CMS communicates major policy changes, survey focus requests and nursing home goals through memorandum and letters to its survey and compliance partners in the field.
PBJ-based staffing data is increasingly used for survey and deficiency (f-tags) citations of SNFs.
These changes are not exclusively announced in QSO Memorandums. Any new policies also get documented in the PBJ Policy Manual & FAQs and/or the Five Star QRS Technical Users Guide and/or the Federal Register.
These QSO memoranda, guidance, clarifications and instructions are sent to State Survey Agencies and CMS Regional Offices.
State Survey Agencies are responsible for the survey (inspection) to determine if nursing homes are complying with the prescribed health and safety standards under the agreements in Section 1864 of the Social Security Act (the Act) and collectively known as the certification process.
They are typically sent from the Director of CMS’ Quality, Safety & Oversight Group. Prior to 2019, they were sent from the Director of CMS’ Survey and Certification Group (before it was renamed).
PBJ Central has gathered Quality and Safety Oversight (QSO) memorandums from CMS that relate to staffing policies and payroll based journal reporting. Review the QSO memo archives to uncover insights on PBJ compliance from how CMS communicates these changes to the States. Here's a brief summary of major changes since PBJ began in 2016.
In a series of Survey and Certification letters from CMS to the States, the rule making process for the creation of the payroll-based journal program is completed. In addition, CMS provides the technical specifications and key milestone dates for the newly created program. July 1, 2016 is set as the go live date for PBJ.
From the July 1, 2016 launch of PBJ reporting, CMS focused on ensuring skilled nursing facilities are consistently reporting, and reporting comparable, like data. In the 2016 and 2017 Survey and Certification letters from CMS to the States, CMS shared reporting progress, changed and simplified reporting requirements, and finally made PBJ data available to the public starting November 2017.
Now with several years of PBJ data in hand, CMS transitioned to PBJ-based Staffing Five Star ratings and added penalties for non-compliance. In the 2018 and 2019 Survey and Certification letters from CMS to the States, CMS transitioned from CMS-671 staffing reports to PBJ reports, added penalties for the 6% of facilities not reporting daily RN hours, and refined the measures and rating tiers used in Five Star calculations.
The COVID pandemic greatly impacted the Five Star rating system for skilled nursing facilities. PBJ data collection was paused temporarily. The newly renamed Quality & Safety Oversight group of CMS notified States of updated processes and rules to oversee nursing homes during the pandemic and the eventual re-start of PBJ data collection and staffing Five Star calculations.
Got more PBJ data? Make more staffing rules! In these Quality & Safety Oversight letters from CMS to the States, CMS implemented additional outcomes for nursing homes to monitor and fix. New compliance approaches included Weekend staffing and Staff Turnover measures, sharing of PBJ data with state surveyors to trigger investigations of non-compliance and use of staffing to identify Special Focus Facilities
QSO Memorandums answer an important question about new CMS policies: "Why?".
You can track changes to the PBJ Policy Manual and the Five Star Technical Users Guide to find out "what" changed. And "when" the changes become effective. However, those changes are very technical in nature, and do not come with any explanation for the rationale or objective that triggered the change.
We monitor QSO Memorandums to distill a deeper understanding of the policy or regulation change. Often our experience is these changes signal future enforcement or compliance focus. Closely monitoring CMS' explanations in these Memorandums enable the reader to stay prepared.
Find all QSO memorandums on CMS.
Take a course in the PBJ Academy for a practical hands-on understanding of the PBJ policies and penalties in real-life.
Browse our QSO Memorandums archive to view prior versions of the PBJ manual and see how it changed over time (requires login).
To view the PBJ QSO Memorandum archives, create a free account on our PBJ Circle member hub.
