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© 2016 AADNS

The Looming PBJ Reporting Deadline How to Strengthen Your Staffing Management System

Now

Presenter:

Amy Franklin, RN, DNS-MT,RAC-MT

Faculty Disclosure

• I have no financial relationships to disclose

• I have no conflicts of interest to disclose

• I will not promote any commercial products or services

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Requirements for Successful Completion

• 1.0 contact hours will be awarded for this continuing nursing education activity.

• Criteria for successful completion includes attendance for at least 80% of the entire event. Partial credit may not be awarded.

• Approval of this continuing education activity does not imply endorsement by AADNS or ANCC (American Nurses Credential Center) of any commercial products or services.

American Association of Post-Acute Care Nursing (AAPACN)* is accredited as a provider of continuing nursing education by the American Nurses Credentialing Center’s Commission on accreditation.

*AAPACN d/b/a American Association of Directors of Nursing Services

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Objectives

• Utilize facility level reports, as well as the CASPER online reporting system, to understand your staffing benchmarks and set goals

• Identify when it’s time to audit, and how to conduct staffing audits most effectively

• Integrate PBJ reporting requirements into your facility’s internal protocol, policies, and procedures

• Understand how PBJ will impact your facility’s Five Star rating

• Develop administrative oversight and monitoring

systems to consistently ensure effective staffing

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CMS Payroll-Based Journal

Why

PBJ

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CMS PBJ Background

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• Section 6106 of the Affordable Care Act• Funding provided by the IMPACT Act of 2014• Strengthen Public Reporting and Five-Star Quality Rating

System

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CMS PBJ Objectives

• Report staffing levels, turnover, and tenure• Auditable back to payroll data and other verifiable

sources• Report staffing information throughout the year (more

frequently than 671/672 forms)

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PBJ: The Electronic Submission of Staffing

Finalized• In the FY16 SNF PPS Rule as 42 CFR 483.75(u)

(https://www.federalregister.gov/articles/2015/08/04/2015-18950/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities)

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How will PBJ be

viewed?

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How PBJ Interacts With Quality Reporting

• 5 • Five Star QMs

• Public

• Survey Results

• Governmental Audit

• Audit will crosswalk: Reported hours: Survey, PBJ and Cost Report

• CASPER QMs

• Survey & Cert

• Census

• Staff Retention

• Staff Categories

PBJQuality

Measure

5 STARAnnual

Cost Reporting

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CMS Forms That Will Continue

• 671 Form: Completed during the standard (annual) Survey (2 week staffing hours)

• 672 Form: Completed during the Standard (annual) Focus and Complaint Survey

• The Census and Payer Type breakout portion of the 672 is used for the 5-Star calculation

• Reported Census and MDS snap shots are used to report staffing needs on the last business day, per quarter, based on the 672 census form

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PBJ Captures Staff Retention

Unique Identification (ID) Number (employee ID)

• Facility creates ONLY one per employee

• Tracts hire date

• Termination date

• The Unique ID Number Never Changes even with rehires

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PBJ Captures Staff Retention

This requires collaboration between the Director of Nursing Services (DNS) and Human Resources (HR)

Questions to ask your HR personnel:• Is HR focused on staff retention? • What type of retention program is in place?• Does HR understand PBJ will be reporting retention?• Are employee satisfaction surveys viewed valuable

within your organization?• Is employee turnover reported in Quality Improvement

Committee?• Does HR understand staff retention is a intricate part of

delivering quality care and services?

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PBJ Definitions for Category and Job Title

CMS’s PBJ Version 2.1 Policy Manual CH 2: Definitions

• Pay Type Code

oClassification of whether the staff member is a direct employee of the facility (exempt or non-exempt), or employed under contract paid by the facility.

• Labor Category Code

oA code identifying the CMS defined labor category groupings of associated Job Titles

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PBJ Definitions for Category and Job Title

CMS’s PBJ Version 2.1 Policy Manual CH 2: Definitions (cont.)

