Understanding PBJ Reporting in Nursing Homes

In 2010, the CMS introduced Payroll-Based Journal (PJB) reporting as part of Section 6106 of the Affordable Care Act (ACA). PBJ reporting relies on tracking the hours worked by direct care staff in nursing homes, such as nurses, nursing assistants, therapists, and other frontline staff members who provide hands-on care to residents. 

PJB reporting has become mandatory, impacting nursing homes to report the required information to the CMS quarterly. PJB reporting is now required by law for nursing homes that receive Medicare or Medicaid reimbursement. The purpose is to allow the CMS to identify trends and patterns in incidents and accidents and to take corrective action to prevent future occurrences. 

What is PJB reporting?

At its core, PJB reporting requires nursing homes to submit staffing information to the CMS, ensuring they are adequately staffed to provide quality care. It is primarily aimed at expanding the availability of staffing data for analysis and comparison, making it easier for the CMS to track staffing, hours, and quality of care. 

Who uses payroll-based journal reporting?

Nursing homes and other types of long-term care facilities that receive Medicare or Medicaid funding, regardless of size and location, must submit PBJ reporting. PBJ journals must be submitted directly to the CMS, which compiles the data into their 

Five-Star Quality Rating System and publishes the results on the Medicare Nursing Home Compare website so that the public can view staffing levels and quality of care ratings. 

Why is PBJ reporting necessary?

There are several reasons why PBJ reporting is necessary:

• PBJ reporting ensures that nursing homes are adequately staffed, as staffing and turnover levels directly impact residents’ quality of care. The CMS publishes turnover measures on the Care Compare website so that the public can view and compare quality ratings, thus motivating nursing homes to implement innovative staff retention strategies. 
• PBJ reporting helps the CMS to calculate the staffing levels required for each nursing home. The CMS uses the information from PBJ reporting to determine the number of hours of care required for each resident in a nursing home. 
• PBJ reporting helps to prevent fraud and abuse by rewarding transparency in nursing homes. Nursing homes must maintain accurate records of their direct care staff’s hours worked and job titles. This information is subject to audit by the CMS to ensure that nursing homes comply with federal regulations and are not engaging in fraudulent activities. And the compiled data is accessible to the public, allowing residents and their families to decide where to receive care. 

Next, we will explore what information nursing homes and other long-term care facilities must submit to the CMS, the deadlines, and the penalties they face if they do not comply with PBJ reporting guidelines. 

PBJ Medicare Reporting: Nursing Home Deadlines and Penalties 

As mentioned above, payroll-based journal reporting is essential for nursing homes that receive funding from Medicare or Medicaid, as PBJ Medicare ensures transparency and accuracy in staffing information at nursing homes. So nursing homes that receive Medicare funding must comply with PBJ reporting requirements by submitting specific information on their staffing levels and hours worked by staff.

To comply with PBJ reporting requirements, nursing homes must submit the following information:

• Employee ID: The ID must be unique to each staff member and cannot be duplicated for other staff members, including current or previous employees. The employee ID should also not contain personally identifiable information, such as Social Security Number or name.
• The facility ID number (CMS certification number) and location
• Job role title and code: The job role specifies what hours of paid work are recorded for each member of staff allowed by the CMS. Job roles include registered nurses, licensed practical nurses, or certified nursing assistants.
• Pay type code (exempt, non-exempt, contract staff): This identifies the three types of pay classification a member of staff works during their shifts, according to the CMS guidelines.  
• Work days and dates: This records the associated work days and dates a staff member works, including the number of hours of paid work.
• Hours worked per day: The hours each staff member is paid to deliver daily services. These hours are then tallied into the total number of hours worked per quarter.
• Hire and termination date (optional)
• Census data (optional)

For more details on the required information for PBJ reporting, nursing homes can refer to the CMS’ Electronic Staffing Data Submission Payroll-Based Journal.  

When are the PBJ reporting deadlines?

The deadlines for PBJ reporting are critical, and nursing homes must ensure they meet them. The submission deadlines are as follows:

• Quarter 1 (January-March): May 15th
• Quarter 2 (April-June): August 14th
• Quarter 3 (July-September): November 14th
• Quarter 4 (October-December): February 14th

What are the penalties for submitting inaccurate or late PBJ reports?

