QSO 18-17-NH
QSO 19-02-NH

PBJ Policy Manual v2.5
PBJ Policy FAQs Nov ’18

CMS directive orders state agencies to increase weekend surveys of skilled nursing facilities

“Based on audits of the PBJ data, CMS became concerned that some nursing homes are reporting several days in a quarter without a registered nurse (RN) onsite and/or significantly low nurse staffing levels on weekends, potentially impacting risk to resident health and safety. To address this concern, CMS will provide state agencies with a list of nursing homes with potential staffing issues, those with significantly low nurse staffing levels on weekends and those with several days in a quarter without an RN on site. State agencies are now required to conduct at least 50 percent of required off-hours surveys on weekends using this list of nursing homes.”

— Bricker Graydon LLP | February 27, 2019

Will state surveyors be knocking on your door Saturday night?

“CMS will be flagging the bottom decile (10%) in each state based on total reported weekend nurse staffing. The list will be forwarded to state survey agencies, who are then charged with increasing the number of weekend surveys. Surveyors will use this list to identify facilities due for survey that have potential staffing issues and schedule their surveys to occur on the weekend. Prior to the release of memo QSO 19-02-NH, surveyors were required to perform 10% of all surveys on either weekends or off hours. Post release, surveyors are required to hold 50% of all off-hour surveys on weekends.”

— McKnight’s Long-Term Care News | February 11, 2019

CMS to take Active Role in Ensuring Adequate RN Staffing in Nursing Facilities

“CMS became concerned with RN staffing after PBJ data analysis indicated that some facilities exhibited ‘recurring instances or aberrant patterns of days with no RN onsite.’ CMS cited data showing that six percent (6%) of facilities that submitted complete data had seven (7) or more days where no hours for RNs were reported. Further, it noted that 80% of all days with no RN hours were during the weekend. CMS specified that facilities reporting seven (7) or more days in a quarter with no RN hours would receive a one-star staffing rating, which in turn, would result in a one-star drop in the facilities’ overall star rating.”

— Arnall Golden Gregory LLP | December 12, 2018

How Would Your Nursing Facility Fare on a Weekend Survey?

“CMS has identified concerns in nursing home staffing levels using the Payroll-Based Journal (PBJ) data, including multiple days with no RN on site as well as significant decreases in staffing levels over the weekend. As a result, CMS will be providing the Regional Offices and State Agencies (SAs) with a list of facilities that may have potential staffing issues to aid their investigations on survey to see if there is sufficient staffing. If no RN is onsite for the minimally required time, they will be cited at F727. The SAs are now required to conduct a minimum of 50% of required off-hours surveys on weekends using the list that CMS is providing.”

— CMS Compliance Group | December 5, 2018

CMS intensifying nursing home staffing oversight; providers say it won’t help

“The changes come after a Kaiser Health News analysis in July uncovered an average of 11% percent fewer direct-care nurses and 8% fewer aides on duty on weekends. Analysts also showed that one-fourth of nursing homes reported no registered nurse on duty for at least one day during a three month period — despite the Medicare requirement that an RN be on duty at least eight hours per day. ‘Unfortunately, today’s action by CMS will enforce policies that make it even more difficult to meet regulatory requirements and hire staff,’ David Gifford, senior VP of quality and regulatory affairs at the American Health Care Association told McKnight’s.”

— McKnight’s Long-Term Care News | December 3, 2018

Meal breaks eating away at Star ratings

“With the latest update to the PBJ Policy Manual, CMS makes very clear its rules on removing meal breaks from Payroll-Based Journal reports. With confusion and inconsistent reporting by facilities, CMS updated its PBJ Policy Manual with detailed guidance on applying Meal Breaks. Many facilities were getting ‘caught’ over-reporting staffing hours due to not adequately deducting meal breaks for all employees (regardless of pay type). The policy manual now states: Meal times, paid or unpaid, shall not be reported for all staff (exempt, nonexempt, and contract). Facilities must deduct the time allotted for meals from each employee’s daily hours.”

— SimpleLTC | December 1, 2018

CMS Implements Stricter Nursing Home Staffing Survey Rules for States

“Previously, the State Operations Manual required states to conduct at least 10% of standard health surveys on the weekend or during off-hours. But for facilities on the list provided by CMS, states are now required to conduct at least 50% of the required off-hours surveys on weekends. ‘We’re notifying states of the 20% of facilities in the state with the lowest levels of staffing on the weekends,’ a CMS spokesperson explained. ‘That’s not saying that we think the lowest 20% of facilities in a state are the only facilities with low staffing issues, or that all of them have low staffing issues.'”

— Skilled Nursing News | November 30, 2018

CMS Strengthens Nursing Home Oversight and Safety to Ensure Adequate Staffing

“CMS will use frequently-updated payroll-based data to identify and provide state survey agencies with a list of nursing homes that have a significant drop in staffing levels on weekends, or that have several days in a quarter without a registered nurse onsite. State survey agencies will then be required to conduct surveys on some weekends based on this list. If surveyors identify insufficient nurse staffing levels, the facility will be cited for noncompliance and required to implement a plan of correction.”

— Centers for Medicare & Medicaid Services | November 30, 2018