The mandatory Payroll-Based Journal (PBJ) reporting requirement for skilled nursing facilities to collect and electronically submit direct care hours starts July 1, 2016. This presentation covers the ins and outs of the PBJ requirements and walk away with best practices to collect, review and submit the required information to CMS.

1. Payroll-Based Journal Reporting:
Strategies To Get Ready
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
• Gain an in-depth
understanding of the new
PBJ requirements
• Find out what hours to
count and what not to
count
• Learn what processes you
should implement today
to get ready

4. What is Payroll-Based Journal?
Payroll-Based Journal (PBJ) is a new system
used by CMS to electronically collect:
• Employee tenure information
• Direct care hours worked – including
agency and contractor hours
• Census data

5. PBJ Importance
• Failure to submit or
reporting inaccurate data
can be costly, potentially
leading to citation and civil
money penalties.
(condition of participation)
• Information used on
Nursing Home Compare
• Believed to be used in Five
Star Quality Ratings starting
in 2018

6. Staffing Data: Current vs PBJ Practices
Current Practices
Future 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
in place even after the July 1st PBJ start date

7. PBJ Data In Use
• Washington will begin
using PBJ information to
measure its 3.4 hours per
resident day requirement
– Beginning July 1st, 2016
– Done on a quarterly
basis
• Likely that other states
will follow suit

8. A Little History
Why Payroll-Based Journal?
Self-reporting accuracy questioned
• 2009: 38% received 4 or 5 star
rating, by 2014 increased to 54%
• Quality measure ratings
increased since transition to
MDS 3.0
• Trends have raised questions
about the validity of self
reported QM and staffing data
• NYT article “Medicare Star
Ratings Allow Nursing Homes to
Game the System” – 10/14

9. A Little History
• Payroll-Based Journal
– Section 6106 of the
Affordable Care Act
required skilled nursing
communities to
electronically submit
staffing data
– PBJ staffing reporting brings
consistency, transparency
and validation
– $11M in funding approved
in the IMPACT Act of 2014
“The use of payroll
based data will help
address the
misconception that
SNFs self-report higher
staffing levels.”
David Gifford, MD,MPH, Sr.
VP Quality & Regulatory

10. Countdown to July 1
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
Aug
2015
Oct 1
2015
Registration for
voluntary
submission
Voluntary
submission
started
PBJ mandatory
submission
begins
First mandatory
reporting
deadline
July 1
2016
Nov 14
2016

11. Starting Now: Getting Access
• Step 1:
– Go to www.qtso.com/accesspbj.html to register
– Use the CMSNet Online Registration application
to request a CMSNet User ID.
– The CMSNet ID is needed to access secure CMS
sites (e.g., submissions pages/reports) unless an
otherwise secure connection has been
established.

12. Starting Now: Getting Access
• Step 2:
– Use the QIES online User Registration tool to
obtain a QIES Submission ID.
– Once you have registered for a CMSNet User ID,
you will receive an email from
MDCN.mco@palmettogba.com containing your
login information. Using this information you will
connect through the 'CMS Secure Access
Service'.

13. What Needs To Be Submitted
• Tenure data
– Hire & termination
date
• Direct care hours
worked
– Per employee per day
• Census information
– last day of each month

14. Who Counts As 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. 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
12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker
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)

16. 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 36 Clinical Laboratory Service Worker
12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker
How will you
collect this
information?

17. 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

18. Frequently Asked Question
• Do I have to collect and submit this information for
non-facility, contract and agency direct care workers?
Yes. This information must be submitted for all workers providing care in
your community. For agency and contract workers:
• Hire date for contract staff is defined as the first day worked and billed
for at your community
• Termination date for contract staff is the last day your community or
the agency communicates that the contract individual will no longer be
providing services at your community.
• If you are unsure, do not fill in the termination date.

