PBJ Update: CMS Continues to Crack Down on Incorrect Submissions

The scrutiny that Centers for Medicare & Medicaid Services (CMS) faces with respect to facility Payroll-Based Journal (PBJ) reporting continues to evolve and senior care providers need to be aware of the importance of submitting timely and accurate data.

You will recall that after the first required submission period of Oct. 1 to Dec. 31, 2016, CMS added an icon to each facility’s information on Nursing Home Compare (located beside the facility name) to show whether a facility had electronically submitted the required PBJ staffing data. This icon is either green, indicating that the information was submitted, or now gray with a red slash, indicating that it was not:

In talking to providers during my travels, I have heard that CMS has begun performing pilot testing audits of PBJ data. According to these providers, a letter was sent to these facilities that reported an employee had worked more than 300 hours in a month during the Jan. 1 to March 30, 2017 period. Within the letter CMS mandated that the facility provide a copy of the employee’s time card(s) and an earnings statement to substantiate the hours submitted. CMS included the employees ID, Job Code and the number of hours the facility submitted on their PBJ report for reference.

The test-audited facilities are given two weeks to provide the required information and warned that failure to comply will result in a full audit and suppression of their Five-Star Quality Rating on the Nursing Home Compare website. 

It’s clear that CMS wants to ensure the accuracy of submitted PBJ data before they start using it as the system of record for computing Five-Star staffing ratings. CMS wants to be confident that facilities are taking the new requirements seriously and not overreporting hours worked. Therefore, it’s crucial that skilled nursing providers have systems and processes in place to ensure the accuracy of all future submissions.