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Payroll-Based Journal Reporting
Lessons Learned
Solving Everyday Workforce Challenges in
Post-Acute Care & Senior Living
Ryan Edgerly
Director of Account Management
OnShift
redgerly@onshift.com
Peter Corless
EVP of Enterprise Development
OnShift
pcorless@onshift.com
Introductions
- Confidential -
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
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
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
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
Additional PBJ Implications
• Tenure & Turnover
• Information on
Nursing Home
Compare
• Five Star Quality
Ratings
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
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
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
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
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).
CMS Job Title Codes & Descriptions
Labor
Category
Code
Labor Description
Job
Title
Code
Job Description
1 Administration
Services
1 Administrator
2 Physician Services 2 Medical Director
2 Physician Services 3 Other Physician
2 Physician Services 4 Physician Assistant
3 Nursing Services 5 Registered Nurse Director of Nursing
3 Nursing Services 6 Registered Nurse with
Administrative Duties
3 Nursing Services 7 Registered Nurse
3 Nursing Services 8 Licensed Practical/Vocational Nurse
with Administrative Duties
3 Nursing Services 9 Licensed Practical/Vocational Nurse
3 Nursing Services 10 Certified Nurse Aide
3 Nursing Services 11 Nurse Aide in Training
3 Nursing Services 12 Medication Aide/Technician
3 Nursing Services 13 Nurse Practitioner
3 Nursing Services 14 Clinical Nurse Specialist
4 Pharmacy Services 15 Pharmacist
5 Dietary Services 16 Dietitian
5 Dietary Services 17 Paid Feeding Assistant
6 Therapeutic Services 18 Occupational Therapist
6 Therapeutic Services 19 Occupational Therapy Assistant
6 Therapeutic Services 20 Occupational Therapy Aide
Labor
Category
Code
Labor Description
Job
Title
Code
Job Description
6 Therapeutic Services 21 Physical Therapist
6 Therapeutic Services 22 Physical Therapy Assistant
6 Therapeutic Services 23 Physical Therapy Aide
6 Therapeutic Services 24 Respiratory Therapist
6 Therapeutic Services 25 Respiratory Therapy Technician
6 Therapeutic Services 26 Speech/Language Pathologist
6 Therapeutic Services 27 Therapeutic Recreation Specialist
6 Therapeutic Services 28 Qualified Activities Professional
6 Therapeutic Services 29 Other Activities Staff
6 Therapeutic Services 30 Qualified Social Worker
6 Therapeutic Services 31 Other Social Worker
7 Dental Services 32 Dentist
8 Podiatry Services 33 Podiatrist
9 Mental Health Services 34 Mental Health Service Worker
10 Vocational Services 35 Vocational Service Worker
11 Clinical Laboratory Services 36 Clinical Laboratory Service Worker
(OPTIONAL)
12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker
(OPTIONAL)
13 Administration & Storage of
Blood Services
38 Blood Service Worker (OPTIONAL)
14 Housekeeping Services 39 Housekeeping Service Worker
(OPTIONAL)
15 Other Services 40 Other Service Worker (OPTIONAL)
Non-Facility Direct Care Workers
Labor Category
Code
Labor Description Job Title Code Job Description
2 Physician Services 2 Medical Director
2 Physician Services 3 Other Physician
2 Physician Services 4 Physician Assistant
4 Pharmacy Services 15 Pharmacist
5 Dietary Services 16 Dietitian
6 Therapeutic Services 18 Occupational Therapist
6 Therapeutic Services 19 Occupational Therapy Assistant
6 Therapeutic Services 20 Occupational Therapy Aide
6 Therapeutic Services 21 Physical Therapist
6 Therapeutic Services 22 Physical Therapy Assistant
6 Therapeutic Services 23 Physical Therapy Aide
6 Therapeutic Services 24 Respiratory Therapist
6 Therapeutic Services 25 Respiratory Therapy Technician
6 Therapeutic Services 26 Speech/Language Pathologist
6 Therapeutic Services 27 Therapeutic Recreation Specialist
6 Therapeutic Services 28 Qualified Activities Professional
7 Dental Services 32 Dentist
8 Podiatry Services 33 Podiatrist
9 Mental Health Services 34 Mental Health Service Worker
10 Vocational Services 35 Vocational Service Worker
11 Clinical Laboratory Services
12 Diagnostic X-ray Services
How will you
collect this
information?
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
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.
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
Direct Care Staffing Hours
• Staffing hours data per direct care worker
– Work day and date
– Job title code
– Hours worked per day
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.
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
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
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
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?
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
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.
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
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
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
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
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
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
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
&
Special Pricing for LeadingAge Members!
