Submit or Face the Consequences: Mandatory Staffing Data Collection Starting July 1st. March 24, 2016 Webinar Presented by.

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Submit or Face the Consequences: Mandatory Staffing Data Collection Starting July 1st March 24, 2016 Webinar Presented by Speaker Profiles Peter Corless is the Executive Vice President of Enterprise

Peter is also currently the Associate Business Member President on AHCA/NCAL s Board ofgovernors.

As an experienced, international chief administrative and human resources officer within these organizations, he developed strategies that reduced turnover, improved recruiting and hiring strategies,

1 Submit or Face the Consequences: Mandatory Staffing Data Collection Starting July 1st March 24, 2016 Webinar Presented by Speaker Profiles Peter Corless is the Executive Vice President of Enterprise Development of OnShift, a leader in human capital management software for post-acute care and senior living. Peter is also currently the Associate Business Member President on AHCA/NCAL s Board ofgovernors.peterisarecognizedhrleader inpost-acutecareandis well-knownforhis achievements at some of the country s largest post-acute care organizations, including Kindred Healthcare and Genesis HealthCare. As an experienced, international chief administrative and human resources officer within these organizations, he developed strategies that reduced turnover, improved recruiting and hiring strategies, and reduced laborcosts.peter receivedhisbafromthe UniversityofWaterlooandhisMBAfromYork University s Schulich School of Business. Elaine Howell has 25 years of experience in the labor management field with expertise in human resources, payroll, timekeeping and scheduling solutions. She has been with Kronos for over 16 years and dedicated to the Healthcare vertical for the last 12 years. For the last 7 years, Elaine has been consulting with customers providing long-term care, home health and hospice services. She attends multiple Executive Conferences specific to the Post-Acute industry so Kronos can understand& be prepared to help the industry with new requirements such as the PBJ. 1

to count Learn what processes you should implement today

2 Today s Agenda Gain an in-depth understanding of the new PBJ requirements Find out what hours to count and what not to count Learn what processes you should implement today to get ready Answers to some questions the industry is asking 2

3 PBJ Importance Staffing Data: Current vs PBJ Practices Note: Current staffing reporting practices will still remain in place even after the July 1 st PBJ start date 3

4 A Little History A Little History 4

Countdown to July 1 Aug 2015 Oct 1 2015 July 1 2016 Nov 14 2016 Registration for voluntary submission Voluntary submission

qtso.com/accesspbj.html to register Use the CMSNet Online Registration application to request a CMSNet User ID.

5 Countdown to July 1 Aug 2015 Oct July Nov Registration for voluntary submission Voluntary submission started PBJ mandatory submission begins First mandatory reporting deadline Starting Now: Getting Access Step 1: Go to to register Use the CMSNet Online Registration application to request a CMSNet User ID. The CMSNet ID is needed to access secure CMS sites (e.g., submissions pages/reports) unless an otherwise secure connection has been established. 5

6 Starting Now: Getting Access Step 2: Use the QIES online User Registration tool to obtain a QIES Submission ID. Once you have registered for a CMSNet User ID, you will receive an from MDCN.mco@palmettogba.com containing your login information. Using this information you will connect through the 'CMS Secure Access Service'. 6

7 Who Counts As Direct Care? CMS Job Title Codes & Descriptions Labor Category Code Labor Description 1 Administration Services Job Title Code 1 Administrator 2 Physician Services 2 Medical Director 2 Physician Services 3 Other Physician Job Description 2 Physician Services 4 Physician Assistant 3 Nursing Services 5 Registered Nurse Director of Nursing 3 Nursing Services 6 Registered Nurse with Administrative Duties 3 Nursing Services 7 Registered Nurse 3 Nursing Services 8 Licensed Practical/Vocational Nurse with Administrative Duties 3 Nursing Services 9 Licensed Practical/Vocational Nurse 3 Nursing Services 10 Certified Nurse Aide 3 Nursing Services 11 Nurse Aide in Training 3 Nursing Services 12 Medication Aide/Technician 3 Nursing Services 13 Nurse Practitioner 3 Nursing Services 14 Clinical Nurse Specialist 4 Pharmacy Services 15 Pharmacist 5 Dietary Services 16 Dietitian 5 Dietary Services 17 Paid Feeding Assistant 6 Therapeutic Services 18 Occupational Therapist 6 Therapeutic Services 19 Occupational Therapy Assistant 6 Therapeutic Services 20 Occupational Therapy Aide Labor Category Code Labor Description Job Title Code Job Description 6 Therapeutic Services 21 Physical Therapist 6 Therapeutic Services 22 Physical Therapy Assistant 6 Therapeutic Services 23 Physical Therapy Aide 6 Therapeutic Services 24 Respiratory Therapist 6 Therapeutic Services 25 Respiratory Therapy Technician 6 Therapeutic Services 26 Speech/Language Pathologist 6 Therapeutic Services 27 Therapeutic Recreation Specialist 6 Therapeutic Services 28 Qualified Activities Professional 6 Therapeutic Services 29 Other Activities Staff 6 Therapeutic Services 30 Qualified Social Worker 6 Therapeutic Services 31 Other Social Worker 7 Dental Services 32 Dentist 8 Podiatry Services 33 Podiatrist 9 Mental Health Services 34 Mental Health Service Worker 10 Vocational Services 35 Vocational Service Worker 11 Clinical Laboratory Services 36 Clinical Laboratory Service Worker 12 Diagnostic X-ray Services 37 Diagnostic X-ray Service Worker 13 Administration & Storage of Blood Services 38 Blood Service Worker (OPTIONAL) 14 Housekeeping Services 39 Housekeeping Service Worker (OPTIONAL) 15 Other Services 40 Other Service Worker (OPTIONAL) 7