19. Starting Now: Collect Direct Care Worker Data
• Identify your system of record for company
employees
– Assign an Unique ID for each staff member
– Update information for current staff
• hire date, termination date, pay code status
– Implement a process for this data to be collected for
new hires
• Work with your agency and contract providers
– Request a list of active staff with the initial date each
employee worked in your community

20. Direct Care Staffing Hours
• Staffing hours data per direct care worker
– Work day and date
– Job title code
– Hours worked per day

21. Frequently Asked Question
• How should I report an employee’s hours where
their shift spans multiple days? For example a
Friday shift that begins at 11pm and ends
Saturday at 7am.
According to CMS, communities must allocate hours to the
actual days worked.
In this example, 1 hour should be reported for Friday and 7
hours should be reported for Saturday. Remember to account
for meal break as well on the applicable day.

22. What Hours Count, What Don’t
• Communities must submit the number of hours each staff member (including
agency and contract staff) is paid to deliver services for each day worked.
• CMS has highlighted instances when hours should not be included:
– Do not count hours paid for any type of leave or non-work related absence
from the facility, including paid meal breaks.
– Do not count any unpaid hours (e.g. overtime).
• For example, if a salaried employee works 10 hours but is only paid for 8 hours, only 8
hours should be submitted.
– Do not count hours for services performed that are billed to FFS Medicare or
other payer.
– Do not count hours providing services to residents in non-certified beds.
• For example, if nursing home staff is shared with an assisted living community, only those
hours dedicated to the residents of the nursing home should be reported .

23. Frequently Asked Question
• How are we expected to report for staff who
perform different roles throughout their day?
1. If the system of record (e.g. time clock) is able to account for time worked in
different positions, then yes, you can split the time.
Example:
• Employee XYZ clocks in at 7:00 a.m. in the job code of CNA.
• Clocks out at 11:00 a.m. Has a half hour meal break.
• Clocks back in at 11:30 a.m. in the job code of Activities Aide.
• Clocks out at 3:00 p.m.
• System would record on that date: Employee XYZ CNA 4 hours; Employee
XYZ Activities Aide 3.5 hours.

24. Frequently Asked Question – Different Roles
2. It is understood that most roles have a variety of non-primary duties that are
conducted throughout the day (e.g., helping out others when needed). In these
cases, reporting should be based on the employee’s primary role and their official
categorical title (for example, as indicated in a Human Resources system).
Example
A CNA who goes to help hand out meal trays over the meal period for a short
amount of time. You wouldn’t want to try to separate out and attribute that 30
min. or so to a dietary duty.
3. Universal workers are more problematic because they probably do many different
jobs during the day (e.g. CNA, Dietary, Housekeeping, Laundry, etc.) and the time
spent doing each position would need to be captured in the system of record for
audit purposes. This would be more administratively burdensome such that the
facility may just want to report the major function of that shift (e.g. CNA).

25. Frequently Asked Question
• How should facilities report hours for staff who are
attending training? For example, a CNA might work in the
morning for 4 hours with residents and then have 3 hours
of in-service training in the afternoon.
According to CMS, If the direct care staff (e.g. CNA) attending
training (either onsite or offsite) is not available to provide
resident care, the hours that the nurse is in training should not
be reported. If another staff member is called in to fill in for a
nurse that is away for training, the hours for the called-in
nurse should be submitted. However, the hours for the nurse
in training may not be submitted.

26. Frequently Asked Question
• If an exempt employee works as a floor nurse to
fill-in when an employee has called off, can I
report those hours?
This must be handled very carefully so as not to run the risk of
violating the employee’s exempt status under FLSA rules, but
yes there is a way to report these additional hours.

27. Starting Now: Map Job Title Codes
• Match your organization’s
unique job
codes/descriptions to the
37 CMS job title codes
– Classify all agency and
contract workers
• Determine a process for
collecting appropriate job
title code at the beginning
of each shift

28. Frequently Asked Question
• How do we report on hours that are not captured
in our time and attendance system (salaried &
corporate staff, therapy, contract)?
Data reported should be auditable and able to be verified
through either payroll, invoices, and/or tied back to a contract.
There is an expectation of accountability for services provided.
Facilities must use a reasonable methodology for calculating
and reporting the number of hours spent on site conducting
primary responsibilities, based on payments made for those
services.

