The new CMS PBJ requirements are being reported here on the RA Blog, in a simplified, resourceful 3-part series, and include:
- PART 1: Important essentials, present and future differences, biggest challenges facing providers, resources.
- PART 2: Direct staff list and codes, what data to report, when and how to report.
- PART 3 (this post): Tracking agency and contractors, questions and considerations, list of helpful resources.
Tracking of Employees and Contractors
Healthcare facilities, most notably SNFs, are responsible for PBJ. All direct care staff that have interpersonal contact with residents, including employees and contractors, must be reported in the PBJ. Facilities Rehab Directors and or Rehab Managers must strategize how they intend to manage and obtain the required information and implement reporting systems with agencies and contractors to ensure month over month accuracy so that data gathered can be verified through either payroll, invoices, and/or tied back to a contract.
According to CMS, facilities have a few options for reporting contractors:
- “Facilities can include contract staff hours in their attendance system (e.g., have contractors “swipe in and out”), or enter contractor hours manually through the PBJ online data entry process.
- Facilities can have the contract staff enter hours as a designee of the facility in the PBJ system.
- The vendor can provide the facility with an XML file that meets the technical specifications, and the files can be uploaded and merged.”
As stated by OnShift, in the PBJ, contractors and agency workers will be defined by ‘Pay Type Code’:
- “Non-exempt: Employees who are entitled to overtime pay.
- Exempt: Employees who are not entitled to overtime pay.
- Contract: Contract staff includes individuals under contract (e.g ., a contracted physical therapist) as well as individuals who provide services through organizations that are under contract (e.g ., an agency to provide nurses).”
Questions and Considerations
Some of the most important considerations include:
Tracking 37 different staff codes – you will need to work with your staffing teams to define which job titles suit each labor code to ensure accuracy. In some cases, if multiple roles are performed, time will need to be split and this process of reporting will need to be communicated to staff.
Documenting hours correctly – shifts that crossover midnight will need to be split in two as data is only recorded for each day. Knowing what hours/ work to report for each job code is essential, as even 30 minutes in resident care must be reported.
Collecting auditable data – not only do you need systems to record data but your data also needs to be auditable. At this stage, CMS have not released information on how data will be audited. But know that it will and your facility may be randomly selected at anytime. If you haven’t already, speak to your current healthcare IT/ software provider to enquire about how they will be accommodating the new CMS changes and creating auditable data that you can easily dispose to CMS if required.
Be prepared and organized – because it is mandatory for data to be reported quarterly, do not leave it until the last minute to pull information together. Without a doubt, this is both an administrative and financial burden for many facilities, at least in the beginning. But since it is mandatory, there is no choice but to be prepared and organized. It will save you stress and non-compliance penalties, too!
Resources and Further Reading
- Registration information
- PBJ checklist
- CMS PBJ website – Includes basic policy information, technical details for providers and third parties, and is updated regularly with new information.
- QIES PBJ website and here – Includes training, FAQs and information for third-party vendors/developers.
- OnShift and here – Some great information and a free whitepaper on the topic. They also offer software that meets PBJ requirements.
- Various vendors (and here) with system/ software solutions.