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Payroll-Based Journal (PBJ) Priorities

Avoid Top Errors & Identify Effects on Star Ratings & PDPM

April 10, 2019

› Individuals Participate in entire webinar Answer polls when they are provided

› Groups Group leader is the person who registered & logged on to the webinar Answer polls when they are provided Complete group attendance form Group leader sign bottom of form Submit group attendance form to training@bkd.com within 24 hours of webinar

› If all eligibility requirements are met, each participant will be emailed their CPE certificate within 15 business days of webinar

To Receive CPE Credit

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Your Presenter

Joanne Jones, RNDirector jjones@bkd.com

Today’s Learning Objectives

1Review recent policy manual updates & common areas of misreporting2

3Discuss the staffing issues that trigger PBJ audits & strategies to address the issues & facilitate accurate submission. Review process for submitting information if selected for an audit

Review the key data requirements under PBJ & how they affect the CMS Five-Star Rating System

Recognize the role of PBJ data under PDPM4

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History of PBJ Reporting

› Mandatory reporting initiated › 3rd Quarter CY 2016

› July 1–September 30, 2016

› CMS posted Public Use Data file› November 1, 2017

› Staffing data used for Staffing Star rating› April 2018 Nursing Home Compare Update

› PBJ Policy Manual & Q&A Document Updated› October 2018

PBJ Reporting Requirements

› Mandatory reporting of staffing hours› Paid worked hours

› Submitted at least quarterly › Can submit more frequently

› Submission must be timely› No later than 45 days after completion of quarter

› Staffing data must be auditable› Must have back up to support hours submitted

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PBJ Reporting Requirements

› Required departments/positions for reporting› Administration› Nursing › Medical Director› Therapy – PT/OT/SLP› Consulting Pharmacist› Dietician› Social Services› Activities› Respiratory Therapist

PBJ Reporting Requirements

› Reporting of staffing hours

› All facility employees working in the SNF› Full time, part time & per diem

› Any contract staff › Staff hours allocated to SNF from co-located

facilities› Hospital-based SNFs

› Consultants

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PBJ Reporting Requirements

› What hours need to be reported› Paid worked time

› No paid benefit time should be included

› Training time› No offsite training time

› No off unit training time

› Onsite only if staff is available to provide care to residents

› Time billed to a third party› Therapy time is reportable

› Physician, Nurse Practitioner time is not reportable if billed to third party

PBJ Reporting Requirements

What staffing data needs to be reported?

› Job Title code› Reflective of primary job function

› Staffing hours by each day/date by employee ID

› Hours must be reported for the day worked› Shifts that cross midnight must report the

specific hours for each day

Example

11PM – 7AM shift• 1 hour for the day the

shift started• Remaining hours on the

next day• Determine when meals

are taken

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PBJ Reporting Requirements

› Staffing hours by each day/date by employee ID

› Reported in hours › Round minutes to the nearest 10th

› Facility may opt to round to the nearest 100th

Important to know how your software is rounding your minutes.Remember it is paid time!

PBJ Reporting Requirements

› Meal Break Policy

› Subtract 30-minute meal time from each full shift› Regardless if meal time is paid or unpaid

› Whether or not the employee takes the break

Shift Hours Paid Hours Meal Break PBJ Hours

8 7.5 30 minutes unpaid 7.58 8 30 minutes paid 7.58.5 8 30 minutes unpaid 812 12 30 minutes paid 11.5

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PBJ Reporting Requirements

› Meal Break Policy

› If meal break is longer than 30 minutes› Deduct actual time taken for meal break

› If meal breaks are provided for shorter shifts› Deduct meal break time according to facility’s policy

› Questions raised in “Household model”› Employees are required to eat with the residents

› Still need to deduct 30 minutes from PBJ-reported time• Requirement for 30-minute meal break regardless if employee takes the time

PBJ Reporting Requirements

› Universal Care Workers› Staff are typically CNAs› Provide other non-CNA services

› Cooking› Cleaning

› Facility must adopt methodology to separate time› Report only time providing CNA direct services› Document how Facility developed methodology

› Time Study› Need to have documentation in the case of an audit

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PBJ Reporting Requirements

› Pay Type Code› Exempt

› Report only hours expected to work as exempt employee

› Documented in facility policy

› Do not report “additional hours” unless receiving additional pay

› Be careful – risk “exempt” status

› Non-exempt

› Report hours worked & paid

› Contract

› Actual hours worked at the facility

PBJ Reporting Requirements

› Timely Submission› 45 days after the end of the quarterly reporting period

› Submission must be accepted into the CMS database› Check the file validation report

Fiscal Quarter Date Range

Submission Deadline(11:59 PM ET)

1 October 1 – December 31 February 142 January 1 – March 31 May 153 April 1 – June 30 August 144 July 1 – September 30 November 14

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PBJ Reporting Requirements

› Staffing data must be auditable

› Employees› Payroll Records & /or Time & Attendance

› How do you record adjustments between pay periods?

› Agency staff› Vendors providing file in PBJ format

› Are you getting backup documentation from agency records?

