ reporting forms. This adds to your list of administrative and HR responsibilities and can leave your staff with less time to dedicate to top priorities, like maintaining employee and resident satisfaction, creating efficient schedules, and onboarding new talent.
With the right solution, you can generate user-friendly reports that comply with all PBJ reporting requirements and immediately send them off without hassle. Having access to comprehensive, easy-to-understand staff data makes it easier to analyze your business operations and help you build a reputation for high-performing care levels while meeting PBJ reporting standards.
CMS continually revises and makes updates to its PBJ reporting standards, specifically when it comes to staffing levels. Here are some changes and provisions to the requirements to keep in mind for the upcoming year.
To provide skilled nursing facilities with greater flexibility to adapt to rapidly changing requirements, CMS has waived timeframe requirements on the minimum data set (MDS) assessments in addition to requirements for submitting PBJ staff data in 2023.
In late 2022, CMS used PBJ staffing data to conduct surveys and inspections to identify noncompliance issues in regard to hourly staffing standards. One of these standards includes having an RN on shift for a minimum of eight hours per day.
These surveys also checked for indications of whether a skilled nursing facility met the requirements for sufficient staffing. This is important for all long-term care facilities to note for 2023, as CMS may plan to use PBJ data to improve the enforcement of staffing standards and other inspection violations.
CMS is also finalizing the adoption of several new measures for the skilled nursing facility value-based purchasing (VBP) program in 2023. This program includes facility-level and aggregate-level rankings and improvement scores that may also contribute to a facility's quality rating in addition to PBJ report results.
Some of the new measures for this program and PBJ staffing include:
As we roll into 2023, it's important to keep PBJ reporting dates in mind, as you'll have to submit your reports once per fiscal quarter. CMS requires long-term care facilities to submit their reports within 45 days of the end of the quarter.
If you're submitting reports manually, you'd need to begin this process ahead of time to ensure you meet the deadline—which is why it's worth investing in an integrated system for staff timekeeping and automating your reporting needs.
Here are the 2023 PBJ reporting due dates to know.
Because PBJ reporting has only been mandatory since 2016, it's still a fairly new practice for many long-term care facilities. Whether you're used to using manual, outdated processes or have new members on your administrative team, it can take a while to get everyone on the same page and understand PBJ reporting requirements.
Here are some FAQs you may have about PBJ reporting.
According to the Requirements of Participation, all long-term care and skilled nursing facilities are required to submit PBJ data. These requirements don't extend to swing-bed hospitals.
As noted above, your facility must submit PBJ data on a quarterly basis. However, it's recommended that you submit data more often, such as a few weeks after you complete payroll. Submitting data more regularly will help you recognize inaccuracies or errors ahead of time so you can address them before the submission deadline.
You must submit your data for each fiscal quarter by the end of the 45th calendar day at 11:59 PM (Eastern Standard Time). If you fail to do so, the PBJ system won't accept your submission after the deadline passes.
Prior to 2019, CMS automatically calculated resident census data even if facilities provided the information. However, as of 2019, CMS no longer accepts census data in a PBJ file submission.
This means CMS will reject your submission if you use older versions of the files, so it's important to use the new required version. If you include census data in your Extensible Markup Language (XML) file, the PBJ system will reject it. This process can be complex, which is why it's often recommended to use software to streamline it.
Yes. CMS allows you to input data manually or through the use of automatic reports generated by time-tracking or payroll software. If necessary, you may use both types of submissions for your facility.
For instance, if your facility is transitioning from manual processes to a workforce management solution, you may need to use a combination of manual data entry and reports submitted through XML files, which is acceptable.
No. You shouldn't include staff member breaks, including paid and unpaid breaks, in your PBJ reports.
No. The PBJ system will remember each unique employee ID number across each quarter, so you don't need to provide them with every single submission. However, if there are changes to the employee that prompt a new ID, you'll need to include it.
CMS provides a list of 35 job code titles for direct care staff. You can match your skilled nursing facility's job descriptions with the CMS job code titles for employees, agency staff, and contract workers. To streamline this process, implement an employee data solution or determine a process for collecting job title codes at the beginning of each shift.
According to CMS, direct care staff are individuals who have personal contact with patients or residents, such as providing services or care that contribute to residents' physical, mental, and psychosocial well-being. Staff members don't fall under direct care if their primary role is to maintain the facility environment, such as housekeeping.
Facilities must submit the total number of hours that each staff member, including agency and contract staff, works each day. You can include both training hours and corporate employee hours in these submissions if the staff member is providing direct care or performing direct care duties. Some direct care hours you should exclude are overtime hours, paid time off, sick leave, and vacation leave.
Meeting payroll-based journal reporting requirements can be challenging if your skilled nursing facility still relies on separate outdated systems. Manual administrative processes can also make it difficult for you to ensure proper staffing at all times for your patients. To help streamline your operations and make it easier for you to stay compliant, your facility can benefit from PBJ reporting software that does more than generate reports.
Smartlinx offers workforce management software that interconnects your administrative processes, including collecting and storing staff and attendance data, enabling real-time compliance tracking, managing payroll, and creating efficient staff schedules. See how our solution can help your facility earn and maintain a five-star rating.
Contact us today to learn more or schedule a demo to get started.
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