CMS FAQs on Electronic Staffing Data Submission

Section 6106 of the Affordable Care Act (ACA) requires facilities to electronically submit direct care staffing information (including agency and contract staff) based on payroll and other auditable data. The data, when combined with census information, can then be used to not only report on the level of staff in each nursing home, but also to report on employee turnover and tenure, which can impact the quality of care delivered.

Therefore, the Centers for Medicare & Medicaid Services (CMS) has developed a system for facilities to submit staffing and census information – Payroll-Based Journal (PBJ). This system will allow staffing and census information to be collected on a regular and more frequent basis than currently collected. It will also be auditable to ensure accuracy. All long-term care facilities will have access to this system at no cost to facilities.

CMS began collecting staffing and census data through the PBJ system on a voluntary basis beginning on October 1, 2015, and on a mandatory basis beginning on July 1, 2016. CMS will communicate more information at that time and in order to help answer any questions that may come up CMS has developed a FAQ page.Of note, there are requirements for keeping track of time spent by physicians and medical directors in the facility. Questions 4 and 5, pasted below clarify the provision:

Q4: How do we report the hours for a medical director who spends the entire day in the building, but some of that time is spent conducting Medical director responsibilities and some is spent seeing residents as an attending physician?

A: CMS understands it may be difficult to identify the exact hours a physician spends performing medical director activities versus primary care activities. Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on site conducting primary responsibilities. For example, if a medical director is contracted for a certain fee (e.g., per month) to participate in Quality Improvement meetings and review a certain number of medical records each month, the facility should have a reasonable methodology for converting those activities into the number of hours paid to work.

Q5: Our physicians, therapy, respiratory, pharmacy, dietary, and contract staff also provide these services to all of our nursing homes, but we don’t know exactly when they are in any one center. How do we report their hours?

A: Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. We understand it may be difficult to identify the exact hours a specialist contractor (e.g., non-agency nursing staff) is in-house. However, there should be some expectation of accountability for services provided. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on site conducting primary responsibilities, based on payments made for those services. Reminder: Hours for services performed that are billed to FFS Medicare or other payer, should not be reported. For example, physician visits to residents, hospice staff, or private duty nurses hours should not be reported.

For more information please visit FAQs about Electronic Staffing.
 

Additional information about the project is available here.