In recent years, the CMS has initiated audits and imposed penalties on non-compliant facilities regarding their PBJ reporting. Still, the CMS is inclined to collaborate with facilities acting in good faith. In case of minor or unintentional mistakes following a CMS audit, the nursing home facility will be notified by the CMS and given support to rectify the discrepancies to prevent future reporting errors.

However, if there are statistically significant or multiple anomalies, the facility’s rating on the Nursing Home Compare website may be reduced, often resulting in an immediate reduction to a one-star rating in the staffing category for the entire quarter.

The CMS considers an instance significant enough to warrant penalties when “the difference between the submitted and verified hours is large enough to change a facility’s star rating or how the facility compares to its state average.” Meanwhile, facilities that do not submit their PBJ reports will be classed as non-compliant and subject to enforcement actions by the CMS. 

Contact us here to learn how our long-term care software can improve your PBJ reporting capabilities. 

5 PBJ Nursing Home Reporting Facility Types and Requirements

Due to PBJ nursing home reporting being a federal mandate, nursing homes and other long-term care facilities must submit specific staffing information to comply with the CMS’ regulations. As mentioned, the PBJ reporting program aims to provide accurate and transparent staffing data to the CMS to monitor and evaluate the quality of care provided to residents. 

This means that the staffing data submission payroll-based journal (PBJ) information must be accurate when submitted to the CMS. Furthermore, the information to be submitted will vary depending on the type of facility. Here we will discuss the different types of facilities that submit PBJ Medicare reporting and the requirements for each.

1. Skilled Nursing Facilities (SNFs)

Skilled Nursing Facilities, often referred to as “nursing homes,” provide 24-hour skilled nursing care to residents who require long-term medical care. SNFs must submit staffing information for registered nurses (RNs), licensed practical nurses (LPNs), and certified nursing assistants (CNAs). SNFs must also report the total hours worked by all other staff, including physical, occupational, and speech-language therapists.

2. Nursing Facilities (NFs)

Nursing Facilities provide similar care to SNFs but do not require a licensed nurse on staff 24 hours a day. Nursing facilities must submit staffing information for RNs, LPNs, and CNAs. They must also report the total hours worked by all other staff, including physical, occupational, and speech-language pathologists.

3. Assisted Living Facilities (ALFs)

Assisted Living Facilities provide housing and assistance with activities of daily living to residents who do not require 24-hour skilled nursing care. ALFs are not required to submit staffing information for PBJ reporting.

4. Hospice Inpatient Facilities (HIFs)

Hospice Inpatient Facilities provide short-term care to hospice patients who require symptom management and end-of-life care. HIFs must submit staffing information for RNs, LPNs, and CNAs. They must also report the total hours worked by all other staff, including social workers, chaplains, and bereavement counselors.

5. Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs/IID)

Intermediate Care Facilities provide specialized care to individuals with intellectual or developmental disabilities who require 24-hour care and supervision. ICFs/IID must submit staffing information for direct care staff, including RNs, LPNs, and CNAs.

As can be seen, facilities have varying PBJ reporting requirements that must be accurately reported to CMS via PBJ reporting. By submitting accurate staffing information, facilities can help ensure quality care for their residents and maintain their eligibility to receive funding from Medicare and Medicaid.

PBJ Reporting Guidelines: How to Ensure Compliance

Given the importance of submitting PBJ reporting accurately and on time, nursing homes and long-term care facilities should look into investing in long-term care software with a payroll-based module to avoid missing PBJ reporting deadlines. Doing so allows them to stay on top of legislation changes, comply with regulations, meet deadlines, and ensure they can track employee hours accurately and efficiently. 

Advanced payroll software will have specific features to improve the efficiency of tracking and organizing PBJ data, such as:

• Managing PBJ through an in-house payroll system as opposed to a third-party punch clock app, saving the facility time and money in investing in a third-party app
• Ability to import time or clocked-in hours from third-party vendors, so facilities do not need to move the data manually
• Automatically tracking daily hours into payroll
• Automated electronic submission of quarterly PBJ reporting instead of doing it manually

Providing accurate staffing data to the CMS for analysis makes it easier for residents and their families to compare long-term care options using transparent data. This, in turn, improves the quality of care and staff retention of nursing homes seeking to attract new residents and staff. 

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