CMS shared details with State Survey Agency Directors on how they will use Payroll-Based Journal data for Staffing Five Star measures. Download the full memo or read on for our summary.

There’s much to unpack in this detailed memo. ezPBJ has summarized the key points of interest below.

How the CMS Staffing Five-Star rating is calculated

On May 1, 2018 CMS will update the Technical Users Guide with the specifics, but they shared these key points on how the Staffing Five-Star will be calculated:

• The first PBJ Five Star will use one quarter’s worth of data: the Oct. 1 to Dec. 31 2017 PBJ report submitted by Feb. 14, 2018.
• Every Staffing Five-Star rating is adjusted based on the expected level of staff needed given the number and acuity of residents. This adjustment will change from using RUG-III based expectations to RUG-IV based expectations.
• The Staffing Rating will continue to be calculated by combining a Total Nurse rating (based on RN, LPN and nurse aides) with an RN rating.
• New Ratings thresholds (cut-points) will be created based on the existing distribution of ratings among nursing homes. In other words, the number of nursing homes in each category will be approximately the same.
• The 671 (for staffing data collection) will go away as of June 1, 2018. Woo-hoo!
• In the future CMS plans to roll out additional Staffing measures like staff turnover and post them to Nursing Home Compare.

How to get a one-star Staffing rating

For the past two years, CMS focused on getting facilities to submit PBJ data quarterly, on time before the deadline. Lack of compliance was indicated with notes and designations on the Nursing Home Compare website.

Going forward, CMS says:

“Nursing homes whose audit identifies significant inaccuracies between the hours reported and the hours verified, or facilities who fail to submit any data by the required deadline will be presumed to have low levels of staff.

This will result in a one-star (staffing) rating…(and) will drop their overall (composite) star rating by one star for a quarter.”

To break that down, here are ways your facility will receive a one star rating (for that quarter):

• You fail to submit your report by the PBJ deadline  Note:  we have not seen any exceptions to this strict deadline. The dog CANNOT eat your homework!
• Your submission does not stand up on audit. CMS auditors are validating that your facility PAID for the hours you reported and that you can prove with payroll records and vendor documentation. Significant gaps in reported vs. validated that would change your Star rating or how you compare to the State average could trigger a One-Star rating for that quarter
• You fail to respond to an Audit request, or failure to submit proof requested in an audit
• You report 7 or more days in a quarter with no RN hours. This starts in July 2018 based on the May PBJ submission.  CMS will allow waivers to this requirement.

That last bullet is a new warning. Having 8 RN hours daily also triggers F-Tag 727 unless waived for your facility. So this rule can affect both your survey AND your staffing rating.

Per CMS, 6% of facilities reporting otherwise complete PBJ data had 7 or more days where no hours for RNs were reported.

Steps to take

Ask ezPBJ how to pre-audit your PBJ data in our validation tools for the issues described above. If you are not a customer, get a Free Trial to check your PBJ submissions.  Give ezPBJ a call at (585) 210-9780 or send us an email to talk through your concerns.