The July 1, 2016, deadline is drawing near for mandatory Payroll-Based Journal (PBJ) data collection on daily staffing hours. Do you have your facts straight? A clear understanding of PBJ can help your organization successfully meet PBJ requirements and ensure an accurate Five-Star staffing rating.
The words and processes in PBJ are different from the Minimum Data Set (MDS) language. For instance, labor and job code definitions are two distinct categories. The labor category code is the designation of exempt or non-exempt employee (salary, contract, hourly). The job title code (JTC) designates the department/job function within the department under which the employee hours and day of the week get reported. For example, in the nursing department there are a total of nine job title codes: RN director of nursing, RN with administrative duties, RN, LPN/LVN with administrative duties, LPN/LVN, certified nurse’s aide, nurse aide in training, medication aide/technician, and clinical nurse specialist. All of these represent the nursing portion of the hours it takes to care for the facility residents.
Each interdisciplinary team member, including but not limited to the pharmacist and therapists, has a unique identification (ID) number created by your facility, which tracks hire date and termination date and to which the JTC is applied. The unique ID number never changes; however, the JTC can. If within one day a staff member assumes another’s job, such as the RN working as the certified nurse’s aide for four hours, the JTCs for those four hours would be reported as nurse aide, not as RN. However, the PBJ Manual is very clear about “primary role/duties.” If you are assigned to the dining room, wound rounds, or tidying up the unit after meals, you would not change your job title code, as this is typical practice and not taking up the majority of your time in your designated job.
Below are quick facts for practical application. This is by no means a comprehensive list; you must follow the rules in the PBJ Manual, as hours will eventually impact the facility staffing measure rating within the Five-Star report.
- FACT: PBJ is mandatory. The “go live” date for staffing data entry is July 1, 2016. The last day to enter staffing data is 45 CALENDAR days after the end of every quarter.
- FACT: The job title code (JTC) does matter: if your job title code is JTC 6, then, within the PBJ rules, you are considered to be an administrative nurse. The crosswalk for accuracy is to the CMS-671 form, completed during standard survey.
- FACT: The employee ID must be a unique identifier and not duplicated with any other current or previous staff member. If you are doing another job, such as working the floor, you will have another JTC with the same unique ID, hire date, and termination date.
- FACT: JTC 7 RN/JTC 9 LPN nursing hours could be for a nurse manager, NOT an MDS coordinator or a nurse in-service director; when these two roles are “working the floor,” the JTC is changed to RN/LPN nursing hours. (Below are definitions with JTC codes.)
- FACT: There are staffing hours that are NOT required to be reported, including housekeeping, laundry, kitchen staff, lab, X-ray, and others. Consider focusing on the staffing hours that are required, as you will be held accountable for hours that are reported through government audits.
- FACT: Dietitian and feeding assist staff hours are required, but kitchen staff hours are not.
- FACT: Physician hours count if the physician is a paid employee; if the physician bills Medicare for residents’ physical exams, do not record the hours. This rule also applies to nurse practitioners and physician assistants.
- FACT: You can submit a batch and/or manually enter data within the PBJ CASPER system.
- FACT: You can edit the data up to 45 days after the end of the quarter.
Below is a sample of job title codes, with definitions taken from chapter 2 of CMS’s Electronic Staffing Data Submission Payroll-Based Journal Long-Term Care Facility Policy Manual Version 2.1 (PBJ Manual):
Registered Nurse with Administrative Duties—No floor nurse, unit nurse manager, or DON
Nurses (RN) who, as either a facility employee or contractor, perform the Resident Assessment Instrument function in the facility and do not perform direct care functions. Also include other RNs whose principal duties are spent conducting administrative functions. For example, the Assistant Director of Nursing is conducting educational/in-service. Facilities with an RN waiver who do not have an RN as DON report all administrative nursing hours in this category.
Registered Nurse—No DON, MDS, or in-service
Those persons licensed to practice as registered nurses in the State where the facility is located. Includes geriatric nurse practitioners and clinical nurse specialists who primarily perform nursing, not physician-delegated tasks. Do not include Registered Nurses’ hours reported elsewhere.
Licensed Practical/Vocational Nurse with Administrative Duties
Those persons licensed to practice as licensed practical/vocational nurses in the State where the facility is located, and do not perform direct care functions. Also include other nurses whose principal duties are spent conducting administrative functions. For example, the LPN Charge Nurse is conducting educational/in-service, or other duties which are not considered to be direct care giving.
Licensed Practical/Vocational Nurse
Those persons licensed to practice as licensed practical/vocational nurses in the State where the facility is located. Do not include those hours of LPN/LVNs reported elsewhere.
Persons licensed/registered as occupational therapists according to State law in the State in which the facility is located. Include OTs who spend less than 50 percent of their time as activities therapists.
Occupational Therapy Assistant
Person(s) who, in accord with State law, have licenses/certification and specialized training to assist a licensed/certified/registered Occupational Therapist (OT) to carry out the OT's comprehensive plan of care, without the direct supervision of the therapist. Include OT Assistants who spend less than 50 percent of their time as Activities Therapists.
Occupational Therapy Aide
Person(s) who have specialized training to assist an OT to carry out the OT's comprehensive plan of care under the direct supervision of the therapist, in accord with State law.
Persons licensed/registered as physical therapists, according to State law where the facility is located.
Physical Therapy Assistant
Person(s) who, in accord with State law, have licenses/certification and specialized training to assist a licensed/certified/registered Physical Therapist (PT) to carry out the PT's comprehensive plan of care, without the direct supervision of the PT.
Physical Therapy Aide
Person(s) who have specialized training to assist a PT to carry out the PT's comprehensive plan of care under the direct supervision of the therapist, in accordance with State law.
Persons(s) who are licensed under state law (except in Alaska) as respiratory therapists.
Respiratory Therapy Technician
Person(s) who provide respiratory care under the direction of respiratory therapists and physicians
Persons licensed/registered, according to State law where the facility is located, to provide speech therapy and related services (e.g., teaching a resident to swallow).
Month End Census Date: There are four items related to your facility’s resident census that are recorded:
The number of residents in each payer code:
2. Medicaid: Number of residents whose primary payer is Medicaid
3. Medicare: Number of residents whose primary payer is Medicare
4. Other: Number of residents whose primary payer is neither Medicaid nor Medicare
A snapshot of facility census on the last day of every month can be either manually entered into the PBJ CASPER site or electronically uploaded.
The Payroll-Based Journal system will list the last date of each month for facility staff to enter the associated census. As with the staffing data (see chapter 1.2 of the PBJ Manual), the census information must be electronically uploaded or manually entered by the end of the 45th calendar day after the last day in each fiscal quarter in order to be considered timely.
Oct. 1 – Dec. 31
Jan. 1 – Mar. 31
Apr. 1 – Jun. 30
July 1 – Sept. 30
The deadline for the first required submission is November 14, 2016.
This overview of the PBJ should get you headed in the right direction for accuracy on reporting hours. Below are the CMS links and points of contact for the PBJ Manual, as well as frequently asked questions. Utilize the manual and the fast facts to assist you and your facility in correctly reporting the right job code title at the right time.
Questions regarding PBJ policy issues should be directed to:
Questions regarding the PBJ data specifications should be directed to:
Survey and Certification Memo S&C 16-13-NH:
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