payroll-based journal: staffing strategies for success
TRANSCRIPT
Payroll-Based Journal Reporting: Strategies To Get Ready
Introductions
Ryan EdgerlyDirector of Account ManagementOnShift
Peter CorlessAssociate Business Member President on AHCA/NCAL’s Board of GovernorsEVP of Enterprise Development at OnShift
Today’s Agenda
• Gain an in-depth understanding of the new PBJ requirements
• Find out what hours to count and what not to count
• Learn what processes you should implement today to get ready
• OnShift PBJ Sneak Peek• Questions & Answers
What is Payroll-Based Journal?
Payroll-Based Journal (PBJ) is a new system used by CMS to electronically collect:
• Employee tenure information • Direct care hours worked – including
agency and contractor hours• Census data
A Little History
• Payroll-Based Journal – Section 6106 of the
Affordable Care Act required skilled nursing communities to electronically submit staffing data
– PBJ staffing reporting brings consistency, transparency and validation
“The use of payroll based data will help
address the misconception that
SNFs self-report higher staffing levels.”
David Gifford, MD,MPH, Sr. VP Quality & Regulatory
A Little History
Why Payroll-Based Journal? Self-reporting accuracy questioned
• 2009: 38% received 4 or 5 star rating, by 2014 increased to 54%
• Quality measure ratings increased since transition to MDS 3.0
• Trends have raised questions about the validity of self reported QM and staffing data
• NYT article “Medicare Star Ratings Allow Nursing Homes to Game the System” – 10/14
$11M in funding approved in the IMPACT Act of 2014
PBJ Importance
• Failure to submit or reporting inaccurate data can be costly, potentially leading to citation and civil money penalties. (condition of participation)
• Information used on Nursing Home Compare
• Believed to be used in Five Star Quality Ratings starting in 2018
Staffing Data: Current vs PBJ Practices
Current Practices Future Payroll-Based Journal Practices
Reported annually during survey Reported electronically on a quarterly basis
Reported using Forms 671/672 Reported using the Payroll-Based Journal QIES system
Report staff hours for the most recent complete pay period or 14 days prior to survey
Accounts for all direct care hours – including contractor and agency – for each day of the year
Includes employee tenure information
Note: Current staffing reporting practices will still remain in place even after the July 1st PBJ start date
PBJ Data In Use
• Washington will begin using PBJ information to measure its 3.4 hours per resident day requirement– Beginning July 1st, 2016
– Done on a quarterly basis
• Likely that other states will follow suit
Countdown to July 1
Fiscal Quarter Date Range for Staffing Data Submission Deadline
1 October 1 – December 31 February 14
2 January 1 – March 31 May 15
3 April 1 – June 30 August 14
4 July 1 – September 30 November 14
Aug 2015
Oct 1 2015
Registration for voluntary
submission
Voluntary submission
started
PBJ mandatory submission
begins
First mandatory reporting deadline
July 1 2016
Nov 14 2016
Starting Now: Getting Access
• Step 1:– Go to www.qtso.com/accesspbj.html to register
– Use the CMSNet Online Registration application to request a CMSNet User ID.
– The CMSNet ID is needed to access secure CMS sites (e.g., submissions pages/reports) unless an otherwise secure connection has been established.
Starting Now: Getting Access
• Step 2:– Use the QIES online User Registration tool to
obtain a QIES Submission ID.
– Once you have registered for a CMSNet User ID, you will receive an email from [email protected] containing your login information. Using this information you will connect through the 'CMS Secure Access Service'.
What Needs To Be Submitted
• Tenure data– Hire & termination
date• Direct care hours
worked – Per employee per day
• Census information– last day of each month
Who Counts As Direct Care?
CMS defines direct care staff as 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. Direct care does not include individuals whose primary duty is maintaining the physical environment of the long-term care facility (for example, housekeeping).
