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Long-Term Care Facilities and Payroll-Based Journal Reporting: What You Need To Know

Posted by Jack Wilkinson on Wed, Apr 20, 2016 @ 08:45 AM

By Jack Wilkinson

OVERVIEW

As a requirement of Section 6016 of the Affordable Care Act, beginning July 1, 2016, Long-Term Care Facilities will be required to submit direct care staffing information electronically to the Centers for Medicare and Medicaid Solutions (CMS). This information will be based on payroll and other auditable data; agency and contract staffing are included in this mandate. The change is designed to reduce fraudulent reporting, thus improving transparency and quality of care.

To assist in the collection of this information, the CMS has developed a system that facilities can use to submit data. The Payroll-Based Journal (PBJ) will allow staffing and census information to be collected more consistently and frequently, with a higher degree of accuracy. The data collected, when combined with client census information, can then be used to report the level of staff in each nursing home and report on employee turnover and tenure.

The types of information collected will include resident census and case mix data, information on staff employment and turnover, categories of work performed by staff, and hours of care provided by employees for each client. Facilities will be required to specify whether individual staff are employed by the facility or provided under contract or through an agency. The categories of work will include a labor code, job code, and description of services provided by or associated with each employee. In a nutshell, facilities will required to account for the daily activities of every direct care worker.

ENFORCEMENT

These new reporting requirements increase the disclosure and reporting obligations Long-Term Care providers have to the CMS and present new compliance challenges to the personnel responsible for facility staffing. Reviewing and understanding these requirements will be critical for LTC providers to avoid punitive actions.

The CMS will have the authority to impose financial penalties on facilities that are not in compliance. To enforce these rules, the CMS will audit data submissions and look for facilities¬† providing inaccurate information. In a memo released mid-March 2016, the CMS stated “as providers are adjusting to this new requirement, we may refrain from imposing enforcement remedies…Additionally, we will provide feedback mechanisms to providers, such as warnings, that will help facilitate compliance with this requirement”.¬† Nevertheless, it is in the best interest of Long-Term Care providers to implement a plan for accurately providing the required data to the CMS in a timely manner.

REPORTING

There are two methods LTC facilities will be able to transfer the required data to the Payroll-Based Journal.  The first, manual entry, will take time and expose the provider to compliance risk in the form of date entry error. The second method, Data upload, is preferable as it can simplify the electronic PBJ reporting and reduce the administrative burden associated with this task. Many payroll and/or time and attendance systems will be able to generate a file that staff can then upload to the PBJ. Some platforms will even have tools and links to automate this process.

As with any compliance issue, the best strategy is to plan in advance. Set new protocols and procedures and make sure staff are trained and ready. If you have questions regarding the new reporting requirements or would like to learn about the tools available to simplify the reporting process, feel free to contact us anytime.

About Jack

Jack Wilkinson is the Director of Marketing at TruPay, a national provider of payroll and HR services recognized for their best-of-class customer service and cutting edge technology. Jack has over fifteen years experience in sales and marketing, specializing in business-to-business brand development and positioning. He is an avid jiu-jitsu practitioner and teaches classes in his spare time.

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