8 Non-Facility Direct Care Workers How will you collect this information? Required Direct Care Worker Data 8

9 What Hours Count, What Don t Collecting Non-Facility Direct Care Workers 9

19 CMS PBJ Timeline April 6, 2015 October 1, 2015 June 26, 2016 Sept 30, 2016 August 2015 January 15, 2016 July 1, 2016 45 days after Sept 30, 2016 Submission

10 19 CMS PBJ Timeline April 6, 2015 October 1, 2015 June 26, 2016 Sept 30, 2016 August 2015 January 15, 2016 July 1, days after Sept 30, 2016 Submission Specification Version 1 released Submission Specification Version 1.1 released Submission Specification Version 2 released Version 2 accepted for upload 20 10

11 ?Payroll? Based Journal Does Payroll have the following: Hours Per Day Or does payroll have them by week or pay period? Direct Care Or are the hours in payroll Regular, Overtime, Shift Diff s? 21 Verifiable & Auditable Data Uploading data directly from an automated payroll or time and attendance system will function very similarly to how MDS data are submitted currently. The data will be required to meet very specific technical specifications in order to be successfully submitted. Source: Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html 22 11

12 Are facilities required to report hours paid or hours worked? Facilities (SNF/NF) will report hours paid for services performed onsite for the residents of the facility, with the exception of paid time off (e.g,. vacation, sick leave, etc.). For example, if a salaried employee works 10 hours but is only paid for 8 hours, only 8 hours should be reported 23 Do I have to collect and submit this information for non-facility, contract and agency direct care workers? Yes. This information must be submitted for all workers providing care in your community. For agency and contract workers: Hire date for contract staff is defined as the first day worked and billed for at your community Termination date for contract staff is the last day your community or the agency communicates that the contract individual will no longer be providing services at your community. If you are unsure, do not fill in the termination date

13 If someone from corporate is at my facility performing activities that fit into one of the job categories as defined in Table 1, then their hours could be included? If yes, does the corporate person need to be on facility s payroll? If someone from the corporate office is in the facility and is performing duties involving resident care, the hours spent performing that care can be reported, even though the person may be paid through the corporate payroll, rather than the facility s. This would include instances when a corporate nurse is filling in for the Director of Nursing when she/he is on vacation. However, you should not include hours that a corporate nurse spends onsite performing monitoring tasks at the facility or helping the facility prepare for a survey 25 How are we expected to report for staff who perform different roles throughout their day? 1. If the system of record (e.g. time clock) is able to account for time worked in different positions, then yes, you can split the time. Example: Employee XYZ clocks in at 7:00 a.m. in the job code of CNA. Clocks out at 11:00 a.m. Has a half hour meal break. Clocks back in at 11:30 a.m. in the job code of Dietary Aide. Clocks out at 3:00 p.m. System would record on that date: Employee XYZ CNA 4 hours; Employee XYZ Dietary Aide 3.5 hours

14 Different Roles Answer(continued): 2. It is understood that most roles have a variety of non-primary duties that are conducted throughout the day (e.g., helping out others when needed). In these cases, reporting should be based on the employee s primary role and their official categorical title (for example, as indicated in a Human Resources system). Example A CNA who goes to help hand out meal trays over the meal period for a short amount of time. You wouldn t want to try to separate out and attribute that 30 min. or so to a dietary duty. 3. Universal workers are more problematic because they probably do many different jobs during the day (e.g. CNA, Dietary, Housekeeping, Laundry, etc.) and the time spent doing each position would need to be captured in the system of record for audit purposes. This would be more administratively burdensome such that the facility may just want to report the major function of that shift (e.g. CNA). 27 If an exempt employee works as a floor nurse to fill-in when an employee has called off, can I report those hours? This must be handled very carefully so as not to run the risk of violating the employee s exempt status under FLSA rules, but yes there is a way to report these additional hours

15 How should facilities report hours for staff who are attending training? For example, a CNA might work in the morning for 4 hours with residents and then have 3 hours of in-service training in the afternoon. If the direct care staff (e.g. CNA) attending training (either onsite or offsite) is not available to provide resident care, the hours that the nurse is in training should not be reported. If another staff member is called in to fill in for a nurse that is away for training, the hours for the called-in nurse should be submitted. However, the hours for the nurse in training may not be submitted. 29 With the limitation of 5 MB, are we going to be able to upload multiple files for that same facility, or are we going to have to break it down if it goes over 5 MB? Can the file size limit be increased? You can submit multiple ZIP files, if your ZIP file ends up being over 5 MB. XML files compress very well so we don t see the 5 MB limit being an issue but you can certainly submit multiple ZIP files if you need to. You can also submit multiple facilities within a single ZIP file. A 5 MB file is a pretty large file so we re not sure, at this point, if people will be exceeding it, we will monitor and determine what we might need to do in the future

16 After we submit our PBJ data what is the turnaround time to know whether or not it was accepted? Depending on the size of the submission file, most electronic submission turnaround times will be within minutes, however, if we reach peak volumes, turnaround time for submission validation make take up to 24 hours 31 Actual Day Worked We have several locations that do not break at midnight but consistently break at shift changes Hours should be recorded for each individual day. So, for example, if you are reporting on 3/31, any hours worked after midnight on 4/1 would need to be reported for the period beginning 4/

17 Are You Prepared for the Payroll Based Journal (PBJ) Process? 33 17

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