CMS has announced three changes it is making to this quarter’s Payroll-Based Journal (PBJ) submissions in response to some perceived difficulties that long-term care (LTC) providers had during past periods. They hope that these changes will make it easier for them to submit their data with improved accuracy.
Turnover Is Still Being Tracked
Some LTC providers had trouble submitting hire, termination and re-hire dates for employees. As a result, CMS has now made it optional to submit hire and termination dates. Although no longer mandatory, providers can still submit this information and OnShift is compliant with these changes.
CMS previously stated that a benefit of electronically collecting this information through the PBJ system is that it would facilitate reporting a long-term care facility’s turnover and employee retention outcomes. The thinking is that knowing these outcomes would be important for consumers and other stakeholders (e.g. MCOs, ACOs, hospitals, etc.) when determining which Skilled Nursing Facility to seek placement in or contract with, and would therefore incentivize facilities to improve staff retention. By making the submission of hire and termination dates voluntary, LTC providers may think that CMS does not intend to report these statistics anytime soon. However, that is not the case.
CMS has indicated that it intends to determine these statistics by “using the actual hours worked by staff each day.” They have not stated which methodology will be used, but one approach might be to infer that an employee has termed if they have no hours reported for 13 or more weeks. I’m guessing the time frame of 13 weeks may be chosen since FMLA leave is limited to 12 weeks and CMS is not collecting ‘leave status’ in the information that providers are required to report.
CMS has also not outlined how employee turnover and retention will be calculated and reported. Will it be by position? Will it include contractors? Will it be total facility only? It will be interesting to see just how all of this shakes out, but CMS had indicated that it remains committed to reporting turnover and retention information, so providers must stay focused on improving outcomes in this area.
Along those lines, CMS strongly encourages providers to work with contractors such as payroll and timekeeping vendors to maintain the same employee IDs for continuity’s sake.
Suppressed Star Ratings for Failure to Submit
CMS is also changing how it reports facility compliance via PBJ submissions on the Nursing Home Compare website. You’ll recall that after the first required submission, CMS added an icon to each facility’s information (located beside the facility name) to show whether a facility has electronically submitted the required PBJ staffing data. This icon is either green, indicating that the information was submitted, or gray, indicating that it was not:
After the next required submission date of May 15, 2017, nursing homes that have not submitted data for this period and the period prior will have their overall and staffing star ratings suppressed from the Nursing Home Compare website. This means that consumers and other interested parties will not have this information available when considering placement in your facility, and depending on how CMS explains the omission, may know that your facility is not complying with the requirement to submit this data.
New Voluntary Submissions
It is now optional to submit information on three previously required positions: dentists, podiatrists and vocational service workers (CMS job title codes 32, 33 & 35, respectively). These are in addition to the five job codes that CMS previously made voluntary and brings the total number of job codes that providers are required to report down to 32 from 40.There is a lot to digest here, but long-term care providers need to pay attention to these Payroll-Based Journal requirements during all future submissions. OnShift is here to make sure that not only are you in compliance, but that you have the information that you need to obtain and report great outcomes.