2. Ryan Edgerly
Director of Account Management
OnShift
redgerly@onshift.com
Peter Corless
EVP of Enterprise Development
OnShift
pcorless@onshift.com
Introductions
- Confidential -
3. Today’s Agenda
• Review the new Payroll-
Based Journal
requirements
• Get answers to frequently
asked questions
• Learn about LeadingAge &
OnShift’s PBJ partnership
• View OnShift’s Payroll-
Based Reporting software
4. What is Payroll-Based Journal?
Payroll-Based Journal (PBJ) is a new system
used by CMS to electronically collect:
• Employee tenure information
• Census data
• Direct care hours worked – including
agency and contractor hours
5. Importance of PBJ Information
Failure to submit or reporting
inaccurate data can be costly,
potentially leading to citation and
civil money penalties.
Requirement of Participation
6. Accuracy is Critical
• Inaccurate reporting could
have several side effects
• Enforcement action down
the road
– Potential to use inaccurate
data in civil liability cases
– Inaccurate data used to
justify regulatory action
– Potential use within fraud
and abuse situations - from
false claims to anti-kickback
8. Collection Has Begun
Fiscal
Quarter
Date Range for
Staffing Data
Submission
Deadline
1
October 1 –
December 31
February 14
2
January 1 –
March 31
May 15
3
April 1 –
June 30
August 14
4
July 1 –
September 30
November 14
9. Submitting PBJ Data to CMS
• Manual data entry
• Upload an XML file
directly from an
automated system
• Combination of both
NOTE: The file version changed June 26, 2016 to version 2 for upload
10. Lessons Learned: Uploading Reports To CMS
• Merge
– Staffing data: If data exists for a specific
day/employee ID/job title combination, it will be
overwritten
• Otherwise the data for that day is simply added
– Census data: If data exists for a specific month end
date, it will be overwritten
• Otherwise the data for that day is simply added.
• Replace
– All data for that specific section (census or
staffing) for the specified quarter will be removed
from the active database and then replaced with
the data submitted in the file.
• Confirm successful submission through CASPER’s
Validation Report
11. Staffing Data: Current vs PBJ Practices
Current Practices
Payroll-Based Journal
Practices
Reported annually during survey
Reported electronically on a
quarterly basis
Reported using Forms 671/672
Reported using the Payroll-Based
Journal QIES system
Report staff hours for the most
recent complete pay period or 14
days prior to survey
Accounts for all direct care hours –
including contractor and agency –
for each day of the year
Includes employee tenure
information
Note: Current staffing reporting practices will still remain
12. Defining Direct Care
CMS defines direct care staff as those individuals who,
through interpersonal contact with residents or
resident care management, provide care and services
to allow residents to attain or maintain the highest
practicable physical, mental, and psychosocial well-
being.
Direct care does not include individuals whose primary
duty is maintaining the physical environment of the
long-term care facility (for example, housekeeping).
15. Required Direct Care Worker Data
• Unique ID
– Must be unique and not
duplicated
– Should not include personally
identifiable info (name or SSN)
• Hire date
• Termination date
• Pay type code
– Non-exempt – entitled to
overtime pay
– Exempt – not entitled to
overtime pay
– Contract – individuals under
contract or those that provide
services through organizations
under contract
16. Required Census Data
• PBJ requires that census
information be provided for
the last day of each month.
– Medicaid
• Number of residents whose
primary payer is Medicaid
– Medicare
• Number of residents whose
primary payer is Medicare
– Other
• Number of residents whose
primary payer is neither
Medicaid nor Medicare
Associations have
objected to only
submitting census data
for the last day of each
month. They view it as
misrepresentative and
unreliable in depicting
the hours of direct care
provided per resident
per day.
17. Lessons Learned: Sometimes …
• Medicare Medicare
– Medicare Advantage (Part C) should be reported
as Other
• Medicaid Medicaid
– Medicaid Managed Care should be reported as
Other
– Medicaid Pending should be reported as Other
18. Direct Care Staffing Hours
• Staffing hours data per direct care worker
– Work day and date
– Job title code
– Hours worked per day
19. Hours To Count
• Communities must submit
the number of hours each
staff member is paid to
deliver services for each day
worked.
