PBJ=Staffing Data Submission (Not the Treat of Your Childhood)
Staffing numbers, mix of credentials and roles and deployment of staff have a major impact on the quality of life and quality of care for post-acute care residents. An initiative from the Affordable Care Act requires that nursing facility staffing data be reported electronically to CMS starting in July 2016. One mechanism for reporting staffing data is via the Payroll-Based Journal (PBJ) upload process. On October 1, 2015 facilities were given the ability to voluntarily upload staffing data into the CMS system. Facilities that have begun submitting data report that it has not been a smooth process.
Nursing Facilities historically staff according to their budget. Some facilities have budget items for LPNs and RNs. Nursing staffing including payroll and benefits; represent the largest cost area for any health care provider. Failure to effectively manage staffing levels can have an immediate and significant effect on the financial, clinical and compliance health of the organization. Clinical quality is directly and positively impacted by consistent and appropriate staffing levels
There are no consistent staffing regulations across the nation, although some states have specific nursing home staffing regulations. The CMS Guidance to Surveyors says, “The facility must provide services by sufficient numbers of each of the following types of personnel on a 24-hour basis to provide nursing care to all residents in accordance with resident care plans: (i) Except when waived under paragraph (c) of this section, licensed nurses; and (ii) other nursing personnel. Registered nurse – the facility must use the services of a registered nurse for at least 8 consecutive hours a day, 7 days a week. The facility must designate a registered nurse to serve as the director of nursing on a full time basis. The director of nursing may serve as a charge nurse only when the facility has an average daily occupancy of 60 or fewer residents.”
In the Guidance to Surveyors sufficient staffing is referenced as part of surveyor investigation of issues at F155 Resident right to refuse treatment, F162 Resident funds,
F 309 Pain and on the checklist of factors to consider to identify potential causes of behavioral symptoms F315 Incontinence, F323 Accident prevention, F325 Nutrition, F353 Staffing, F356 Staffing posting, and F360 Dietary services.
Access to Staffing Data
There is place that nursing facility staffing data is accessible to the public; the Nursing Home Compare website using the 5 Star Report. Nursing Home Compare was initiated in 1998 as a result of many years of study of possible process and outcome measures using MDS data. Staffing is one of the three domains for the Five-Star Quality Ratings that are published there. Currently staffing data and the resulting star ratings reflect the staffing data reported to surveyors for the two weeks prior to the facility’s routine annual survey. Form CMS 671 has been used to report this data once per year.
Staffing star ratings are risk adjusted and use fixed numerical thresholds for each star level. Star rating thresholds consider the nursing home’s expected staffing based on the facility’s acuity represented by reported RUG distribution and nursing staffing data from 2006-2007 in the Staff Time and Resource Intensity Verification (STRIVE) study. Nursing homes are ranked according to other facilities in their state and across the nation. Star rating thresholds on Nursing Home Compare were modified in February 2015.
Why Staffing Data Matters
With increasing frequency the general public is using available data to choose a facility for themselves or their loved ones. As the public becomes more educated about the correlation between staffing, RN staffing and quality outcomes for residents the facility’s staffing data on Nursing Home Compare will steer them to select facilities that acquire higher star ratings for staffing.
CMS has authorized multiple alternative payment models for Medicare and Medicaid payments. The goal of these payment model trials is to manage and decrease costs while providing care that results in positive clinical outcomes. Initiates such as Accountable Care Organizations (ACO) and Bundled Payment initiatives require participation of providers across the healthcare continuum. The originators and conveners of these trial programs are using 5 Star ratings as one indicator of a SNF’s ability to provide quality outcomes to residents. It is generally accepted that only facilities with a four or five star rating will be invited to participate.
On July 1, 2016 CMS will require nursing facilities to submit staffing data quarterly. Data will be submitted electronically and will be used to update the facility’s Five-Star Nursing Staffing rating on a quarterly basis. Additionally CMS will use the data to monitor and report on staff retention and staff turnover. Staffing data can be entered manually or uploaded electronically to the CMS site.
There are precise requirements for the data to be successfully accepted into the CMS database.
- CMS has identified 37 job codes that must be used. Each facility must define the workers and job descriptions that fi within each job code. Does your facility have a definition of each CMS job code? Is there a crosswalk between the job description titles in your facility and the CMS job codes?
- CMS requires that agency staff and contracted staff beginning and ending employment dates as well as hours worked be tracked and reported. Does the facility have a tracking mechanism that records the employment dates at the facility and the number of hours worked for each agency or contracted employee?
- Each employee is required to be identified by a unique number for reporting hour worked. Does the facility have a tactic for assigning and managing unique employee identifiers?
- Hours worked by corporate staff must be tracked and reported. Do corporate staff track hours spent at the facility and report them to the payroll department?
- CMS has stated that all hour submitted must be auditable back to payment for those hours. Does the facility have a process in place to audit reportable hours for accuracy?
Karolee Alexander, RN, RAC-CT,
Director of Reimbursement and Clinical Consulting
Facilities can voluntarily submit staffing data to CMS now. Begin to prepare your facility now to be able submit staffing data to CMS accurately and efficiently in July 2016. More information about the technical data requirements and the submission process can be found in the PBJ User’s Manual.
Are you prepared for success? Contact us to learn more.