Mandatory compliance with the new Centers for Medicare & Medicated Services (CMS) payroll-based journal reporting (PBJ) requirements begins July 1, 2016. Are you prepared? Whether it’s reaching out to your payroll or timekeeping vendors to supply the data, working with internal IT departments, or contacting other IT software companies, it’s critical you find a solution now.
We believe the number one best practice is to have a total solution for PBJ reporting that covers all of the new CMS’s requirements. Below are the top five issues:
- Reporting of exempt staff in time and attendance systems. Under the new requirements, direct care exempt staff hours must be reported in your PBJ system. If you don’t already, have your exempt staff enter their time or start swiping into your time and attendance system. Remember, you’ll need an accurate record of your exempt staff’s paid time off as these hours cannot be counted.
- Manual hours override. Does your current system support manual overrides for hour adjustments before issuing the final XLM report? Consider this example: if an exempt staff member (i.e., a director of nursing — DON) has dual responsibilities in certified and noncertified areas and does not swipe in or out, someone would need to manually override the PBJ to properly record the certified hours. Note, CMS understands some staff have overall facility responsibilities and that providers need to refer to the staff’s primary role when reporting their hours. Thus, if the DON needs to cover an emergency in the assisted living unit, we would not expect this time to be deducted from PBJ reporting. Additionally, manual override may reduce training hours for CNAs.
- Clocking in and out between certified and non-certified areas. For the majority of providers, we see direct assignment of caregivers by level of care. However, some providers allocate salaries and hours for cost reporting purposes. If your system does not allow automatic tracking and you use allocations to split hours between certified and non-certified areas, you must comply with CMS Publication 15-1 The Provider Reimbursement Manual – Part 1 Chapter 23, 2314 (E) for an auditable methodology for calculating and reporting the number of hours in the certified areas.
- Upload of daily hours from contract nursing agencies and therapy companies. Don’t wait until mandatory reporting to discuss how your vendor’s hours will be uploaded to your PBJ system. Some therapy operating systems may already send daily information to certain EMR systems for billing and medical records. Receiving therapy hours electronically will also provide auditable reconciliations for your therapy bills and provide accurate therapy hours for Medicare cost reporting purposes.
- Monthly time sheets for all direct care consultants. While we understand this is the last thing physicians want to be bothered with, PBJ requires an auditable methodology to record patient care hours for direct care consultants, such as medical directors, corporate staff, and contract nurse consultants. We recommend you update your medical director’s contract to enforce compliance. If you do this right, there is a high probability you will gain additional cost-based reimbursement from Medicare.
Don’t forget the data
The purpose of PBJ is to replace the manual submission of CMS 671 and 672 and determine your reported direct care hours on a quarterly basis. An ideal PBJ system should provide you with data analytics around staffing, use of nonproductive time, and most importantly, the results of your direct care hours and potential impact on your five-star rating before you submit.
This data will help you understand where you currently stand, what adjustments need to be made to get to the next star, or what adjustments will not impact your star rating. Selecting the right data management system will help you manage costs and best position your organization for value based purchasing.
Lastly, be prepared and budget for the new CMS requirement. Depending on your time and attendance vendor, there may be additional annual fees to receive data uploads, especially if you currently use an older version of their software. There may also be a one-time setup fee, or IT development costs if you’re a larger multi-unit facility.