29. Starting Now: Collect Hours
• Define your data collection process for:
– Hourly staff
– Contract workers
– Salaried staff
– Corporate staff
• For those not captured within a system investigate
what options are available to best fit your processes
• Contact the agency and contractor your organization
utilizes to determine if they are able to provide a
CMS ready report of those hours worked.

30. Starting Now: Focus On Daily Staffing Levels
• Benchmark staffing levels against
budget/Five Star Quality Rating
• Evaluate staffing requirements
every shift
– Allow for activity and manage like
an employee absence
• Gain visibility into staffing
– Alert management when
approaching staffing risk

31. Starting Now: Get Predictable & Flexible
• Adjust staff as needed
– Cancel shifts or call in staff as
needed
– Re-allocate staff to direct care
positions – be sure this is
documented
• Correlate labor staffed to
needs based on estimated
future census
• Keep overtime top of mind

32. 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.

33. Review PBJ Submission
• Set budgets per job code
– Identify information gaps
• Fill gaps by importing data or manual entry
• Share data with key stakeholders for review
• Make sure data is auditable

34. Submitting PBJ Data to CMS
• Manual data entry
• Upload an XML file
directly from an
automated system
• Combination of both

35. Frequently Asked Question
• With the file size limitation of 5 MB, are we going to
be able to upload multiple files for that same facility,
or are we going to have to break it down if it goes
over 5 MB?
CMS does allow you to upload your ZIP files as many times as
you would like throughout the collection and 45 day grace
period. Keep in mind that CMS requires an XML file format of
your data. In this format, 5 MB is quite large.

36. Payroll-Based Journal Challenges
Job codes and description
are unique to each
organization and don’t align
with CMS requirements
Don’t have a process to
collect contract, agency
and salaried direct care
hours worked at the
time care is provided
Collecting and reporting
staffing data is difficult
because required
information is stored in
different systems
Countless hours would
be spent submitting
data manually for each
worker
- Confidential -

37.  Meet PBJ staffing regulations
 Eliminate data gathering complexities
 Improve reporting accuracy with checks and balances
Payroll-Based Journal Reporting In 3 Easy Steps
Collect Review Submit
- Confidential -

38. PBJ Reporting Set-up
• Provide best practices and
guidance for implementing PBJ
processes
– Gain clarity on what direct care
hours are reportable
• Map internal job descriptions to
government (CMS) job codes
OnShift’s Customer Success Management consultation ensures
you are set up for PBJ success.
- Confidential -

39. Collect All Required Data
• Gather hourly staff from time & attendance
• Fill potential gaps, such as agency,
contractor (e.g. therapy providers) and/or
corporate employees
– Import staffing reports from outside vendors
– Utilize OnShift’s easy-to-use check-in app
– Schedule salaried staff that don’t punch-in
– Manually input hours when needed
• Automatically classify direct care hours
worked for proper reporting
OnShift simplifies the reporting process by gathering all required
CMS staffing information from different sources and systems.
- Confidential -

40. Review For Accuracy
• View direct care hours by job code
and labor description
• Add direct care hours prior to
submission
• Edit agency or contractor hours
OnShift provides a centralized view into staffing data and the
checks and balances needed for PBJ reporting accuracy.
- Confidential -

41. Submit With Ease
• Get submission-ready reports for
employees, hours worked and
census with the click of a button
OnShift streamlines the submission process with preformatted
exportable reports that meet government requirements.
- Confidential -

42. Interested In Getting Started?
• Simply answer Yes to the
poll question
• Email Ryan to set-up a
time to discuss in further
detail:
redgerly@onshift.com
Ryan Edgerly
Director of Account Management
OnShift
redgerly@onshift.com
- Confidential -