• Job Title Code

oA code identifying the CMS defined Job Title(s) that matches the role(s) of the staff member for the associated number of hours that the role(s) was performed

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Practical Application of the Job Title Code

Job Title Code (JTC) is the designation of which department/job function within the department

(9 JTC for Nursing Services)

• Reporting hours per day

• Day of the week worked

• Can change when the

primary job role changes

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Practical Application of the Job Title Code

Example: If a RN Unit Manager works the floor as a nurses aide for 4 hours on Monday until relieved, then resumes the unit manager role for the next 7 hours…

The hours are recorded as:

JTC10 4 hour Monday CNA

JTC07 7 hours (3.5 hours if salaried) Monday RN Manager

with the same Employee Unique ID

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Direct Care Hours vs. Nurse Administration Hours

Example: The RN in-service director (salaried) had worked Monday through Friday 8 hours each day. She is on-call for the week (Monday pm through the following Monday am). During the work week she had worked additionally:

Consider:1. Does your facility pay

salaried staff for direct care hours worked on the floor ?

2. If yes, then you would capture the hours in the designated JTCs

3. If no, you are not able to capture the direct care hours

4. The JTC is the key to reporting

A. Direct Care hours vs.

B. Nurse Admin. Hours

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JTC Hours

Mon Tue Wed Thu Fri Sat Sun

AdmRN

0 8 8 8 8 8 0

RN -Floor

0 0 0 8 0 0 12

CENA 0 0 0 0 0 8 0

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CMS PBJ Manual:

Table 1: Labor and Job Codes and Descriptions : April 2016 Page 2-7

JTC 5 Nursing Services Registered Nurse Director of Nursing: Professional registered nurse(s) administratively responsible for managing and supervising nursing services within the facility. Do not additionally reflect these hours in any other category.

JTC 6 Nursing Services Registered Nurse with Administrative Duties :Nurses (RN) who, as either a facility employee or contractor, perform the Resident Assessment Instrument function in the facility and do not perform direct care functions. Also include other RNs whose principal duties are spent conducting administrative functions. For example, the Assistant Director of Nursing is conducting educational/in-service. Facilities with an RN waiver who do not have an RN as DON report all administrative nursing hours in this category.

JTC 7 Nursing Services Registered Nurse :Those persons licensed to practice as registered nurses in the State where the facility is located. Includes geriatric nurse practitioners and clinical nurse specialists who primarily perform nursing, not physician- delegated tasks. Do not include Registered Nurses' hours reported elsewhere.

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CMS PBJ Manual:

Table 1: Labor and Job Codes and Descriptions : April 2016 Page 2-8

JTC 8 Nursing Services Licensed Practical/Vocational Nurse with AdministrativeDuties : Those persons licensed to practice as licensed practical/vocational nurses in the State where the facility is located, and do not perform direct care functions. Also include other nurses whose principal duties are spent conducting administrative functions. For example, the LPN Charge Nurse is conducting educational/in-service, or other duties which are not considered to be direct care giving.

JTC 9 Nursing Services Licensed Practical/Vocational Nurse : Those persons licensed to practice as licensed practical/vocational nurses in the State where the facility is located. Do not include those hours of LPN/LVNs reported elsewhere.

JTC 10 Nursing Services Certified Nurse Aide:Individuals who have completed a State approved training and competency evaluation program, or competency evaluation program approved by the State, or have been determined competent as provided in 483.150 and who are providing nursing or nursing-related services to residents. Do not include volunteers.

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CMS PBJ Manual:

Table 1: Labor and Job Codes and Descriptions : April 2016 Page 2-8

JTC 11 Nursing Services Nurse Aide in Training :Individuals who are in the first 4 months of employment and who are receiving training in a State approved Nurse Aide training and competency evaluation program and are providing nursing or nursing-related services for which they have been trained and are under the supervision of a licensed or registered nurse. Do not include volunteers.

JTC 12 Nursing Services Medication Aide/Technician: Individuals, other than a licensed professional, who fulfill the State requirement for approval to administer medications to residents.