Payroll-Based Journal Reporting In 3 Easy Steps
Collect Review Submit
- Confidential -
Q
A
&
Learn More About Our Partnership
Get PBJ-Ready!
• Download presentation
slides
• Request a
demonstration
• Visit:
www.OnShift.com/leadingage-webinar

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Payroll-Based Journal Reporting Lessons Learned

  • 1. Payroll-Based Journal Reporting Lessons Learned Solving Everyday Workforce Challenges in Post-Acute Care & Senior Living
  • 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
  • 7. Additional PBJ Implications • Tenure & Turnover • Information on Nursing Home Compare • Five Star Quality Ratings
  • 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).
  • 13. CMS Job Title Codes & Descriptions Labor Category Code Labor Description Job Title Code Job Description 1 Administration Services 1 Administrator 2 Physician Services 2 Medical Director 2 Physician Services 3 Other Physician 2 Physician Services 4 Physician Assistant 3 Nursing Services 5 Registered Nurse Director of Nursing 3 Nursing Services 6 Registered Nurse with Administrative Duties 3 Nursing Services 7 Registered Nurse 3 Nursing Services 8 Licensed Practical/Vocational Nurse with Administrative Duties 3 Nursing Services 9 Licensed Practical/Vocational Nurse 3 Nursing Services 10 Certified Nurse Aide 3 Nursing Services 11 Nurse Aide in Training 3 Nursing Services 12 Medication Aide/Technician 3 Nursing Services 13 Nurse Practitioner 3 Nursing Services 14 Clinical Nurse Specialist 4 Pharmacy Services 15 Pharmacist 5 Dietary Services 16 Dietitian 5 Dietary Services 17 Paid Feeding Assistant 6 Therapeutic Services 18 Occupational Therapist 6 Therapeutic Services 19 Occupational Therapy Assistant 6 Therapeutic Services 20 Occupational Therapy Aide Labor Category Code Labor Description Job Title Code Job Description 6 Therapeutic Services 21 Physical Therapist 6 Therapeutic Services 22 Physical Therapy Assistant 6 Therapeutic Services 23 Physical Therapy Aide 6 Therapeutic Services 24 Respiratory Therapist 6 Therapeutic Services 25 Respiratory Therapy Technician 6 Therapeutic Services 26 Speech/Language Pathologist 6 Therapeutic Services 27 Therapeutic Recreation Specialist 6 Therapeutic Services 28 Qualified Activities Professional 6 Therapeutic Services 29 Other Activities Staff 6 Therapeutic Services 30 Qualified Social Worker 6 Therapeutic Services 31 Other Social Worker 7 Dental Services 32 Dentist 8 Podiatry Services 33 Podiatrist 9 Mental Health Services 34 Mental Health Service Worker 10 Vocational Services 35 Vocational Service Worker 11 Clinical Laboratory Services 36 Clinical Laboratory Service Worker (OPTIONAL) 12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker (OPTIONAL) 13 Administration & Storage of Blood Services 38 Blood Service Worker (OPTIONAL) 14 Housekeeping Services 39 Housekeeping Service Worker (OPTIONAL) 15 Other Services 40 Other Service Worker (OPTIONAL)
  • 14. Non-Facility Direct Care Workers Labor Category Code Labor Description Job Title Code Job Description 2 Physician Services 2 Medical Director 2 Physician Services 3 Other Physician 2 Physician Services 4 Physician Assistant 4 Pharmacy Services 15 Pharmacist 5 Dietary Services 16 Dietitian 6 Therapeutic Services 18 Occupational Therapist 6 Therapeutic Services 19 Occupational Therapy Assistant 6 Therapeutic Services 20 Occupational Therapy Aide 6 Therapeutic Services 21 Physical Therapist 6 Therapeutic Services 22 Physical Therapy Assistant 6 Therapeutic Services 23 Physical Therapy Aide 6 Therapeutic Services 24 Respiratory Therapist 6 Therapeutic Services 25 Respiratory Therapy Technician 6 Therapeutic Services 26 Speech/Language Pathologist 6 Therapeutic Services 27 Therapeutic Recreation Specialist 6 Therapeutic Services 28 Qualified Activities Professional 7 Dental Services 32 Dentist 8 Podiatry Services 33 Podiatrist 9 Mental Health Services 34 Mental Health Service Worker 10 Vocational Services 35 Vocational Service Worker 11 Clinical Laboratory Services 12 Diagnostic X-ray Services How will you collect this information?
  • 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 -
  • 34. Q A &
  • 35. Learn More About Our Partnership Get PBJ-Ready! • Download presentation slides • Request a demonstration • Visit: www.OnShift.com/leadingage-webinar