PBJ Audits are a key part of the Staffing Five Star methodology going forward based on the details shared by CMS with State Survey Agency Directors on how they will use Payroll-Based Journal data for Staffing Five Star measures.
Download the full memo here.
Here's what to watch for in preparing your PBJ submissions so that when you are audited, your report can meet the demands of auditors.
Why are there PBJ audits?
Simply put, audits verify that your facility actually PAID for the work that you reported in your Payroll-Based Journal submission.
CMS is seeking to pinpoint the paid AND WORKED hours your facility paid employees and vendors to provide Direct Care to your residents as described in the PBJ Policy Manual.
As facilities convert their data into this uniform PBJ tally of hours, there are ways for more hours to get reported than were actually worked and paid. Audits have been seeking out and identifying these issues.
What things are commonly audited?
Every facility that's been audited has their own unique experience. What we detail below are the items CMS is currently looking for in audits - based on their communications and the experiences shared with us by facilities:
|Prove reported hours
|“Nursing homes whose audit identifies significant inaccuracies between the hours reported and the hours verified…will be presumed ot have low levels of staff. This will result in a one-star rating…”
|Audit manager and data checks
|Report PBJ by the deadline
|“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 rating…”
|Sender direct to CMS submission
|8 RN hours daily
|Fulfill “the requirement to have an RN onsite 8 hours a day, 7 days a week. Nursing homes reporting 7 or more days in a quarter with no RN hours will receive a one-star rating.”
|RN hours validation check
|While possible, it's unlikely you have staff working more than 80 hours per week or 300 hours in a month.
|Excessive hours check
|Exclude meal breaks
|“Meal times, paid or unpaid, shall not be reported for all staff. Facilities must deduct the time allotted for meals from each employee’s daily hours.”
|Set meal deductions from hours data
|Unique employee IDs
|“Facilities must not use the same ID to submit hours for multiple employees (exempt, nonexempt, or contract).”
ID validation and deduplication checks
Audit response required
|“Respond promptly to the audit contractor if contacted for an audit. Nursing homes will be contacted via email and certified mail sent to the administrator…If selected, the facility is required to upload supporting documentation by a date specified in the audit notification letter.”
Audit manager utility
Submit MDS assessments
|“Since each facility’s census is calculated using MDS data, it is critical that facilities adhere to the completion and transmission requirements.”