It is critical that all skilled nursing providers are aware of these change and read CMS' new Payroll-Based Journal Technical Guide. Here are the details:
Beginning in April 2018, CMS will utilize PBJ data to calculate the staffing measure rating for the Five-Star Quality Rating System, which will be posted on Nursing Home Compare on the last week of the 2nd month following submission deadline.
CMS will utilize calendar Q4 2017 data within PBJ report submissions and publish four measures on Nursing Home Compare, including:
Calculating Five-Star Staffing Rating
The HPPD measures for nursing staff, RNs and physical therapists will be calculated by summing the number of hours for the relevant job categories submitted for each day of the quarter, and then dividing by the sum of each day's census within the same quarter. Resident census is now derived from the facility MDS submissions and not the previously required census on the last day of the month.* The staffing measure rating is calculated by adjusting the HPPD based on the expected level of staff needed given the number and acuity of the residents in the facility.
*Note: Submitting timely and accurate MDS discharge assessments is key to having an accurately reported census. The CMS algorithm for calculating census will assume that a resident with a missing discharge assessment stayed in the facility 150 days after the last non-discharge assessment, which may lead to many centers having artificially inflated census numbers, lowering HPPD.
Switching To RUG-66 Staffing Risk Adjustment
The HPPD measures used in Five-Star ratings will continue to be risk adjusted to account for differences across facilities' resident acuity. CMS will move to using RUG-66 from RUG-53 to calculate the adjusted staffing levels. The new cut points are below.
Significant Inaccuracies And/Or Failure To Submit PBJ Data
Providers whose audits show significant inaccuracies between hours reported and verified or those who fail to submit data by the PBJ reporting deadlines will have a one-star rating on the staffing domain, which will result in a drop by one star in their overall Five-Star rating.
Through their contractors, CMS started conducting audits of facilities where issues were identified, such as an employee working more than 300 hours in a month, etc. Based on the audits that CMS has conducted, the following five items were identified as common errors found.
**Note: Providers who give their employees a paid meal break and then include those hours in their PBJ submission because they expect employees to ‘work’ during a compensated meal break are being flagged as non-compliant.
Reporting Zero RN Hours For Seven Or More Days In A Quarter
Similarly, those facilities that report seven or more days in a quarter with no RN hours will have a one-star rating on the staffing domain, which will result in a drop by one star in their overall Five-Star rating. This enforcement will start in July 2018, after the May 15, 2018 submission deadline for the first calendar quarter of 2018.
Prior to the July date, facilities that report seven or more days in a quarter with no RN hours will have an icon placed next to their name on Nursing Home Compare.
Why Staffing Ratings Show As 'Not Available' On Nursing Home Compare
Some providers may see 'Not Available' for the reported staffing hours. There are six reasons a staffing rating will not be calculated:
Form-671 Discontinued Starting June 2018
Starting on June 1, CMS will stop requiring providers complete the staffing portion (page 2) of CMS Form-671.
Turnover Reporting On CMS’ Radar
CMS continues to say that at a future date they will start to report turnover and retention percentages. The details and specific timing are yet to be determined.
OnShift will continue to work with CMS and state and national provider associations to keep you apprised of PBJ developments as they occur. Our goal is to assist you in any way that we can and make this transition as easy as possible.