The Centers for Medicare & Medicaid Services (CMS) made several changes to the Payroll-based Journal (PBJ) system this spring, including new penalties for not meeting the submission requirements. Does your staff have a clear understanding of what the damage will be to your organization’s Five-Star ratings if the new guidelines aren’t followed?
Primary changes to PBJ:
- April 2018: CMS replaced the existing staffing measures. Instead of using Form 671 and case-mix based on RUG III, staffing is now determined by the PBJ reporting and case-mix is based on RUG IV.
- May 2018: CMS added additional descriptors defining resident census and how census is calculated.
Organizations that don’t conform to the new updates could be stuck with a one-star rating in the staffing section for the quarter—or worse, the loss of several stars at once.
How much does it hurt?
Like any other quality measure under Nursing Home Compare, staffing quality measures and PBJ reporting impact star ratings. The staffing formula is a complex mathematical stew of reported hours, expected hours, the hourly national average and daily resident census. More than anything else, two things will surely skew your data and produce inaccurate ratings: faulty staffing hours data and faulty census data.
Staff and job codes
Facility staffing ratings are based on two measures: total staff hours per resident per day (RNs, LPNs and nurse aides) and RN-specific hours per resident per day. Staffing data is now submitted quarterly, directly from the PBJ system.
CMS uses the following job codes in the calculations for staffing measures:
- RN hours: Includes RN director of nursing (job code 5), registered nurses with administrative duties (job code 6), and registered nurses (job code 7).
- LPN hours: Includes licensed practical/licensed vocational nurses with administrative duties (job code 8) and licensed practical/vocational nurses (job code 9)
- Nurse aide hours: Includes certified nurse aides (job code 10), aides in training (job code 11), and medication aides/technicians (job code 12)
All staff under these job codes 5-12 are included in the PBJ data reporting, whether they are full-time, part-time or contract employees. Among those not included are housekeeping staff, hospice staff, feeding assistants and private-duty nurses hired by the resident or family. If an employee is in the PBJ system under the wrong job code – or if an employee is performing tasks that should be considered a different job code – it can skew the staff ratios once the CMS PBJ formula is applied.
Daily census measures are now derived from the MDS assessments, using the RUG IV groupings. That means if a resident’s discharge assessment isn’t in the MDS system yet, CMS will assume the resident is still in the facility. Likewise, if a resident has no MDS data for a period of 150 days, CMS will assume the resident has been discharged. Administrators should ensure all employees understand the costs of documentation that is incomplete or late – don’t let problems with your workflow process cause problems with your staffing Five-Star ratings.
Certain things result in the automatic loss of one or more stars. The further an organization’s case mix and staffing ratios are from the desired mark the more stars are lost.
If an organization suffers a star loss because of staffing data, the new lower rating holds until the next quarter. Most would agree that’s better than a whole year, but the lag time in changing public-facing data can still be a pain point when an organization’s reputation is on the line.
The Staffing Domain section of the report details how the changes affect five-star quality ratings. See the CMS guide for information on other 2018 changes.
To learn more about optimizing your staffing data, read our flipbook, Payroll-Based Journal and Your Staffing Stars
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