Our Take: CMS released PBJ Policy Manual Version 2.7 in June 2025. Updates include explicitly requiring that nursing hours be worked on-site to be included in PBJ, establishing a 22.5-hour daily maximum per person, and adding new audit and FAQ guidance. ▼
Facilities with hybrid or remote nursing roles, particularly RN MDS coordinators, must ensure that only on-site hours are submitted, as off-site hours are now explicitly excluded regardless of job function or administrative duties.
The 22.5-hour daily cap, mandatory meal break deduction rule, and three new PBJ audit FAQs require operators to review both their timekeeping workflows and their audit response procedures ahead of future submission deadlines.
PBJ Policy Manual v 2.7 – Jun 2025
“All nursing hours must be worked onsite to be reported in PBJ. Off-site hours are not reportable, even for nursing positions with administrative duties. All nursing staff must be available to provide direct care to residents, if required.”
Centers for Medicare and Medicaid Services. Electronic Staffing Data Submission Payroll-Based Journal Long-Term Care Facility Policy Manual Version 2.7. Centers for Medicare & Medicaid Services, 30 June 2025. https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/nursinghomequalityinits/downloads/pbj-policy-manual-final-v25-11-19-2018.pdf
New PBJ updates clarify tracking of remote workers — McKnight’s Long-Term Care News
“I’m not sure how many facilities may have misunderstood the original PBJ instructions, which state that ‘facilities must submit the number of hours each staff member is paid to deliver services for each day worked,” Amy Stewart, chief nursing officer for the American Association of Post-Acute Care Nursing told McKnight’s Long-Term Care News on Monday. “The updated language helps clarify that only nursing hours worked onsite should be reported in PBJ.”
— McKnight’s Long-Term Care News, July 07, 2025
CMS Publishes Updates to PBJ Manual and FAQs — AHCA/NCAL
Key updates include: Facilities are reminded to run their census reports and verify the accuracy of their resident census data prior to the submission deadline. No single individual can have more than 22.5 hours of work reported for any one day. The manual also clarifies that for nursing hours to be counted, work must be completed on-site. Three new FAQs were added regarding PBJ audits, including information on appeal reconsideration requests, triggers for a failed PBJ audit, and clarity on audit communications from CMS vs. audit contractors.
— AHCA/NCAL, July 01, 2025