CMS Staffing Data Requirements

“PBJ” may be hard to swallow!Lori Brunholtz, CPAManaging Director, BKD, LLP

918.584.2900 lbrunholtz@bkd.com

Staffing Data Required by ACA

Electronic submission of:– Direct Care hours including agency & contract

– Specific categories• RN, LVN, CNA, therapist, & other medical personnel

– Resident census & case mix

– Capture employee turnover & tenure

– Report hours of care

– Auditable data

– Uniform format

Staffing Data Collection

• CMS developed Payroll-Based Journal “PBJ”

• Data to be submitted through QIES• Mandatory start July 1, 2016

• Quarterly submission

• Data will eventually be used in

5-Star Quality ratings– Continue to complete the CMS-671 form for

staffing during survey until transition to PBJ data

Definition of Direct Care StaffPer CMS…“Direct Care Staff are 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 staff does not include individuals whose primary duty is maintaining the physical environment of the long term care facility (for example, housekeeping).”

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html

Detailed Staff Information• Individual IDs – staff & contractors• Hire date• Termination date• Pay type – exempt, non-exempt, contract• Labor category – general department• Job title – specific role

– Hours split if multiple roles performed

• Enter each employee’s hours worked DAILY– Night shift hours spanning midnight must be split – EXCLUDE paid leave time, inservice, training, on-call– EXCLUDE paid meal time– Short breaks throughout the day may be included

Detailed Staff Information• Salaried employees – report only base

hours, even if more hours worked• Medical Directors, other specialists &

contractors, corporate personnel– “reasonable methodology” for reporting

facility time related to resident care– DO NOT report attending physician or

patient care time that the physician or contractor can bill for separately

• Exclude non-SNF/NF time (hospital, ALF)• Exclude volunteers

Detailed Census Information

• Month-end snapshot only

• Only count residents in facility on last day of the month

• By payer – Medicare, Medicaid, Other– Medicare days include only FFS, Medicare

Managed Care (Medicare C) days are “other”

– Medicaid pending are “other” until approved

Reporting• Manual entry through QIES PBJ system• Data can be uploaded electronically

– interface must be in XML format– technical IT specifications on CMS PBJ website

• Due 45 days after each quarter end• Submissions/corrections accepted after

deadline, but not used for staffing measures• Data viewable through CASPER• Per CMS, PBJ data “Audits to be conducted by

individuals or entities who are subject matter experts in this area”

Staffing Data Collection

Facilities that fail to submit accurate, verifiable data

• “…will be considered noncompliant and subject to enforcement actions by CMS”

• “…submission of staffing information…is a condition of participation for Medicare or Medicaid”

Rules of Thumb

•Two basic criteria

– Only count time providing resident care or resident care management

AND

– Only count time paid by the facility

Report Hours in PBJ?• A physician visits a patient in your facility,

then bills the patient’s insurer• No, the facility is not paying the physician for

the encounter• A Hospice company’s nurse visits one or your

residents• No, the Hospice is billing another payer• A CNA participates in CPR training• No, training time should be excluded• A nurse aide in training, shadows another

nurse doing patient care• If the aide in training is being paid, their time

would be included

Report Hours in PBJ?• An LPN takes a bathroom break

• CMS states, “we recognize that nursing home staff engage in other non-care and direct care activities throughout their day, such as breaks, so time for breaks may be included”

• A volunteer takes a resident for a walk

• Volunteers are not paid, so cannot include

• The DON covers a weekend LPN shift

• If the DON is paid extra, above their salary, include, otherwise additional time is excluded

Report Hours in PBJ?• A Corporate Nurse on site assisting with

pre-survey preparation

• Corporate personnel can be counted, but only if they are providing patient care

• A CNA sometimes works as a housekeeper

• Time must be split, housekeeping is not considered patient care

• A CNA sometimes works as activities staff

• Time must be split, report activities time separately

Report Hours in PBJ?• A paid feeding assistant• Paid feeding assistant time is included• A dining assistant serving trays & taking

orders• Not considered patient care by CMS• A phlebotomist from your contract lab• Lab is considered patient care, but optional• An X-ray tech from your mobile x-ray • X-ray is considered patient care, but optional• Time spent by the Beautician washing a

resident’s hair• Not considered patient care by CMS

Report Hours in PBJ?• A Nurse Consultant on site doing MDS

training• Training is excluded• A CNA on a paid lunch break• Lunch breaks should be excluded• The facility Administrator’s time• Report Administrator & Asst Administrator in

PBJ (salary hours only)• Hours worked by an Agency LPN• Agency staff should be reported• Time paid for Holidays• All non-worked paid leave time is excluded

True or False?• Each individual from a staffing company who

works in your facility must be assigned a separate unique ID number

• True

• The salaried DON needs to clock in & out for PBJ so all her hours can be captured

• False, only base salary time can be included

• The direct care time reported for your therapists cannot exceed minutes that count toward the RUG categories

• False, all therapist time providing care can be included

True or False?• You need to change your evening shift to

end at midnight so you don’t have to split time between calendar days for the 11:00 to 7:00 shift

• False, you may want to consider adjusting your shifts, but it’s not required. However, time before and after midnight must be split and reported on the day worked

• Time nurses spend charting, care planning, completing assessments, is considered “Direct Care”

• True

True or False?• A resident is out of the facility on the last day

of the month, but is paying for bedhold, so that day should be counted in census

• False, only residents physically in the facility should be counted

• The hire date reported for an employee who left but returned is their most recent hire date, not their initial employment date

• True• You can count vacation time taken by the

DON, since she is on salary• False, non-worked paid leave time should not

be included

QUESTIONS?

Lbrunholtz@bkd.com(918) 584-2900