Often nurses think that the Payroll-Based Journal (PBJ) electronic staffing data submission system is an issue for payroll or the business office, notes Suzy Harvey, RN-BC, RAC-CT, managing consultant for BKD in Springfield, MO. “However, now that PBJ will impact ratings in the Five-Star Quality Rating System, the director of nursing services (DNS) needs to be aware of PBJ and involved in the process.”
The Centers for Medicare & Medicaid Services (CMS) offers several reports that can help DNSs be sure their PBJ data is accurate, timely, and ready for prime-time viewing as staffing measures and Five-Star staffing star ratings on Nursing Home Compare. Industry experts suggest DNSs take the following steps:
Pay attention to PBJ Final Validation Reports
When providers submit PBJ data, they receive a confirmation message that their submission file was received, says Harvey. “However, this confirmation message doesn’t tell providers whether the data they submitted was processed and accepted by the CASPER Reporting and PBJ systems. It just confirms submission.” Note: For more information, see Section 4.1.3, Confirmation Message, of the PBJ User Manual.
So the DNS or their designee needs to go back and review the PBJ Final File Validation Report after each submission, says Harvey. “This report will alert you to PBJ data that was not accepted into the system for some reason (i.e., a fatal error) or data that was accepted but may be inaccurate, late, or have another potential problem (i.e., a warning).” Note: For more information, see Appendix F, Payroll Based Journal Systems Edits, in the PBJ User Manual for definitions of each error/warning message and tips on potential actions to address those errors/warnings.
Providers that submit data via XML file can obtain an automatically generated PBJ Final File Validation Report that is available from their PBJ VR folder within 24 hours of successful submission. Note: For more information, see Section 4.3, PBJ Final File Validation Report, of the PBJ User Manual.
“However, providers that submit data manually can’t obtain the PBJ Final File Validation Report,” points out Harvey. “Manual submitters must go into CASPER and request the PBJ Submitter Final File Validation Report. These two reports are basically the same, but you get them from different areas of the system.” Note: For more information, see Section 12, “PBJ Reports,” of the CASPER Reporting User’s Guide for MDS Providers.
Manual submitters can’t even print out the initial submission confirmation message for their submission file, says Harvey. “So if you submit manually, you need to write down your submission ID number that you will see onscreen in a string. Then you can request the PBJ Submitter Final File Validation Report for that specific submission file.”
Review other CASPER PBJ reports
To ensure staffing information is reported accurately, DNSs should review available CASPER reports prior to the quarterly reporting deadline, says Harvey. In addition to the PBJ Submitter Final File Validation Report, four PBJ-related reports are available via CASPER, according to Section 12 of the CASPER Reporting User’s Guide for MDS Providers:
· The 1700D Employee Report;
· The 1701D Census Report;
· The 1702D Individual Daily Staffing Report; and
· The 1702S Staffing Summary Report.
“Those last two—the 1702D Individual Daily Staffing Report and the 1702S Staffing Summary Report—probably are the most important of the four,” suggests Harvey. “In conjunction with the business office staff person, you should look at these reports monthly to double-check that the hours that are showing up as paid hours in PBJ match those hours that you actually paid on your payroll for those staff members, as well as looking at the schedule to make sure you are not missing any information.”
If information is missing, providers need to determine: Why are those hours not showing up accurately? “For example, some facilities’ reports have shown zeroes under certain nursing categories when the DNS has said, ‘No, we had nurses in those categories,’” says Harvey.
One common mistake involves staff members who work over a shift, says Harvey. “For example, a nurse put in 16 hours one day, but they forgot to clock in and out at the beginning and end of each shift, or maybe your policy doesn’t require that and they just forgot to clock out when they actually left. The business office assumed they only forgot to clock out at the end of their eight-hour shift and entered that nurse as an eight-hour day when they actually worked that double shift,” she explains. “Running the CASPER PBJ reports and comparing them against your payroll and schedule prior to the quarterly submission deadline will help ensure you capture all of those hours.”
Note: Need to know the quarterly submission deadlines? Find them here.
Look for trends over time
While it’s important to review these PBJ reports timely in order to correct inaccurate data prior to the quarterly data submission deadline, it’s also important to take a more global look at the data, suggests Carl Moellenkamp, CPA, a director in consulting for the Health Care Practice at CliftonLarsonAllen LLP in Oak Brook, IL.
“Typically the staff member who is gathering and inputting the PBJ data is focused on getting the data in timely. They are too close to the data to look at it from a broader perspective,” notes Moellenkamp. “So you need someone to review the data from quarter to quarter to look for inconsistencies and trends. For example, if an employee is listed as contract one quarter, their data is missing for the next quarter, and they are listed as a paid employee the following quarter, someone needs to flag that inconsistency so you can figure out what happened as a team with payroll, the business office, human resources, or whoever else is involved in the PBJ process.”
Don’t ignore these three MDS reports either
“The census used to calculate the staffing measures is being taken directly off of MDS assessments,” says Harvey. “Therefore, missing assessments are critical, especially discharge assessments. A missing discharge assessment will make it look like that resident is still in your facility, which increases your census and actually could decrease your staffing levels because you don’t have enough staff to care for all of the residents who incorrectly show up as still being in your building.”
In addition, providers need to be sure they capture resident acuity accurately on MDSs, says Harvey. “The PBJ-based ‘hours per resident per day’ (HPRPD) staffing measures will use a new risk-adjustment methodology. Until now, CMS has used a risk adjustment involving a facility’s expected nursing hours based on their distribution of residents by RUG-III group. With the change-over to PBJ data, the RUG-IV system will be used for risk adjustments, and CMS also is adjusting the thresholds or cut points between each star rating. So accurate assessments that are submitted timely are extremely important.”
In S&C memo QSO-18-17-NH, CMS cites failure to submit MDS assessments appropriately as a common error identified in PBJ data verification audits, stating that facilities must: “Submit Minimum Data Set (MDS) assessments in accordance with 42 CFR §483.20 and the resident assessment instrument (RAI) 3.0 User’s Manual. Since each facility’s census is calculated using MDS data, it is critical that facilities adhere to the completion and transmission requirements. This includes submitting discharge assessments timely, and completing required assessments for every resident within the certified facility.”
Harvey suggests that nurse assessment coordinators print out and provide the following MDS reports to their DNS:
· The Admission/Re-entry Report;
· The Discharges Report; and
· The Missing OBRA Assessments Report.
“The DNS should review these reports on a monthly basis,” says Harvey. “Doing this review doesn’t mean you don’t trust your MDS coordinator. The point is: Everyone is human and can miss things, so it’s nice to have a second pair of eyes, and the DNS should be that second pair of eyes.”
DNSs often don’t have an in-depth knowledge of the MDS process, acknowledges Harvey. “However, you still need to be able to read those reports and understand what they mean because the MDSs can affect your census, as well as your acuity.” Note: For details on these three reports and how to interpret them, see Section 6, “MDS 3.0 Nursing Home Provider Reports,” in the CASPER Reporting User’s Guide for MDS Providers.
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