PBJ Data Finally Starts, & Is Publicly Available
The payroll based journal program shifted into a higher gear with the publication of a new CMS Survey and Certification letter. PBJ data is now publicly available and visitors to Nursing Home Compare will start seeing icons describing levels of PBJ compliance for every facility.
Earlier in the year, CMS reported that over 90% of facilities successfully submitted a PBJ report – although CMS identified data and technical issues to clean up. Those changes came through in a new Policy Manual and FAQ after industry experts helped teach the industry PBJ details, requirements and how to implement their systems and processes to stay compliant
CMS to Share PBJ Data
In a recent Survey and Certification Letter (S&C: 17-45-NH), the Centers for Medicare and Medicaid Services (CMS) announced that they will begin publishing public use files containing some nursing staffing data submitted through the Payroll Based Journal (PBJ) system on Nov. 1, 2017. The data will be posted here for viewing by long term care facilities, stakeholders, or the general public.
While CMS intends to start using the PBJ data to calculate and report staffing levels, tenure, and turnover measures in 2018, at this time, the 5-Star system continues to rely on staffing data collected on form CMS-671 at the time of a facility’s survey.
September 2017

CMS announces date for PBJ public use files to be made public
In a memo published earlier this week, CMS announced that they will begin posting PBJ public use files for viewing by LTC facilities, stakeholders, and the general public at https://data.cms.gov/ on November 1, 2017.
The first public use file posted will include data submitted by facilities for the reporting period of calendar quarters 1 and 2, which had deadline submissions of May 15 and August 14 2017. CMS will continue to post subsequent quarters of data as they become available.
The data will include the total number of hours submitted for nursing services job categories (e.g., registered nurse, licensed practical nurse, and nurse aides) for each day in the quarter, in addition to each facility’s census for each day in the quarter as calculated using minimum data set (MDS) submissions.
Link no longer available. The Post-Acute Advisor, 27 Sept. 2017.
CMS Staff Tracking System Promises More Accuracy
The new payroll-based journal (PBJ) system developed by the Centers for Medicare & Medicaid Services to determine the staffing component ratings in the Five-Star Quality Rating System will likely be “a huge change, [resulting in] a more comprehensive and more accurate” look at a facility’s staffing, Ashkan Javaheri, MD, CMD, said at the AMDA – the Society for Post-Acute and Long-Term Care Annual Conference.
Medical directors’ hours are part and parcel of the new system, and “it’s important to understand that the hours you [record and] submit should be based on your medical directorship duties — on what the facility is paying you to do,” said Dr. Javaheri, assistant professor at the University of California–Davis School of Medicine and head of the geriatric division at Mercy Medical Group–Dignity Health Medical Foundation in Sacramento. “Hours for your patient care are not reportable in PBJ.”
CMS urges more provider diligence on PBJ data
Skilled nursing providers should submit their next round of payroll based journaling data well ahead of the May 15 deadline in order to catch errors, Centers for Medicare & Medicaid Services officials said Thursday.
CMS staff told attendees of the Skilled Nursing Facility Open Door Forum call to not hold out until the deadline in order to see if there are “errors and issues” and leave time for corrections if needed.

PBJ updates make it easier for providers to submit hire, termination, and rehire information
On February 17, 2017, the Centers for Medicare & Medicaid Services (CMS) released two updates to the Payroll-Based Journal, making it easier for providers to submit hire, termination, and rehire information for employees without receiving errors.
These updates, detailed below, are considered a “step in the right direction” by the American Health Care Association (AHCA) in their pursuit, joined by other providers and organizations, to “create efficiencies in the collection of staffing data.”
The Post-Acute Advisor, 23 Feb. 2017. Link no longer available.
Don’t punish SNFs for training
The Centers for Medicare & Medicaid Services have made information technology and staff competency a priority for the past five years. In response, skilled nursing facility educators expanded training programs to keep up with increased needs. For example, a Certified Nursing Assistant early detection training program was focused on decreasing re-hospitalizations.
Then in July 2016, the Payroll Based Journal system became mandated. It requires a SNF to deduct the hours CNAs participate in in-service training so that staffing levels will be accurately reflected for the Nursing Compare Five Star Rating reporting. Consequently, SNFs are be penalized for training their staff. That’s despite saving the CMS money by avoiding unnecessary hospital readmissions and improving quality of care.
Providers get an ‘A’ for submitting PBJ data, officials say
Around 90% of long-term care providers have submitted electronic staffing data, officials said Thursday.
The Payroll-Based Journal submissions were due Nov. 14 to reflect staffing data from July 1 to Sept. 30. However, the Centers for Medicare & Medicaid Services will accept submissions until Dec. 1 as long as providers are making a “good faith effort,” according to sources on a CMS Skilled Nursing Facilities/Long-Term Care Open Door Forum call Thursday.
CMS: deliver data — or else
Providers who miss staffing data submission deadlines could be sanctioned — and see their Five-Star Nursing Quality Ratings suffer — federal officials said.
Nursing home operators are required to submit Payroll-Based Journal staffing data for the July 1 to Sept. 30 period no later than Nov. 14. Failure to do so could bring serious consequences, officials with the Centers for Medicare & Medicaid Services said on a SNF Open Door Forum call.
October 1, 2016
The cost of payroll-based journal reporting adding up fast
For the past year, skilled nursing facilities have been aware of pending new regulations from the Centers for Medicare & Medicaid Services (CMS). Facilities are required to electronically submit detailed direct-care staffing information, with the intent of linking those staffing records to the CMS’ five-star rating system.
When the first quarterly reporting period for the Payroll-Based Journal (PBJ) program began July 1, long-term, post-acute care providers have woken up to the realization that meeting the requirement is more difficult and time-consuming than originally thought. As a result, many have turned to the vendors of time-and-attendance software and other solution providers for help.
July 20, 2016
PBJ staffing data submission gaining steam, CMS officials say
Nearly half of skilled nursing facilities have registered to voluntarily submit electronic staffing data, officials with the Centers for Medicare & Medicaid said Thursday during an SNF Open Door Forum call.
Facilities were strongly encouraged to submit electronic staffing data beginning in October 2015 as that voluntary period was “created specifically to help providers prepare” for the mandatory filing period, said Evan Shulman, deputy director of the Division of Nursing Homes at CMS, according to call attendees.
Avoid these 'gotchas' in PBJ reporting
The latest communications from the Centers for Medicare & Medicaid Services indicate mandatory PBJ submission will not be delayed. Most skilled nursing facilities are starting the work to prepare for the first Payroll-Based Journal submission that is due no later than November 14.
Here’s some of the trickier parts of the PBJ reporting rules that you will need to either validate or make changes to your systems and processes to ensure your staffing data is PBJ compliant.
May 16, 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
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.
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?
March 8, 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.
March 3, 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.

QSO Memo 17-45-NH

PBJ Policy Manual v2.4

PBJ Policy FAQs Sep '17





