payroll-based journal reporting lessons learned
TRANSCRIPT
Payroll-Based Journal Reporting Lessons Learned
Solving Everyday Workforce Challenges in Post-Acute Care & Senior Living
Ryan EdgerlyDirector of Account [email protected]
Peter CorlessEVP of Enterprise [email protected]
Introductions
- Confidential -
Today’s Agenda
• Review the new Payroll-Based Journal requirements
• Get answers to frequently asked questions
• Learn about LeadingAge & OnShift’s PBJ partnership
• View OnShift’s Payroll-Based Reporting software
What is Payroll-Based Journal?
Payroll-Based Journal (PBJ) is a new system used by CMS to electronically collect:
• Employee tenure information • Census data• Direct care hours worked – including
agency and contractor hours
Importance of PBJ Information
Failure to submit or reporting inaccurate data can be costly,
potentially leading to citation and civil money penalties.
Requirement of Participation
Accuracy is Critical
• Inaccurate reporting could have several side effects
• Enforcement action down the road
– Potential to use inaccurate data in civil liability cases
– Inaccurate data used to justify regulatory action
– Potential use within fraud and abuse situations - from false claims to anti-kickback
Additional PBJ Implications
• Tenure & Turnover
• Information on Nursing Home Compare
• Five Star Quality Ratings
Collection Has Begun
Fiscal Quarter
Date Range for Staffing Data
Submission Deadline
1October 1 –
December 31February 14
2January 1 –March 31
May 15
3April 1 –June 30
August 14
4July 1 –
September 30November 14
Submitting PBJ Data to CMS
• Manual data entry
• Upload an XML file directly from an automated system
• Combination of both
NOTE: The file version changed June 26, 2016 to version 2 for upload
Lessons Learned: Uploading Reports To CMS
• Merge
– Staffing data: If data exists for a specific day/employee ID/job title combination, it will be overwritten
• Otherwise the data for that day is simply added
– Census data: If data exists for a specific month end date, it will be overwritten
• Otherwise the data for that day is simply added.
• Replace
– All data for that specific section (census or staffing) for the specified quarter will be removed from the active database and then replaced with the data submitted in the file.
• Confirm successful submission through CASPER’s Validation Report
Staffing Data: Current vs PBJ Practices
Current PracticesPayroll-Based Journal
Practices
Reported annually during surveyReported electronically on a quarterly basis
Reported using Forms 671/672Reported using the Payroll-BasedJournal 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
Defining 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
CodeLabor 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
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.
Lessons Learned: Sometimes …
• Medicare Medicare
– Medicare Advantage (Part C) should be reported as Other
• Medicaid Medicaid
– Medicaid Managed Care should be reported as Other
– Medicaid Pending should be reported as Other
Direct Care Staffing Hours
• Staffing hours data per direct care worker
– Work day and date
– Job title code
– Hours worked per day
Hours To Count
• Communities must submit the number of hours each staff member is paid to deliver services for each day worked.
• Don’t forget to include agency and contract staff.
Hours Not To Count
• Unpaid time worked
• If a salaried employee works 10 hours but is only paid for 8 hours, only 8 hours should be submitted.
• Hours paid for any type of leave or non-work related absence from the facility, including paid meal breaks
• Hours for services performed that are billed to FFS Medicare or other payer
• Hours providing services to residents in non-certified beds
FAQ: Allocating Shift Hours That Span Two Days
• How should I report an employee’s hours where their shift spans multiple days?
– Communities must report hours to the actual days worked.
• Example: 11pm-7am shift
– 1 hour reported first day
– 7 hours reported next day
Issue is most systems are not set-up to automatically report in accordance to these requirements
Lessons Learned: Addressing the Day Divide
What providers are doing
• Change shifts to start at midnight
• Manually adjust and enter to meet regulations
• Contract with vendors that can automatically allocate these hours
FAQ: Workers That Perform Different Roles
• How are we expected to report for staff who perform different roles throughout their day?
– Utilize time & attendance systems to account for time worked in different positions.
• This is a good practice if shift responsibilities are split
– Otherwise report on the worker’s primary role
• It is understood that most roles have a variety of non-primary duties that are conducted throughout the day
– What about universal workers?
FAQ: Submitting Training Hours
• How should facilities report hours for staff who are attending training?
– Hours should not be reported if employee is not providing resident care
– Caregiving staff called in to replace those in training should have hours submitted
FAQ: Exempt Staff Working Above & Beyond
• If an exempt employee works as a floor nurse to fill in when an employee has called off, can I report those hours?
– You can report these hours – but do so carefully so that it doesn’t violate their exempt status under FLSA rules.
FAQ: Reporting Re-hires
• How do we submit hours for an employee who was terminated and then re-hired at our facility?
– CMS only allows for one hire and one termination field per submission
– This creates errors or lost data if those staff are part of the same submission
– CMS is aware of this issue
Lessons Learned: Reporting Boomerang Staff
What providers are doing
• Submit separate files for rehired staff
• Submit PBJ reports more frequently to reduce odds of rehires overriding
FAQ: Tenure Data For Contractors
Do I have to collect and submit hire & termination date for non-facility, contract and agency direct care workers?
• Yes!
– Hire date
• First day worked and billed for at your community
– Termination date
• Last day your community or the agency communicates that the contract individual will no longer be providing services at your community.
• If unsure leave blank
FAQ: Collecting Hours Non-Punched Hours
How do we report hours not captured in time & attendance system? (salaried & corporate staff, contract)
• Facilities must use a reasonable methodology for calculating and reporting the hours spent conducting primary responsibilities
• Data must be reported and auditable
– Payroll, invoices, and/or tied back to a contract
– First day worked and billed for at your community
Lessons Learned: Collecting Outside Hours
What providers are doing
• Contact agency & contractors to provide this data for upload
• Manually collect and enter into CMS
• Utilize systems to allow these caregivers to easily check in and check out
Utilize Technology
• Too many moving parts with information in multiple systems to do this all manually
• Software can provide the help you need to get PBJ reporting right
LeadingAge & OnShift Partner For PBJ
• OnShift is the leader in labor management software for long-term care
• LeadingAge partnered with OnShift because of OnShift’s proven solution and focus on aging services
&
Special Pricing for LeadingAge Members!
Payroll-Based Journal Reporting In 3 Easy Steps
Collect Review Submit
- Confidential -
QA
&
Learn More About Our Partnership
Get PBJ-Ready!
• Download presentation slides
• Request a demonstration
• Visit:
www.OnShift.com/leadingage-webinar