Managing staff roles, credentials and hours through the Payroll-based Journal (PBJ) system is more important than ever for providers who are watching their stars on Nursing Home Compare.
The Centers for Medicare & Medicaid Services (CMS) released several modifications to the staffing section of the Design for Nursing Home Compare Five-Star Quality Rating System: Technical Users’ Guide(1) in spring 2018, including new Five-Star penalties for missing staffing data and insufficient RN hours.
These five proactive strategies can give your organization an edge when incorporating the PBJ updates and keep your Nursing Home Compare star ratings shining bright.
1. Fill the Documentation Gaps
As of April, CMS has activated two new penalties for missing data. Providers that fail to submit staffing data by the required deadline or that have significant discrepancies between reported hours and verified hours will receive an automatic rating of one star in the staffing section. Tardy documentation or inaccurate timekeeping will come back to haunt you – and you’ll be stuck with that one-star rating for an entire quarter.
2. Catch a Falling Star
Frequent monitoring of your PBJ data is the key to spotting declining trends in data that will hurt your star ratings. Running PBJ reports and watching data on a weekly basis can help administrators solve snags in staff ratios, RN coverage and missing documentation before the next quarterly report to CMS. Being proactive can alert administrators to problems while they can be remedied quickly, rather than waiting for the quarterly CASPER reports from CMS after the data damage has already been done.
3. Mind the Submission Dates
PBJ data uploads for any quarter are due within 45 days of the end of the reporting period. CMS will not consider any data submitted after this reporting deadline until the next quarter, so the Five-Star ratings will not reflect any improvements in staffing measures until the next reporting period. Even if your organization has made great strides to improve staffing measures, none of it will count in CMS’ eyes if it isn’t submitted on time.
4. Understand the Exclusions
Some post-acute care environments have unusual staff/resident ratios because of specialized case mixes, extremely high acuity or other extenuating circumstances. If your quarterly total nurse staffing and resident census data are excessively high or excessively low, CMS will exclude the data from the public reporting on the Nursing Home Compare website. In other words, CMS will use “data not available” on the ratings rather than display data that is skewed by unusual circumstances. If your organization is in this category, some additional consumer outreach and education could go a long way to explaining why your staffing section on Nursing Home Compare doesn’t look like other organizations’ entries.
5. Shift to RUG IV
As of April 2018, the Expected Hours portion of the staffing formula now stems from resident distributions under the RUG IV groupings, which are determined by combining data from various sources, including the most recent OBRA-required or scheduled-PPS assessments. For the Five-Star calculations, the RUG category distribution data is pulled on the last business day of the last month in the quarter. Therefore, tardy documentation – especially near the end of the quarter—can seriously affect RUG IV calculations.
Taking a proactive approach to the PBJ changes and establishing protocols to monitor staffing data closely can keep clinical administrators and human resources personnel on the same page in the joint effort to keep those star ratings high.
To learn more about optimizing your staffing data and PBJ reporting, contact ABILITY Network for a consultation.
1: CMS. Design for Nursing Home Compare Five-Star Quality Rating System: Technical Users’ Guide. Accessed August 14, 2018. https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/downloads/usersguide.pdf