CMS Releases Draft Electronic Staffing Data Submission Payroll Policy Manual and Submission Specs

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This week CMS released a draft of the policy manual that has been developed, along with submission specs that will be used in the system under development. This is in furtherance of the future expectation for nursing facilities to submit electronic staffing data. While in draft form and there are no current obligations for facilities to begin submitting staffing data, this manual and related information requires member attention at this time.

As background, Section 6106 of the Affordable Care Act requires nursing 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. CMS has been obligated to implement a system to comply with the ACA requirement. Therefore, CMS has developed the Payroll-Based Journal (PBJ), which is envisioned to 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. When finalized all long term care facilities will have access to this system at no cost to facilities.

CMS intends to collect 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.  Registration for voluntary submission will begin in August 2015, and CMS will communicate more information at that time.

Earlier this week, CMS posted the draft Policy Manual that has been developed as part of this system, and as importantly, as provided the submission specs for this system at this time to allow for facilities to share this information with their payroll/timekeeping vendors. Nursing homes are being encouraged to forward this information to their software developers and payroll or time and attendance vendors to evaluate the technical specifications.  Further, nursing homes should encourage software developers or vendors to participate in voluntary vendor registration at https://www.qtso.com/vendor/post.php. This information will be used to contact vendors with important PBJ news, updates, and conference call information.

Members are encouraged to review the information released, all of which can be found posted with additional information HERE. Given the potential impact on facility resources, we will be working with AHCA to provide feedback on CMS’s efforts to implement their statutory mandate. Accordingly, we request members provide WHCA with feedback as to the draft policy released, as well as any reaction or input you receive from your vendors regarding the specifications provided and the ability to integrate your systems to avoid the need to manually enter the to be required information.