CMS Job Title Codes & DescriptionsLabor
Category Code
Labor DescriptionJob Title Code
Job Description
1 Administration Services
1 Administrator
2 Physician Services 2 Medical Director
2 Physician Services 3 Other Physician
2 Physician Services 4 Physician Assistant
3 Nursing Services 5 Registered Nurse Director of Nursing
3 Nursing Services 6 Registered Nurse with Administrative Duties
3 Nursing Services 7 Registered Nurse
3 Nursing Services 8 Licensed Practical/Vocational Nurse with Administrative Duties
3 Nursing Services 9 Licensed Practical/Vocational Nurse
3 Nursing Services 10 Certified Nurse Aide
3 Nursing Services 11 Nurse Aide in Training
3 Nursing Services 12 Medication Aide/Technician
3 Nursing Services 13 Nurse Practitioner
3 Nursing Services 14 Clinical Nurse Specialist
4 Pharmacy Services 15 Pharmacist
5 Dietary Services 16 Dietitian
5 Dietary Services 17 Paid Feeding Assistant
6 Therapeutic Services 18 Occupational Therapist
6 Therapeutic Services 19 Occupational Therapy Assistant
6 Therapeutic Services 20 Occupational Therapy Aide
Labor Category
CodeLabor Description
Job Title Code
Job Description
6 Therapeutic Services 21 Physical Therapist
6 Therapeutic Services 22 Physical Therapy Assistant
6 Therapeutic Services 23 Physical Therapy Aide
6 Therapeutic Services 24 Respiratory Therapist
6 Therapeutic Services 25 Respiratory Therapy Technician
6 Therapeutic Services 26 Speech/Language Pathologist
6 Therapeutic Services 27 Therapeutic Recreation Specialist
6 Therapeutic Services 28 Qualified Activities Professional
6 Therapeutic Services 29 Other Activities Staff
6 Therapeutic Services 30 Qualified Social Worker
6 Therapeutic Services 31 Other Social Worker
7 Dental Services 32 Dentist
8 Podiatry Services 33 Podiatrist
9 Mental Health Services 34 Mental Health Service Worker
10 Vocational Services 35 Vocational Service Worker
11 Clinical Laboratory Services 36 Clinical Laboratory Service Worker (OPTIONAL)
12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker (OPTIONAL)
13 Administration & Storage of Blood Services
38 Blood Service Worker (OPTIONAL)
14 Housekeeping Services 39 Housekeeping Service Worker (OPTIONAL)
15 Other Services 40 Other Service Worker (OPTIONAL)
Non-Facility Direct Care WorkersLabor Category
Code Labor Description Job Title Code Job Description
2 Physician Services 2 Medical Director
2 Physician Services 3 Other Physician
2 Physician Services 4 Physician Assistant
4 Pharmacy Services 15 Pharmacist
5 Dietary Services 16 Dietitian
6 Therapeutic Services 18 Occupational Therapist
6 Therapeutic Services 19 Occupational Therapy Assistant
6 Therapeutic Services 20 Occupational Therapy Aide
6 Therapeutic Services 21 Physical Therapist
6 Therapeutic Services 22 Physical Therapy Assistant
6 Therapeutic Services 23 Physical Therapy Aide
6 Therapeutic Services 24 Respiratory Therapist
6 Therapeutic Services 25 Respiratory Therapy Technician
6 Therapeutic Services 26 Speech/Language Pathologist
6 Therapeutic Services 27 Therapeutic Recreation Specialist
6 Therapeutic Services 28 Qualified Activities Professional
7 Dental Services 32 Dentist
8 Podiatry Services 33 Podiatrist
9 Mental Health Services 34 Mental Health Service Worker
10 Vocational Services 35 Vocational Service Worker
11 Clinical Laboratory Services
12 Diagnostic X-ray Services
How will you collect this
information?
Required Direct Care Worker Data
• Unique ID– Must be unique and not duplicated
– Should not include personally identifiable info (name or SSN)
• Hire date• Termination date• Pay type code
– Non-exempt – entitled to overtime pay
– Exempt – not entitled to overtime pay
– Contract – individuals under contract or those that provide services through organizations under contract
Frequently Asked Question
• Do I have to collect and submit this information for non-facility, contract and agency direct care workers?
Yes. This information must be submitted for all workers providing care in your community. For agency and contract workers:
• Hire date for contract staff is defined as the first day worked and billed for at your community
• Termination date for contract staff is the last day your community or the agency communicates that the contract individual will no longer be providing services at your community. • If you are unsure, do not fill in the termination date.
Starting Now: Collect Direct Care Worker Data• Identify your system of record for company employees– Assign an Unique ID for each staff member
– Update information for current staff• hire date, termination date, pay code status
– Implement a process for this data to be collected for new hires
• Work with your agency and contract providers– Request a list of active staff with the initial date each
employee worked in your community
Direct Care Staffing Hours
• Staffing hours data per direct care worker– Work day and date
– Job title code
– Hours worked per day
Frequently Asked Question
• How should I report an employee’s hours where their shift spans multiple days? For example a Friday shift that begins at 11pm and ends Saturday at 7am.
According to CMS, communities must allocate hours to the actual days worked.
In this example, 1 hour should be reported for Friday and 7 hours should be reported for Saturday. Remember to account for meal break as well on the applicable day.
What Hours Count, What Don’t
• Communities must submit the number of hours each staff member (including agency and contract staff) is paid to deliver services for each day worked.
• CMS has highlighted instances when hours should not be included:– Do not count hours paid for any type of leave or non-work related absence
from the facility, including paid meal breaks.
– Do not count any unpaid hours (e.g. overtime). • For example, if a salaried employee works 10 hours but is only paid for 8 hours, only
8 hours should be submitted.
– Do not count hours for services performed that are billed to FFS Medicare or other payer.
– Do not count hours providing services to residents in non-certified beds. • For example, if nursing home staff is shared with an assisted living community, only
those hours dedicated to the residents of the nursing home should be reported .
Frequently Asked Question
• How are we expected to report for staff who perform different roles throughout their day?
1. If the system of record (e.g. time clock) is able to account for time worked in different positions, then yes, you can split the time.
