• Payroll Based Journal

    Friday January 8, 2016

    In accordance with Section 6106 of the Affordable Care Act facilities are required to electronically submit staffing information to drive accountability effective July 1, 2016.

    Providers will be required to submit their staffing and census data quarterly. They will have 45 days after the last day in each fiscal quarter to submit - making the due date for the first PBJ submission November 14, 2016

    Get Ready With These Five Steps:   

    1.  Identify & Classify All Direct Staff - all direct care staff (including agency and contract staff), does not include individuals whose primary duty is maintaining the physical environment (example housekeeping).
    CMS defines direct care staff as 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.

    · Create a Unique Employee ID - for each direct care employee; should not contain any personally identifiable information, such as a Social Security Number (SSN).

    · Hire Date - the first date of a staff member's employment and is paid for services rendered, either through direct employment or under contract. Note: Contract Employees -first date worked at the facility and billed for.

    · Termination Date - the last date of a staff member's employment and is paid for services rendered either through direct employment or under contract. Note: Contract Staff - the last date the facility communicates that the contract employee will no longer be providing services (either voluntary or involuntary).

    · Pay Type Code - categorizes the staff member as a direct employee of the facility (exempt or non-exempt), or hired under contract and paid by the facility. Note: non-exempt - entitled to overtime pay, exempt - not entitled to overtime pay, contract - individuals under contract and individuals who provide services through organizations that are under contract.

    2.   Assign CMS Job Codes - identifying and assigning a CMS job code to an employee for each and every shift to ensure a payroll-based reporting submission is accurate and complies with CMS requirements. CMS has defined 37 job Codes to be used when reporting direct care hours worked. Facilities should report the hours worked based on an employee/s primary function for that shift.

    There must be a job code attached for every hour submitted through the PBJ system. Job responsibilities can change multiple times throughout the day and CMS recognizes that most roles have a variety of non-primary duties that are provided throughout the day.

    Assign each position and shift a job code, this job code should be used and paired with the direct care staff including agency and contract staff, which works those shifts.

    See Attached CMS PBJ Version 1.0 Policy Manual Table 1: Labor and Job Codes and Descriptions.

    3.   What Should Be Counted, What Should Not Be Counted? - It is important for facilities to know what should and should not be reported in the PBJ when compiling a complete an accurate file for submission. CMS has provided situations where direct care hours worked should not be reported:

    · Hours paid for any type of leave or non-work related absence from the facility.
    · Any unpaid overtime (a salaried employee works 10 hours but is only paid for 8 hours).
    · Hours for services performed that are billed to FFS Medicare or other payer.
    · Hours providing services to residents in non-certified beds.

    One of the biggest challenges for submission of the PBJ will be to gather and aggregate staffing data from disparate sources. Direct care hours are usually tracked through time and attendance systems. The following situations could possibly be overlooked but should be reported:

    · Contract and Agency work.
    · Corporate staff at a facility performing task/duties that fit into a CMS job category (e.g. Regional Director fills in for the Administrator that's out on vacation or leave).
    · Salaried staff that do not clock in or clock out.

    4.   Create a Checks and Balances System - CMS provided examples of the difficulty facilities may experience in their ability to appropriately track and allocate exact hours.

    · For Medical Directors, it might be difficult to allocate the exact hours spent performing medical director duties as opposed to primary care duties.
    · For Consultants, it might be difficult to identify the exact hours a specialist contractor (e.g. non-agency nursing staff) is on-site.

    (Note: It is important for facilities to define their expectations within their service provider contract.)

    (CMS has stated that the hours reported should be based on payments made for services and be verified through payroll, invoices and/or tied back to contract).

    5.   Start Now and Be Ready - Your success will be determined based on staffing with the PBJ staffing measurements by implementing a proactive process to identify and adjust staffing levels. Staffing is a challenging process with constant shift updates including call-offs, time-off requests, employee no-shows, and fluctuations in census, activity, acuity and workload.

    Set up a process that allows staffing information to be easily accessed, create dashboards that identifies staffing requirements based on census, against budgeted hours. If gaps are identified adjustments should be made.

    CMS has identified staffing as a key component in delivering quality care and positive resident outcomes. They use staffing information in the Nursing Home Five Star Quality Rating System to help consumers understand the level and differences of staffing in nursing homes. CMS requires facilities to submit CMS Form 671 and CMS Form at the time of survey to calculate the Staffing Domain of the Five Star Rating System.

    Hopefully utilizing these 5 steps will help your facility achieve the staffing and management goals that will enable you to correctly document and report direct care hours worked.

     Payroll Based Journal

  • CMS Scheduled Extended Maintenance – March 16, 2016 – March 21, 2016

    Wednesday January 20, 2016

    Just a quick heads-up from the team at eHDS. See below for a notice received from CMS. Please plan accordingly!

    Please be aware that CMS has planned an off-schedule extended maintenance period for all of the national QIES systems, which include the MDS 3.0 Submission and CASPER systems, for Wednesday, March 16, 2016 beginning at 8:00 PM ET and continuing through Monday, March 21, 2016 at 11:59 PM ET.

    This makes for a 5+ day window where all of the national QIES systems will be offline and providers will be unable to transmit any MDS assessments or obtain reports. This also applies to vendors who submit assessments on the providers' behalf. CMS has started to post notices to the related application and support websites that encourage vendors and providers to take this downtime into account and plan their business around it.

    This information is also noted on your Care Watch home page. We recommend making sure your team is well informed and is planning for this scheduled downtime.

    For access to the original CMS notice, please click here. 

    eHealth Data Solutions