CMS Requires Payroll-Based Journal, Electronic Staffing Data Submission for Skilled Nursing Facilities, Effective July 1, 2016

Effective July 1, 2016, skilled nursing facilities (SNFs) will be required to submit staffing, time and attendance information electronically to the Centers for Medicaid and Medicare Services (CMS) via their Payroll-Based Journal (PBJ) system.   These requirements originate from section 6106 of the Patient Protection and Affordable Care Act (PPACA), and the final rule requires facilities to submit direct care staffing information, in a uniform and auditable format, at least quarterly.  Early implementation is allowed; the CMS has been accepting electronic PBJ submissions since October 2015.
The CMS reports that it will use the direct care staffing information to gauge its impact on care in nursing homes.  They also plan to use it in the Nursing Home Five Star Quality Rating System to help consumers understand the level and differences of staffing in nursing homes.
General Requirements of CMS Staffing Data Submission PBJ
AAFCPAs would like to point out that the reporting requirements are significant, may present challenging factors for facilities, and will likely create a significant administrative burden for many SNFs. We have summarized the following general requirements for your convenience.

• Electronic submission of direct care staffing information, including: category of work a certified employee performs (RN, LPN, licensed vocational nurse, CNA, therapist or other medical personnel), hours compensated per employee by day, and dates of hire / termination of employees.
• The submission must include contracted direct care staff. The reporting requirements for contracted staff are the same as those for employees; however the SNF must distinguish between contracted direct care providers and employees.
• SNF’s must submit resident census data monthly, by payor (Medicaid, Medicare or other), on a snap short basis at the end of each month.
• The data submitted must be auditable. Which means it must be based on payroll reports/journal, invoices and contracts, and other verifiable data, in a uniform format.
• The payroll/contractor time, attendance and compensation data may be submitted electronically, or manually entered into CMS’ online system. The submission of the data electronically requires the SNF to import/upload an XML file in a specified format.
• The PBJ submissions are due within 45 days after the end of a calendar quarter. SNFs can submit this data on the frequency of their choosing (monthly, bi-weekly, etc.); however it must be done at least quarterly.

Many of the PBJ requirements involve evaluating and changing internal controls, processes and reporting over your organization’s payroll cycle.  AAFCPAs advises that SNFs start preparing now to ensure compliance.
We have provided a summary of the key considerations and guidance when implementing the CMS’ Payroll-Based Journal reporting requirements.  Click here to download the CMS/PBJ Key Considerations and Guidance>>

If you have any questions about implementing the payroll-based journal (PBJ) requirements, please contact your AAFCPA partner, or Charlie Webb, CPA at 774.512.4046, cwebb@nullaafcpa.com.