Payroll-Based Journal Reporting: Strategies To Get Ready

PBJ Importance

• CMS is mandating that all Skilled Nursing Facilities submit electronic census and staffing information on a quarterly basis – July 1st, 2016 is the first date providers

must start collecting this information

• Failure to submit or reporting inaccurate data can be costly, potentially leading to citation and civil money penalties. (requirement of participation)

• Information used on Nursing Home Compare

• Believed to be used in Five Star Quality Ratings starting in 2018

1July

Why Paychex Is Working With OnShift

• OnShift Software is the leader in labor management software for Skilled Nursing Facilities

• Paychex is working with OnShift because of OnShift’s PBJ thought leadership and 100% focus on the industry

• OnShift has a proven solution that can assist Paychex clients meet this requirement

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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

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

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 collection 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 MDCN.mco@palmettogba.com containing your login information. Using this information you will connect through the 'CMS Secure Access Service'.

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.

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 time worked. • 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.

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.

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.

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

Meet PBJ staffing regulations Eliminate data gathering complexitiesImprove reporting accuracy with checks and balances

Payroll-Based Journal Reporting In 3 Easy Steps

Collect Review Submit

Payroll Based Journal

Sneak Peek

- Confidential -

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.

- Confidential -

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