In its recent letter to State Survey directors, CMS announced an increased focus on nurse staffing levels and sharing of Payroll-Based Journal (PBJ) data with state survey agencies. States will be notified of underperforming facilities, for issues including:
- Facilities with “low” nurse staffing on weekends
- Facilities showing days without an on-site RN (possible deficiency F-tag 727)
CMS plans to send out the list of facilities to states sometime in December. In a recent article explaining the changes, Don Feige, CEO of ezPBJ, stated, “It’s going to become even more imperative that they’ve got their information and their back-end systems up to reflect what’s going on in the building.”
Other PBJ updates
CMS also updated its policy manual and FAQs with further clarification on removing meal breaks and reportable hours for universal care workers. Going forward, ALWAYS remove 30 minutes for lunch in your PBJ reports. Even when your staff works through lunch, those 30 minutes cannot be reported.
The policy manual includes updates to job descriptions for roles such as administrators and medical directors, which may correct errors SNFs made in the past misreporting who serves in those roles.
“To me, they’re clarifying the definitions because they’ve seen people not consistently reporting those roles,” Feige said. “There are very specific rules around those roles. This is probably their first step toward that next wave of: ‘Let’s get data for these things.’”
The key takeaway?
Your PBJ data is more scrutinized than ever — and you could be self-reporting your own F-tag violation! Auditors are looking for over-reporting of nursing hours and meal breaks, while the States will now be looking for issues with weekend and low nurse staffing levels.
You should always self-audit your PBJ reports before submitting them to CMS.
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