Payroll-Based Journal
An overview of the section of the Affordable Care Act that mandates all long-term care facilities to submit data about employees working in direct care called a Payroll-Based Journal.
What is a Payroll-Based Journal?
Employee turnover and length of tenure in long-term care facilities and nursing homes is one of the most important aspects of quality care, according to the Center for Medicare and Medicaid Services (CMS).
That’s why it’s especially important to track staff data at these facilities and for consumers to be aware of the quality of staff when they make buying decisions.
In an effort to exponentially increase the accuracy and transparency required of nursing home staff data reporting, Section 6106 of the Affordable Care Act (ACA) created a new Payroll-Based Journal (PBJ) mandate.
The law enforces a requirement in which all “long-term care facilities” are mandated to submit data about employees working in direct care.
The PBJ submission program wasn’t always compulsory. When it was first launched on Oct. 1, 2015, it was optional. But in order to expand the program, encourage improvement in an industry that struggles with understaffing and provide better data to consumers, the ACA made the journal mandatory on July 1, 2016.
Every long-term care facility has 45 days from the end of each quarter to submit the previous quarter’s report to the CMS.
As of November 2017, the CMS began to use the collected data to create a five-star direct care provider rating system, employed in the search system available on medicare.gov to help users compare the quality of nursing homes around the country. The grades are based on four criteria:
- Health inspections
- Staffing
- Quality measures
- Overall
This data also allows the CMS to ensure more quality care of homes around the country and verify that these facilities maintain an acceptable and functional level of staff on hand at all times.
Who Needs to Use a Payroll-Based Journal, and Who Must Be Reported?
The ACA specifically states that the PBJ reporting requirement applies to all long-term care medical and nursing facilities.
Long-term care facilities are defined as any location that provides skilled nursing services to residents or patients who require everyday aid with activities. In addition to nursing homes, these facilities also can include rehab centers, inpatient behavioral health facilities and long-term chronic care hospitals.
Locations that fit this definition are required to catalog and submit extensively detailed quarterly data on all employees who work in direct-care-related positions. This includes employees who are employed both as agency staff and contract staff.
The CMS defines “direct-care staff” as any employee who uses a social or interpersonal skill set to provide care or is tasked with the residential care management to provide healthcare or other services that improve or sustain the mental, physical or psychological health and wellness of the patient or resident. This can include nursing staff, management and more.
However, some employees often employed at long-term care facilities are not required to be included in the PBJ reports because they do not fit the “direct-care” description. For example, janitors, housekeeping, maintenance, tech support and other staff responsible for repairs, cleaning and routine upkeep of the facility are not considered direct-care employees.
Corporate staff hours, on the other hand, only should be reported when those staff members are performing duties that directly involve resident care.
Long-term care facilities include data in their PBJ report that supports the United States Census by tracking resident data. On a monthly basis, the facility is required to report how many residents pay primarily via Medicaid, Medicare or “other.”
What Kind of Data Is Required in a Payroll-Based Journal?
The CMS developed a specific PBJ reporting system in order to streamline the reporting process and better handle the flow of large quantities of highly specific, detailed employee information.
For the official, comprehensive rundown of the PBJ process, visit the official CMS website. The page also includes registration material so that you’re officially prepared to file your report at the end of the quarter.
Long-term care facilities are required to list every individual employee working in direct care. The CMS’s PBJ system organizes employees into 40 individual job types, each with an associated labor category code and job title code. Each of these categories will need to be included when listing every individual employee, along with that employee’s hours and the day those hours were worked.
Required information data points about direct-care employees include:
- Unique employee ID.
- Employee’s hire date.
- Termination date (if applicable).
- Pay type code (non-exempt, exempt or contract).
- The workday and date.
- The job category code.
- The job title code.
- The hours worked per day and date.
How to Submit a Payroll-Based Journal
A PBJ can be submitted to the CMS via its website in three ways:
- Automatically with a pre-prepared XML file of up to 5 MB. This works similarly to how MDS data is currently submitted. The data must meet technical requirements established by the CMS, however. These requirements are established in documentation located here. The CMS also established a tech-support email for any further questions when formatting your XML, which is: NursingHomePBJTechIssues@cms.hhs.gov
- Manually by entering each employee line by line into the CMS system on its website. The PBJ user interface was designed to be intuitive, quick and easy to operate.
- Through both methods—whatever information is not included on your XML file can be added manually line by line into the CMS system afterward.
Employers are required to be specific and exact when tracking an individual staff member’s hours at the proper date and time under the corresponding labor category and job title code. In the case of employees who work night shifts over the course of two separate days, two individual entries are required for the single shift.
The hours of employees who are paid directly by Medicare are not required to be reported in your PBJ submission.
It’s important to be as specific and detailed as possible about the functions and duties each employee performs. Employees who transition to different duties during the course of a shift (for instance, occupational therapy one half of the day and advisory services the second half of the day) should be categorized with separate job codes for each half of the shift. The CMS reporting system will allow for this when entering data.
Nursing Home Compare and the Five-Star System
As mentioned above, all data gathered by the CMS via the PBJ report will be used for the Nursing Home Compare tool to inform the five-star quality rating system, which will measure each long-term care facility.
You can view the mathematical metrics (a system that compares the number of employee hours against the number of residents) by which the rating system is created on the CMS website here. A more technical documentation of the system is available and continuously being updated here.
Potential Penalties
There’s always the potential of a records audit since these reports have been submitted in good faith. If the facility is selected, it will be contacted both by email and certified mail.
If there are minor errors in the PBJ report after a CMS audit, the employers will be notified by the CMS after completion, and the CMS is actually very willing to work with the employer to correct those discrepancies and work to avoid errors in reporting in the future.
However, large and significant inaccuracies can impact the facility’s star rating—most likely resulting in a one-star rating in the staffing category for the quarter.
As an example of a discrepancy large enough to penalize, the CMS listed “instances where the difference between the submitted hours and verified hours is large enough that it would change a facility's star rating or change how the facility compares to its state average.”
Failure to report also will cause a long-term care facility to immediately receive a single star in the staffing category for the quarter.
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We apply innovative payroll solutions, and our payroll system comes complete with PBJ reporting built-in so you don’t have to worry about any complications. Plus, our time and attendance solutions make compliance easier.
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