Gotchas to watch for in PBJ audits

Mar 30, 2018 | PBJ Audits by CMS

Gotchas to watch for in PBJ Audits

Audits of PBJ data were introduced in the shift to PBJ from the prior staffing data collection method.  With triggered or random audits, CMS verifies reported data is consistent with payroll records and have higher confidence in PBJ accuracy. 


Gotchas to watch for in PBJ audits

PBJ Audits are a key part of the Staffing Five Star methodology going forward based on the details shared by CMS with State Survey Agency Directors on how they will use Payroll-Based Journal data for Staffing Five Star measures.

Here’s what to watch for in preparing your PBJ submissions so that when you are audited, your report can meet the demands of auditors.


“Gotchas to Watch for in PBJ Audits.” SimpleLTC, 4 May 2018,


Preliminary Testing Audits of PBJ Data

The Centers for Medicare & Medicaid Services (CMS) has begun a pilot testing program to audit Payroll-Based Journal (PBJ) data.

Granite Dolphin and Myers and Stauffer audit teams are focused on examining payroll records and other auditable data to identify if staffing is accurately reported based on paid hours. As such, information requested may include information from payroll, timekeeping systems, invoices or contracts for contracted staff and interviews with staff responsible for PBJ data entry and submission.

The audits may take place on or off site.


“Preliminary Testing Audits of PBJ Data.” FORVIS, 22 June 2017,


CMS to conduct pilot audit process for PBJ

CMS has announced in a letter addressed to skilled nursing facility administration that their PBJ staffing audit team will begin conducting audits of PBJ data submitted to CMS.

The letter states that the PBJ audit team will examine payroll records and other auditable data along with PBJ submission data to identify if staffing is being reported accurately based on hours staff are paid to work.

Hurlburt, Amanda. “CMS to Conduct Pilot Audit Process for PBJ.” The Post-Acute Advisor, 15 June 2017. No longer available.

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

QSO Memo 17-25-NH

CMS Payroll-Based Journal (PBJ) Policy Manual

PBJ Policy Manual

FAQs for PBJ Policy Manual

PBJ Policy FAQs