Example: • Employee XYZ clocks in at 7:00 a.m. in the job code of CNA.• Clocks out at 11:00 a.m. Has a half hour meal break. • Clocks back in at 11:30 a.m. in the job code of Activities Aide.• Clocks out at 3:00 p.m. • System would record on that date: Employee XYZ CNA 4 hours; Employee
XYZ Activities Aide 3.5 hours.
Frequently Asked Question – Different Roles
2. It is understood that most roles have a variety of non-primary duties that are conducted throughout the day (e.g., helping out others when needed). In these cases, reporting should be based on the employee’s primary role and their official categorical title (for example, as indicated in a Human Resources system).
ExampleA CNA who goes to help hand out meal trays over the meal period for a short amount of time. You wouldn’t want to try to separate out and attribute that 30 min. or so to a dietary duty.
3. Universal workers are more problematic because they probably do many different jobs during the day (e.g. CNA, Dietary, Housekeeping, Laundry, etc.) and the time spent doing each position would need to be captured in the system of record for audit purposes. This would be more administratively burdensome such that the facility may just want to report the major function of that shift (e.g. CNA).
Frequently Asked Question
• How should facilities report hours for staff who are attending training? For example, a CNA might work in the morning for 4 hours with residents and then have 3 hours of in-service training in the afternoon.
According to CMS, If the direct care staff (e.g. CNA) attending training (either onsite or offsite) is not available to provide resident care, the hours that the nurse is in training should not be reported. If another staff member is called in to fill in for a nurse that is away for training, the hours for the called-in nurse should be submitted. However, the hours for the nurse in training may not be submitted.
Frequently Asked Question
• If an exempt employee works as a floor nurse to fill-in when an employee has called off, can I report those hours?
This must be handled very carefully so as not to run the risk of violating the employee’s exempt status under FLSA rules, but yes there is a way to report these additional hours.
Starting Now: Map Job Title Codes
• Match your organization’s unique job codes/descriptions to the 35 CMS job title codes– Classify all agency and
contract workers
• Determine a process for collecting appropriate job title code at the beginning of each shift
Frequently Asked Question
• How do we report on hours that are not captured in our time and attendance system (salaried & corporate staff, therapy, contract)?
Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. There is an expectation of accountability for services provided. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on site conducting primary responsibilities, based on payments made for those services.
Starting Now: Collect Hours
• Define your data collection process for: – Hourly staff
– Contract workers
– Salaried staff
– Corporate staff
• For those not captured within a system investigate what options are available to best fit your processes
• Contact the agency and contractor your organization utilizes to determine if they are able to provide a CMS ready report of those hours worked.
Starting Now: Focus On Daily Staffing Levels
• Benchmark staffing levels against budget/Five Star Quality Rating
• Evaluate staffing requirements every shift– Allow for activity and manage like an
employee absence
• Gain visibility into staffing – Alert management when approaching
staffing risk
Starting Now: Get Predictable & Flexible
• Adjust staff as needed– Cancel shifts or call in staff as
needed
– Re-allocate staff to direct care positions – be sure this is documented
• Correlate labor staffed to needs based on estimated future census
• Keep overtime top of mind
Required Census Data
• PBJ requires that census information be provided for the last day of each month. – Medicaid: Number of residents
whose primary payer is Medicaid
– Medicare: Number of residents whose primary payer is Medicare
– Other: Number of residents whose primary payer is neither Medicaid nor Medicare
Associations have objected to only
submitting census data for the last day of each month. They view it as misrepresentative and unreliable in depicting the hours of direct care provided per resident
per day.
Review PBJ Submission
• Set budgets per job code– Identify information gaps
• Fill gaps by importing data or manual entry
• Share data with key stakeholders for review
• Make sure data is auditable
Submitting PBJ Data to CMS
• Manual data entry• Upload an XML file
directly from an automated system
• Combination of both• NOTE: the file version is
changing June 26 to version 2 for upload!
Frequently Asked Question
• With the file size limitation of 5 MB, are we going to be able to upload multiple files for that same facility, or are we going to have to break it down if it goes over 5 MB?
CMS does allow you to upload your ZIP files as many times as you would like throughout the collection and 45 day grace period. Keep in mind that CMS requires an XML file format of your data. In this format, 5 MB is quite large.
Utilize Technology
• Too many moving parts with information in multiple systems to do this all manually
• Software can provide the help you get staffing right– Meet PBJ/Five Star staffing
goals
– Automate scheduling & labor management
– Staff to resident need and labor budgets
OnShift Schedule’s Payroll-Based Journal Reporting
Collect Review Submit
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Schedule
Payroll Based Journal
Sneak Peek
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OnShift For PBJ Reporting
• Product is available now– XML successfully
submitted
• Set up process has started!
OnShift is actively working with clients in preparation of the July 1 deadline.
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Q
A
&
Interested In Getting Started?
• Simply answer Yes to the poll question
• Email Ryan to set-up a time to discuss in further detail
Ryan EdgerlyDirector of Account [email protected]
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