How HR efforts can help—or hurt—your organization’s PBJ compliance
In 2018, the Centers for Medicare and Medicaid Services (CMS) issued additional details relating to the Payroll-Based Journal (PBJ) requirements, the staff reporting system that CMS uses to calculate the staffing measures under the five-star ratings.
The electronic submission of PBJ data is now required, including all data on staff ratios and RN-specific hours, for which there is a federal minimum of eight hours. The PBJ software must be updated immediately upon every new hire or termination, and the database must be kept current for all staff credentials and certifications.
In April 2018, in anticipation of the switch to all-PBJ reporting of staffing data, CMS amended the staffing measures and clarified the definitions of some job codes. Facility staffing ratings are now based on two measures: Total staff hours per resident per day (RNs, LPNs and nurse aides) and RN-specific hours per resident per day.
CMS uses the following job codes in the calculations for staffing measures:
- RN hours: Includes RN director of nursing (job code 5), registered nurses with administrative duties (job code 6), and registered nurses (job code 7).
- LPN hours: Includes licensed practical/licensed vocational nurses with administrative duties (job code 8) and licensed practical/vocational nurses (job code 9)
- Nurse aide hours: Includes certified nurse aides (job code 10), aides in training (job code 11), and medication aides/technicians (job code 12)
All staff under these job codes 5-12 are included in the PBJ data reporting, whether they are full-time, part-time or contract employees. Among those not included are housekeeping staff, hospice staff, feeding assistants and private-duty nurses hired by the resident or family. If an employee is in the PBJ system under the wrong job code—or if an employee is performing tasks that should be considered a different job code or multiple job codes—it can skew the staff ratios once the CMS PBJ formula is applied.
The other big factor is the resident-to-staff ratio. If the organization’s PBJ system shows a deficiency in staff coverage per resident day, the organization’s penalty could be the automatic loss of a star in the staffing section of its CMS five-star ratings. The greater the deficiency, the more stars could be lost—and the loss remains for the rest of the quarter.
HR’s Role in PBJ Compliance
Ensuring compliance with PBJ mandates is a concerted effort among clinical administrators, IT and HR. While clinical directors are responsible for scheduling the nursing coverage, HR directors should review PBJ data on a regular basis to ensure employees are placed in the correct job codes. If some employees seem to be performing duties of a job code above them (such as “helping out” with RN duties on a regular basis), it may be in the organization’s best interest to offer enough training to elevate that employee to the higher job code, which will improve the PBJ staffing ratios.
For information on other 2018 changes, see the CMS Design for Nursing Home Compare Five-Star Quality Rating System: Technical Users’ Guide (PDF). The Staffing Domain section of the report details how the changes affect five-star quality ratings.