JTC 14 Nursing Services Clinical Nurse Specialist :A registered nurse with specialized graduate education who

provides advanced nursing care.

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PBJ Role: Director of Nursing Services

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PBJ reports available in CASPER

• CASPER system provides a number of reports

• These can be used to monitor the process

• Assure staff are submitting staffing reports

• Opportunity to correct prior to deadline

• Sample of reports are provided following this slide

• Request staff members to obtain and have them assessed for accuracy, timeliness, staff retention

• Request staff member who is responsible to report off in QAA

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Must Have PBJ CASPER Reports

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CASPER 1700D Employee Report

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CASPER Report 1700D

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CASPER 1701D

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Sample CASPER Report 1701D Census

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CASPER Staffing Summary Report

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Sort by JTC or Staffing Hours

Leading The Team

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Improving Quality Through QAPI

Action Plan-Identify and Prioritize

Identify Your Gaps & Opportunities

Incorrect hours reported vs. payroll

Knowledge deficit to JTC

671 Compare to PBJ reporting inaccurate

5 star staffing lower than expected vs. PBJ reported

Staff turnover trends

Staff/patient/family satisfaction

Prioritize Quality Opportunities

Problems versus opportunities

Identify high risk issues

Identify high frequency issues

Consider issues

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Action Plan-Plan

• Identify Areas

• Define the Scope

• Determine a Timeline

• Use a Problem Solving Tool (PDSA)

• Report Results

Target Areas for Improvement

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Action Plan

Root Cause Analysis

Select the event & gather preliminary information

Designate a facilitator

Describe what happened

Identify contributing factors (what & why)

Identify the root cause

Corrective Action Plan

Design and implement changes to eliminate the root cause

Choose actions that are linked to the root cause

Consider piloting changes in one area to identify unintended consequences

Measure the success of changes

Submission Deadlines

• Direct care staffing and census data will be collected for each fiscal quarter.

Staffing data includes the number of hours each staff member is paid for

working each day within a quarter. Census data includes the facility’s census

on the last day of each of the three

• Submissions must be received by the end of the 45th calendar day (11:59

PM Eastern Standard Time) after the last day in each fiscal quarter in order

to be considered timely.

The deadline for the first required submission is November 14th, 2016

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FISCAL QUARTER

REPORTING PERIOD DUE DATE

1 October 1 – December 31 February 142 January 1 – March 31 May 153 April 1 – June 30 August 144 July 1 – September 30 November 14

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Effective Delegation

• Asking for reports from the CASPER PBJ System will assist with data analysis

• Delegating is key

• Payroll department to match staffing hours reported

• Facilitate collaboration with the submitter to correct data

• Remember: There are 45 days after the end of each quarter to correct your hours, days of the week and staff JTC.

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Enforcement

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• CMS retains enforcement authority (e.g., civil money

penalties (CMPs) for noncompliance with all requirements

for participation, including this new requirement(§483.75(u))

• We will provide feedback mechanisms to providers that willhelp facilitate compliance with this requirement

• CMS may refrain from imposing enforcement remedies

while providers adjust to the new requirement (e.g., for

good faith effort)

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CMS Contacts

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• Questions regarding PBJ policy issues should be directed toNHStaffing@cms.hhs.gov

• Questions regarding the PBJ Data Specifications should bedirected to NursingHomePBJTechIssues@cms.hhs.gov.

• Software developers or vendors that provide services such asautomated payroll or time and attendance systems that willsupport electronic submissions should use this address.

Resources and CMS Contacts

More Information

• PBJ Website: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-

• Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html

• Survey and Certification Memo S&C 13-16-NH:https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html

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Resources

Handouts

• Electronic Staffing Data Submission Payroll-Based Journal (PBJ) System Data Submission Frequently Asked Questions

• CMS’s PBJ Version 2.1 Policy Manual

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Questions and Clarification Time

43Amy Franklin’s email:afranklin@aadns.org