• Don’t forget to include
agency and contract staff.
20. Hours Not To Count
• Unpaid time worked
• If a salaried employee works 10 hours
but is only paid for 8 hours, only 8
hours should be submitted.
• Hours paid for any type of leave or
non-work related absence from the
facility, including paid meal breaks
• Hours for services performed that
are billed to FFS Medicare or other
payer
• Hours providing services to
residents in non-certified beds
21. FAQ: Allocating Shift Hours That Span Two Days
• How should I report an
employee’s hours where
their shift spans multiple
days?
– Communities must report
hours to the actual days
worked.
• Example: 11pm-7am shift
– 1 hour reported first day
– 7 hours reported next day
Issue is most systems are not set-up to automatically report in
accordance to these requirements
22. Lessons Learned: Addressing the Day Divide
What providers are doing
• Change shifts to start at
midnight
• Manually adjust and enter
to meet regulations
• Contract with vendors
that can automatically
allocate these hours
23. FAQ: Workers That Perform Different Roles
• How are we expected to report for
staff who perform different roles
throughout their day?
– Utilize time & attendance systems
to account for time worked in
different positions.
• This is a good practice if shift
responsibilities are split
– Otherwise report on the worker’s
primary role
• It is understood that most roles
have a variety of non-primary
duties that are conducted
throughout the day
– What about universal workers?
24. FAQ: Submitting Training Hours
• How should facilities
report hours for staff
who are attending
training?
– Hours should not be
reported if employee is
not providing resident
care
– Caregiving staff called
in to replace those in
training should have
hours submitted
25. FAQ: Exempt Staff Working Above & Beyond
• If an exempt employee
works as a floor nurse to
fill in when an employee
has called off, can I
report those hours?
– You can report these
hours – but do so
carefully so that it
doesn’t violate their
exempt status under
FLSA rules.
26. FAQ: Reporting Re-hires
• How do we submit hours
for an employee who was
terminated and then re-
hired at our facility?
– CMS only allows for one
hire and one termination
field per submission
– This creates errors or lost
data if those staff are
part of the same
submission
– CMS is aware of this issue
27. Lessons Learned: Reporting Boomerang Staff
What providers are doing
• Submit separate files
for rehired staff
• Submit PBJ reports
more frequently to
reduce odds of rehires
overriding
28. FAQ: Tenure Data For Contractors
Do I have to collect and submit hire &
termination date for non-facility, contract
and agency direct care workers?
• Yes!
– Hire date
• First day worked and billed for at your
community
– Termination date
• Last day your community or the
agency communicates that the
contract individual will no longer be
providing services at your community.
• If unsure leave blank
29. FAQ: Collecting Hours Non-Punched Hours
How do we report hours not captured
in time & attendance system?
(salaried & corporate staff, contract)
• Facilities must use a reasonable
methodology for calculating and
reporting the hours spent
conducting primary
responsibilities
• Data must be reported and
auditable
– Payroll, invoices, and/or tied back
to a contract
– First day worked and billed for at
your community
30. Lessons Learned: Collecting Outside Hours
What providers are doing
• Contact agency &
contractors to provide
this data for upload
• Manually collect and
enter into CMS
• Utilize systems to allow
these caregivers to
easily check in and
check out
31. Utilize Technology
• Too many moving
parts with information
in multiple systems to
do this all manually
• Software can provide
the help you need to
get PBJ reporting right
32. LeadingAge & OnShift Partner For PBJ
• OnShift is the leader in
labor management
software for long-term
care
• LeadingAge partnered
with OnShift because of
OnShift’s proven solution
and focus on aging
services
&
33. Special Pricing for LeadingAge Members!
Payroll-Based Journal Reporting In 3 Easy Steps
Collect Review Submit
- Confidential -
35. Learn More About Our Partnership
Get PBJ-Ready!
• Download presentation
slides
• Request a
demonstration
• Visit:
www.OnShift.com/leadingage-webinar