Getting prepared for the new payroll-based journal reporting requirements

Mar 30, 2016 | Rules for PBJ Reporting, CMS' PBJ Policies

News Digest: Getting prepared for the new payroll-based journal reporting requirements

With just three months to go until the PBJ program starts July 1, the industry and nursing facilities are going over PBJ program details, learning about the requirements and thinking about how to implement their systems and processes to stay compliant.  Industry experts are actively sharing their expertise and perspective on how to get ready for the program.


Are you prepared for the new payroll-based journal reporting requirements?

We believe the number-one best practice is a total solution for PBJ reporting that covers all new CMS requirements. Here’s our list of the top five issues to address, and don’t forget to budget for possible additional fees.

Mandatory compliance with the new Centers for Medicare & Medicated Services (CMS) payroll-based journal reporting (PBJ) requirements begins July 1, 2016. Are you prepared?


“Are You Prepared for the New Payroll-Based Journal Reporting Requirements?” Plante Moran, 8 Mar. 2016,


Organizational Impact and Preparing for CMS Payroll Based Journal

Experts from CliftonLarsonAllen provided an extensive learning session to help skilled nursing providers

  • understand the CMS payroll based journal voluntary reporting and how to prepare for mandatory reporting
  • review the set up process from online reigstration through submission
  • analyze the payroll data requirements and key terms used
  • review the classification of employees and how to properly categorize staff for PBJ reporting


CliftonLarsonAllen. “Organizational Impact and Preparing for CMS Payroll Based Journal.” CLAConnect.Com, 25 Mar. 2016,


CMS Releases Updated PBJ Manual To Allow For On & Off Site Medical Director Responsibilities To Count

Last week, the Centers for Medicare & Medicaid Services (CMS) released survey and certification letter 16-13 which reminds long-term care facilities that the mandatory submission period for electronic reporting on staffing begins on July 1, 2016. The Society for Post-Acute and Long-Term Care Medicine met with CMS and argued that the “on site” requirement for reporting Medicare Director hours could lead to inaccurate reporting.

CMS has amended this requirement in its recent changes to the Payroll-Based Journal (PBJ) – Implementation of required electronic submission of Staffing Data for Long Term Care (LTC) Facilities manual, which includes the removal of “on site” when describing the way Medical Directors hours are to be reported.


“CMS Releases Updated PBJ Manual to Allow for On and Off Site Medical Director Responsibilities to Count | AMDA | The Society for Post-Acute and Long-Term Care Medicine.” The Society for Post-Acute and Long-Term Care Medicine, 25 Mar. 2016,


CMS Requires Payroll-Based Journal, Electronic Staffing Data Submission for Skilled Nursing Facilities, Effective July 1, 2016

Effective July 1, 2016, skilled nursing facilities (SNFs) will be required to submit staffing, time and attendance information electronically to the Centers for Medicaid and Medicare Services (CMS) via their Payroll-Based Journal (PBJ) system.

These requirements originate from section 6106 of the Patient Protection and Affordable Care Act (PPACA), and the final rule requires facilities to submit direct care staffing information, in a uniform and auditable format, at least quarterly. Early implementation is allowed; the CMS has been accepting electronic PBJ submissions since October 2015.


Webb, Charles. “CMS Requires Payroll-Based Journal, Electronic Staffing Data Submission for Skilled Nursing Facilities, Effective July 1, 2016.” AAFCPAs, 3 Mar. 2016,


CMS Issues Finalized PBJ Manual

The Centers for Medicare and Medicaid Services has issued the updated/final ‘Electronic Staffing Data Submission Payroll-Based Journal Long-Term Care Facility Policy Manual’ (PBJ Manual); Version 2; March 2016


“CMS Issues Finalized PBJ Manual.” LeadingAge, 16 Mar. 2016,

Related CMS and PBJ Resources

To learn more about the details, policies and information in these articles, please review these CMS and PBJ publications.

Cms qso memorandum for pbj
S&C Memo 16-13-NH
Payroll based journal policy manual
PBJ Policy Manual v2.0

More News in this PBJ Topic

Understanding Staffing Compliance Issues & Exemptions

News Digest: Proposed Rule Includes More than Minimum Staffing Lost in the uproar over minimum staffing requirements for RN's and CNA's are a number of additional provisions in CMS' Proposed Minimum Staffing Rule.  A delayed rollout and provisions...

read more

Comments on Staffing Rule Pour in to CMS

News Digest: Overwhelming Response to CMS' Proposed Rule on Minimum Staffing The 60 day comment period for the Proposed Minimum Staffing Rule ended November 6, 2023.  AHCA and Leading Age associations led efforts to generate industry response. ...

read more

Plans to Defeat CMS’ Proposed Minimums Rule

News Digest: Various Strategies Floated to Avoid Proposed Minimum Staffing Rule With widespread opposition to CMS' Proposed Rule, a variety of tactics are under consideration to overcome the potential regulations.  Both a Congressional over ride...

read more

Congress Weighs in on Proposed Staffing Rule

News Digest: Legislative branch questions proposed executive rule Federal legislators in Congress vocally responded to CMS' proposed rule.  While CMS considers public comments and works on the Final Rule in 2024, the congressional push back can...

read more

CMS Updates Staffing & Turnover Measures

the Centers for Medicare & Medicaid Services (CMS) issued updates to guidance on minimum health and safety standards that Long-Term Care (LTC) facilities (often called “nursing homes”) must meet to participate in Medicare and Medicaid.

CMS also updated and developed new guidance in the State Operations Manual (SOM) to address issues that significantly affect residents of LTC facilities.

read more

CMS Issues Proposed Minimum Staffing Rule

News Digest: CMS Issues Proposed New Minimum Staffing Rule Some predicted that the payroll-based journal program was intended to enable the creation of a minimum staffing requirement.  8 years after the PBJ program was launched, that prediction...

read more

Congress weighs in on possible minimum staffing rules

News Digest: Congress Weighs in on possible minimum staffing rules CMS took its time between an early 2022 announcement of the INTENTION to create minmium staffing regulations until the Sept 1, 2023 announcement of the ACTUAL Proposed Minimum...

read more

Minimum staffing requirement: Thank you?

Minimum staffing requirement: Thank you?“The only way to assure there is enough staff in a skilled nursing facility is to implement a minimum staffing requirement.” When you hear or read statements like this from a member of Congress, a staffer at...

read more