PBJ audits and F-Tags

Published by CMS Policies & Rulemaking
Our Take: CMS uses PBJ data to flag facilities for audit and to set staffing star ratings, with RN hours and reporting accuracy serving as the primary pressure points. Understanding what CMS is measuring and how the data is used is the first step toward avoiding an F-Tag, suppressed rating or an audit response.▼

For skilled nursing operators, these three regulatory touchpoints – audit triggers, F727 RN coverage requirements, and F851 submission obligations – interact directly with Five Star staffing ratings and survey risk.  Facilities that see sharp increases in hours per resident day, fall short on RN coverage, or miss submission deadlines face measurable consequences on Nursing Home Compare.


PBJ Audits: Why Me?

When Nursing Hours Per Resident Day increased by 15% or more, this question was asked — including the calculation for that facility. We saw increases from about 15% to well over 30% in the audits, and the threshold may be lower than the 15% seen in our unscientific sample. When a facility’s Nursing Hours Per Resident Day was higher than the majority of facilities, the next question was asked. We only saw this question when the HPRD was over 6.0.

— SimpleLTC, October 22, 2019

Ftag of the Week – F727 RN 8 Hrs/7 Days/Wk, Full Time DON

Facilities that have more than 7 days per quarter where RN hours per this regulation are not met will receive a 1-star rating for staffing for that quarter. This includes facilities that have received an RN waiver. Even though these facilities do not have to have an RN on staff 8 hours a day / 7-days a week, they will be subject to the same rating methodology applied to facilities that have 7 or more days/quarter without RN staffing submitted to the PBJ system.

— CMS Compliance Group, April 13, 2018

Ftag of the Week – F851 Payroll Based Journal

Each facility is responsible for ensuring that complete and accurate direct care staffing data that is entered into the Payroll-Based Journal system is auditable and, as the name implies, verifiable through payroll, invoices and/or is tied back to a contract. If a provider misses two consecutive submission deadlines, its Overall star rating and Staffing star rating are suppressed until the data is received.

— CMS Compliance Group, September 21, 2017

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