CMS Staffing Data Requirements

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Gary Mason
6 years ago
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1 CMS Staffing Data Requirements PBJ may be hard to swallow! Lori Brunholtz, CPA Managing Director, BKD, LLP

2 Staffing Data Required by ACA Electronic submission of: Direct Care hours including agency & contract Specific categories RN, LVN, CNA, therapist, & other medical personnel Resident census & case mix Capture employee turnover & tenure Report hours of care Auditable data Uniform format

Staffing Data Collection CMS developed Payroll-Based Journal PBJ Data to be submitted through QIES Mandatory start July 1, 2016 Quarterly submission

3 Staffing Data Collection CMS developed Payroll-Based Journal PBJ Data to be submitted through QIES Mandatory start July 1, 2016 Quarterly submission Data will eventually be used in 5-Star Quality ratings Continue to complete the CMS-671 form for staffing during survey until transition to PBJ data

4 Definition of Direct Care Staff Per CMS Direct Care Staff are those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well-being. Direct care staff does not include individuals whose primary duty is maintaining the physical environment of the long term care facility (for example, housekeeping).

5 Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html

Detailed Staff Information Individual IDs staff & contractors Hire date Termination date Pay type exempt, non-exempt, contract Labor category general department Job title specific role Hours split if

6 Detailed Staff Information Individual IDs staff & contractors Hire date Termination date Pay type exempt, non-exempt, contract Labor category general department Job title specific role Hours split if multiple roles performed Enter each employee s hours worked DAILY Night shift hours spanning midnight must be split EXCLUDE paid leave time, inservice, training, on-call EXCLUDE paid meal time Short breaks throughout the day may be included

7 Detailed Staff Information Salaried employees report only base hours, even if more hours worked Medical Directors, other specialists & contractors, corporate personnel reasonable methodology for reporting facility time related to resident care DO NOT report attending physician or patient care time that the physician or contractor can bill for separately Exclude non-snf/nf time (hospital, ALF) Exclude volunteers

Medicaid, Other Medicare days include only FFS, Medicare Managed

8 Detailed Census Information Month-end snapshot only Only count residents in facility on last day of the month By payer Medicare, Medicaid, Other Medicare days include only FFS, Medicare Managed Care (Medicare C) days are other Medicaid pending are other until approved

9 Reporting Manual entry through QIES PBJ system Data can be uploaded electronically interface must be in XML format technical IT specifications on CMS PBJ website Due 45 days after each quarter end Submissions/corrections accepted after deadline, but not used for staffing measures Data viewable through CASPER Per CMS, PBJ data Audits to be conducted by individuals or entities who are subject matter experts in this area

10 Staffing Data Collection Facilities that fail to submit accurate, verifiable data will be considered noncompliant and subject to enforcement actions by CMS submission of staffing information is a condition of participation for Medicare or Medicaid

12 Rules of Thumb Two basic criteria Only count time providing resident care or resident care management AND Only count time paid by the facility

13 Report Hours in PBJ? A physician visits a patient in your facility, then bills the patient s insurer No, the facility is not paying the physician for the encounter A Hospice company s nurse visits one or your residents No, the Hospice is billing another payer A CNA participates in CPR training No, training time should be excluded A nurse aide in training, shadows another nurse doing patient care If the aide in training is being paid, their time would be included

14 Report Hours in PBJ? An LPN takes a bathroom break CMS states, we recognize that nursing home staff engage in other non-care and direct care activities throughout their day, such as breaks, so time for breaks may be included A volunteer takes a resident for a walk Volunteers are not paid, so cannot include The DON covers a weekend LPN shift If the DON is paid extra, above their salary, include, otherwise additional time is excluded

15 Report Hours in PBJ? A Corporate Nurse on site assisting with pre-survey preparation Corporate personnel can be counted, but only if they are providing patient care A CNA sometimes works as a housekeeper Time must be split, housekeeping is not considered patient care A CNA sometimes works as activities staff Time must be split, report activities time separately

16 Report Hours in PBJ? A paid feeding assistant Paid feeding assistant time is included A dining assistant serving trays & taking orders Not considered patient care by CMS A phlebotomist from your contract lab Lab is considered patient care, but optional An X-ray tech from your mobile x-ray X-ray is considered patient care, but optional Time spent by the Beautician washing a resident s hair Not considered patient care by CMS

17 Report Hours in PBJ? A Nurse Consultant on site doing MDS training Training is excluded A CNA on a paid lunch break Lunch breaks should be excluded The facility Administrator s time Report Administrator & Asst Administrator in PBJ (salary hours only) Hours worked by an Agency LPN Agency staff should be reported Time paid for Holidays All non-worked paid leave time is excluded

18 True or False? Each individual from a staffing company who works in your facility must be assigned a separate unique ID number True The salaried DON needs to clock in & out for PBJ so all her hours can be captured False, only base salary time can be included The direct care time reported for your therapists cannot exceed minutes that count toward the RUG categories False, all therapist time providing care can be included

19 True or False? You need to change your evening shift to end at midnight so you don t have to split time between calendar days for the 11:00 to 7:00 shift False, you may want to consider adjusting your shifts, but it s not required. However, time before and after midnight must be split and reported on the day worked Time nurses spend charting, care planning, completing assessments, is considered Direct Care True

20 True or False? A resident is out of the facility on the last day of the month, but is paying for bedhold, so that day should be counted in census False, only residents physically in the facility should be counted The hire date reported for an employee who left but returned is their most recent hire date, not their initial employment date True You can count vacation time taken by the DON, since she is on salary False, non-worked paid leave time should not be included

21 (918) QUESTIONS?

Electronic Staffing Data Submission Payroll-Based Journal

Centers for Medicare & Medicaid Services Electronic Staffing Data Submission Payroll-Based Journal Long-Term Care Facility Policy Manual Version 1.0 April 2015 TABLE OF CONTENTS Chapter 1: Overview 1.1