TOP 9 THINGS TO REMEMBER ABOUT PBJ

Updated: Feb 6


Accurate PBJ reporting can impact your Five-Star rating, referral patterns, census stability and overall long-term viability. The deadline for PBJ submission is February 14, 2020. Here are the top things to remember about PBJ.


What threshold do providers need to be aware of for monthly hours of a single employee?

CMS will be monitoring the PBJ data to identify if an individual employee has worked more than 400 hours in a single month. Likely, this will only be investigated during an audit, but could imply the employee is being overworked or the SNF is overstating hours.


What threshold do providers need to be aware of for quarterly hours of a single employee?

CMS will be monitoring if an individual employee has worked more than 1,200 hours throughout the quarter. Again, this will likely only be investigated during an audit and carries the same implications as the monthly threshold above.


What will CMS be monitoring for weekend coverage for direct care staff?

CMS will also be monitoring weekday vs. weekend hours per resident per day (PRD) coverage for direct care staff. CMS is now notifying state agencies and CMS regional offices with a list of facilities that report low staffing during the weekend, which could potentially raise audit concerns or trigger state surveyors to commence a health inspection survey during the weekend.


What is the deduction policy for meal breaks?

CMS requires the deduction of meal break time for all staff

  • For staff paid and/or unpaid at meal-times who work 8 hours shall deduct 30 minutes for meal-time

  • For staff paid and/or unpaid at meal-times who work 16 hours shall deduct 1 hour for meal-time


How should providers report hours for universal care workers?

Some facilities employ universal care workers who are typically certified nurse aides performing a number of duties, including direct resident care, food preparation and housekeeping services. Prior to this update, CMS has broadly explained how to report hours for staff performing these roles. CMS has now added language stating the following items:

  • Facilities must use a reasonable methodology to allocate the appropriate number of hours related to performing certified nurse aide duties. Employees who work across different levels of care (i.e. SNF, assisted/independent living) need to be allocated appropriately to only include SNF-related hours. Other duties, such as time related to dietary and housekeeping, shall not be reported as certified nurse aide hours.

  • Hours related to other duties above can be reported to housekeeping or other services, but are not required to be reported per PBJ guidelines.


What do providers need to assess for reasonable staffing levels?

The most important step throughout the PBJ process is to check the PBJ data for reasonability. SNFs should assess the direct care hours PRD being reported and compare it to the SNF’s budget and/or actual staffing levels.


What should providers do if the PBJ data submission was rejected?

Once SNFs submit their PBJ data into the QIES system, they should return to the QIES website to obtain the validation report, which will indicate whether the submission was “accepted” or “rejected”. If rejected, the SNF should find the cause of the rejection, correct it and resubmit the PBJ information until it is accepted.


Why is RN coverage such an important component of staffing data?

The biggest reason skilled nursing facilities (SNF) are downgraded to a 1-Star in the staffing component of the Five-Star rating system. SNFs that submit staffing data indicating there were four or more days in the quarter with no RN staffing, but on which there were one or more residents in the facility, regardless of reported staffing levels, will receive the rating downgrade.


How can star rating be impacted by Nurse Aide coverage?

SNFs that submit staffing data for any day in the quarter with no aide staffing, but on which there were one or more residents in the facility, regardless of reported staffing levels, will receive the 1-Star downgrade as well.


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