When choosing long-term care (LTC) facilities, patients and families seek providers they believe will deliver the best possible care. However, they no longer turn to family and neighbors for word-of-mouth reviews but to star ratings from Centers for Medicare & Medicaid Services (CMS).
Ratings can make or break a provider’s reputation with the coveted Five-Stars representing the gold standard in post-acute and long-term care. Achieving the highest Five-Star Rating requires proving you adhere to rigorous health inspections, staffing, and quality requirements.
You cannot earn and keep all Five Stars unless you can prove you properly staff your facilities 3 shifts a day, 365 days a year despite changing schedules and patient demands. CMS started routinely auditing long-term care facilities a couple of years ago after initiating a pilot Payroll-Based Journal audit program. Today, audits are a reality. In many states, facilities must be prepared for surprise audits from state regulators as well. If you can’t demonstrate compliance quickly, you can incur sanctions for Payroll-Based Journal noncompliance as well as tarnish your rating.
Payroll-Based Journal reporting enables you to produce the staffing data that supports CMS requirements.
Here are a few tips to help you land and keep a Five-Star Rating.
Know what CMS wants CMS uses Payroll-Based Journal data to determine each facility’s staffing measure on the Nursing Home Compare tool (Medicare.gov) and to calculate the staffing rating used in its Five-Star Quality Rating System. Originally, CMS used staffing measures derived from the CMS-671 form and case-mix based on Resource Utilization Group data or RUG-III but no longer requires you complete the staffing portion of CMS-671.
CMS combines Payroll-Based Journal data with resident census derived from Minimum Data Set (MDS) assessments, and the case-mix based on RUG-IV. Listen to CMS representatives and Payroll-Based Journal experts discuss their priorities during a SmartLinx webinar.
Understand Payroll-Based Journal format requirements
The mechanics behind Payroll-Based Journal requirements fall into three basic categories:
- Census, which is currently optional.
Each category features key information you must include and may include optional subcategories, such as employee hire date and termination date.
The annual Long-Term Care Survey Process (LTCSP) required by CMS has become much more granular than it used to be. Originally, CMS required you be able to produce a summary-level report for any given two-week period. Now you must be able to produce detailed staffing data for every day in the. Daily reporting details must be done at the employee level. Watch 7 Secrets to PBJ Success.
For example, you must report on each employee by day and include the following elements:
- All staff, including employees and contractors
- All hours worked and paid
- Reporting that’s based on the positions worked
- Reporting that’s based a midnight day break
- Meal deductions for all shifts 8 hours or more
- Data that is auditable and verifiable
Remember to map your organization’s positions to the list of standard CMS Job titles and be sure to match the position based on the true nature of a person’s work rather than the title alone.
Prepare for a compliance audit
Since compliance audits are now the norm rather the exception, you must be ready to demonstrate compliance at a moment’s notice. Facilities with significant inaccuracies between the hours reported and the hours verified will receive a one-star staffing rating. This, in turn, will drop the facility’s overall (composite) rating by one star for a quarter. See how Greek American refuted a compliance allegation in moments.
Be sure to avoid these common errors to avoid when submitting Payroll-Based Journal data:
- Failure to exclude time for meal breaks
- Failure to assign each employee a unique identifier (ID)
- Failure to submit MDS assessments in accordance with 42 CFR §483.20 and the resident assessment instrument (RAI) 3.0 User’s Manual
- Failure to exclude hours for staff providing care to individuals in non-certified areas of a larger institution or institutional complex that houses the certified facility
- Failure to respond promptly to the audit contractor if contacted for an audit
Understand the process
Keep in mind, ratings can take time to judge. Even when you fully comply with CMS staffing requirements and demonstrate it by submitting perfect Payroll-Based Journal reports, you may not see an immediate impact on your Five-Star Rating. CMS will review your reports and compare it to other facilities as well as their criteria before issuing a new rating. If you suffered from below average Five-Star Ratings in the past, you may need to wait for multiple quarters to receive your desired rating.
While you can’t change the data you’ve submitted in the past, you can make sure the data you submit in the future is clean, accurate, complete and timely.
Compliance does not happen magically, so you need to make sure you have every shift filled with the appropriate person. That is not an easy task. Proactive scheduling is one of the most important ways to ensure compliance.
Optimizing your scheduling system and integrating it with time and attendance can also help you stay compliant. When you link your attendance and scheduling systems with your Payroll-Based Journal system, you can quickly produce reports during a surprise inspection.
In between deadlines, is also a perfect time to take advantage of predictive analytics and predictive scheduling to prevent understaffing. When it comes to Payroll-Based Journal, you can’t afford a miss as it could result in one less star in your rating. An integrated scheduling, attendance and Payroll-Based Journal system can help earn and keep a Five-Star Rating.
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