› Facility will be liable for accuracy in an audit not vendor

PBJ Reporting Requirements

› Staffing data must be auditable› Consultants

› Examples: Consulting Pharmacist, Dietician› Providing documentation on hours working in the facility

› Tied back to invoice or a contract

› Medical Director› Methodology for separating time between direct patient care & administrative

duties› Tied back to payroll, invoices or a contract› Document the methodology used

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PBJ Reporting Requirements

› Census Data

› No longer required to be reported › Daily census is now calculated based on the MDS

› Important that all discharge MDSs are transmitted by the PBJ submission deadline for accurate calculation

› Need to accurately reflect the acuity of the patients

› May inflate the expected staffing

• Need to accurately reflect the number of residents in facility

› May reduce the actual RN & Total Nursing HRD

PBJ Audits

› CMS PBJ Audits are conducted by outside firms

› Granite Dolphin Actuarial Services› Myers & Stauffer

› Audits are conducted after each quarterly submission

› Typically requests go out 30 days after submission deadline› Third CY Quarter 2018 had a 2nd round of audits

› Information requested was due prior to end of December 2019

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PBJ Audits

› Process

› Administrator notified via email & certified mail› Specific PBJ support information is requested by auditors

› Given specific timeframe to respond› 5 to 7 days experience for some providers

› Required to submit information to a secured website› Request information in Excel or Access format if available

› Facility can scan documents if not available in Excel/Access

PBJ Audits

› Information requested› Payroll &/or timekeeping records

› Daily time system reports, timecards or punch detail reports› Payroll records & reports› Description of department job code/department listings

› Cross walk between employees’ IDs used in PBJ & employees on payroll records

› Cross walk between PBJ job title code & job titles in the payroll/timekeeping systems

› Invoices for contracted/agency staff› Documentation & methodology for allocation of hours reported (shared

staff, consultants, Medical Director)

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PBJ Audits

› Audit Goal

› To verify the accuracy of the hours submitted› Verified that hours were worked & paid

› Triggers for Audits

› Significant increase in hours from one quarter to next› High hours per resident day (HRD)

› RN or Total Nursing

› Lack of RN onsite each day

PBJ Audit Impact

› Results of PBJ Audit› Discrepancies that are identified are classified as minor or significant › Significant discrepancies

› Differences would have changed the Staffing Star rating › Differences that would have changed how facility compares to its state average› Will result on 1 Star staffing rating› Will reduce overall rating by 1 Star› 1 Star rating reduction will be in place for 3 months from finalization of the audit

› Facility does not respond to an audit request› Will result in 1 Star staffing rating for 3 months from deadline for information submission› Will reduce overall rating by 1 Star

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PBJ Impact on 5-Star Rating

› Nursing Staffing Star Rating is based on Adjusted Hours(Reported Hours / Expected Hours) * National Average Hours

› Reported Hours = Facility PBJ Submitted Hours› Expected Hours = Nursing HRD associated with RUGs IV Groups› National Average Hours = Average PBJ-Reported Hours

› Calculated each Quarter

› Exclusion criteria for Staffing Star Rating › Total Nursing is < 1.5 HRD› Total Nursing is > 12 HRD› Nurse Aide Staffing is > 5.25 HRD

PBJ Impact on 5-Star Rating

› Staffing Star Rating Methodology changes effective April 2019

› Changes to Scoring Exceptions› 4 or more days in quarter with no RN staffing hours

› Was 7 days

› New thresholds for staffing ratings› Increase the weight that RN staffing has on rating

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Staffing Star Thresholds – Adjusted Hours

Staff Type 1 Star 2 Stars 3 Stars 4 Stars 5 Stars

RN < 0.246 0.246 – 0.382 0.383 – 0.586 0.587 – 0.883 ≥ 0.884

Total < 3.176 3.176 – 3.551 3.552 – 4.009 4.010 – 4.237 ≥ 4.238

April 2018

April 2019

Staff Type 1 Star 2 Stars 3 Stars 4 Stars 5 Stars

RN < 0.316 0.316 – 0.500 0.501 – 0.723 0.724 – 1.041 ≥ 1.042

Total < 3.107 3.107 – 3.573 3.574 – 4.037 4.038 – 4.403 ≥ 4.404

Staffing Star Rating Methodology

April 2019 Staffing Star Rating

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PBJ Reporting & PDPM

Unknown

› Will facilities change the type of admissions› PDPM rewards medically complex admissions

› Increase in medical complexity may require higher RN hours

› Will CMS change methodology for Staffing Star Rating › Currently based on RUGS IV

› RUGS IV will no longer be supported after October 2020

Next Steps – PBJ Success

› Verify competency of staff responsible for PBJ submission

› Understands how to validate submission & data acceptance› Understands facility-specific mapping of PBJ job title codes

› Documentation is in writing

› Knows how to utilize CASPER reports to identify potential errors› Understands how to pull documents if necessary for audit

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Next Steps – PBJ Success

› Establish process for verifying accuracy of your data

› Submit early – Don’t wait until last minute› Submit at least 10 days before quarterly deadline

› If submitting more frequently, make sure that overnight shift is reported accurately

› Utilize CASPER reports to identify potential errors› 1702S – Staffing Summary Report

› Identify missing hours by category

› Compare with previous quarter to see variances

› Not attributed to change in total days

Next Steps – PBJ Success

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Next Steps – PBJ Success

› Review mapping of facility job titles to PBJ job titles › Develop a document that outlines mapping

› Audit periodically – new job titles› Audit new employees’ job titles assignment

› Review 1704S – Daily MDS Census Summary Report › Compare to facility daily census › Identify any potential missed discharged assessments

› Determine need for PBJ “scrubbing” software› Analyzes data before it is submitted to CMS

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Continuing Professional Education (CPE) Credit

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› CPE credit may be awarded upon verification of participant attendance

› For questions, concerns or comments regarding CPE credit, please email the BKD Learning & Development Department at training@bkd.com

CPE Credit

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The information contained in these slides is presented by professionals for your information only & is not to be considered as legal advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered.