What is Payroll Based Journal Reporting?
Payroll Based Journal (PBJ) Reporting is required under Section 6106 of the Affordable Care Act (ACA). Under the ACA, long term care facilities must submit information about staff working in direct care. This includes agency and contract staff.
To deal with this type of reporting, the Center for Medicare and Medicaid Services (CMS) created the PBJ system. This allows participating companies to submit data
- electronically by uploading an XML file (file size limit 5MB).
- by manually entering the data into the CMS system.
- using a combination of both.
Since October 1st, 2015 PBJ submissions were optional. However, submissions became mandatory on July 1st 2016.
PBJ reporting requires a high level of detail and accuracy in the data provided. It has brought a new level of transparency to long term care facilities which is a positive outcome for all stakeholders. However, the level of data required means that for many facilities, the number one priority now, is ensuring their time and attendance and HR management systems are up to the task. Should these fall short, PBJ requirements have the potential to cause significant strain on employees and impact on patient care.
What kind of work is captured in PBJ?
Direct care staff are defined by the CMS as anyone that uses interpersonal contact or is involved in residential care management to provide care and services that allows the recipients to attain or maintain the highest achievable mental, physical, and psychological health and well-being.
Direct care does not include individuals that are responsible for the upkeep of the physical environment of the facility.
The CMS has defined 40 job descriptions that each have a Labor Category Code and Job Title Code. Staffing hours need to be reported per day per individual staff member under the correct labor category and job title codes.
All of the staffing categories and job titles can be found in the CMS Long Term Care Policy Manual in Table 1.
What is the CMS trying to achieve with PBJ?
The PBJ staffing reports will bring an increased level of accuracy, transparency and validation to the direct care industry.
Each company has 45 days from the start of a new quarter to submit payroll data for the previous quarter.
All the details of what exactly companies are required to submit relating to PBJ can be found on the CMS website.
What type of information is recorded in the PBJ?
Once the company has completed the registration process to facilitate filing a PBJ there are several data points required for each individual registered employee.
- Employee Unique ID
- Hire date
- Termination date
- Pay type code
The information required for direct care workers are
- The work day and date
- The job category code
- The job title code
- The hours worked per day/date
It is important to note that if a contractor or individual is paid directly by Medicare, those hours cannot be reported within your PBJ submission.
Treatment of night shifts
The CMS requires hours worked to be prescribed to the actual date they are worked. In the case of a night shift that starts at 22:00 on one day and finishes at 06:00 the following day, this would require 2 entries – 2 hours for the first day and 6 hours for the second day.
Performing multiple duties
If an employee has different duties to perform in a day and your system can record the change in duties CMS allows you record and submit this data.
For example, if an employee clocks in and performs four hours of Therapeutic Services as an Occupational Therapist and then clocks out for their meal break that should be recorded under the appropriate labor category and job title codes. When they clock back in and perform Therapeutic Services as an Occupational Therapy Aide this requires different labor category and job title codes.
Companies can only record up to 40 hours for exempt, salaried staff. If an exempt employee works 50 hours, they can only record 40 hours work under PBJ as they will only be paid for 40 hours work.
Non-exempt staff can claim overtime for extra work and this can be recorded under PBJ.
Will the public benefit from the data that is recorded?
All the data being collected through the PBJ system will go towards creating the 5 Star Rating system for direct care providers. Facilities are graded on
- Health inspections – based on physical inspections of the facility
- Staffing – based on the PBJ data input into the CMS system
- Quality measures – based on a select set of clinical data measures
- Overall Rating – based on the facility’s results in the above
If a company fails to meet the deadline for submission they risk losing their overall and staffing star ratings on the CMS Nursing Home Compare site.
The PBJ systems also record some Census Data.
At the end of each month a direct care facility must submit the number of residents whose primary payer is
- Other: neither of the above
PBJ is essentially an exercise in timekeeping. The more reliable your timekeeping system, the more reliable the data you provide to the CMS system will be.
Companies need to ensure that every hour an employee spends working in direct care is recorded as failure to do so could impact your 5 Star Rating.
Our Time and Attendance system has several clock-in/out options that ensure employees can record their time worked accurately and easily.
- Web Based Clocking – employees can login using a web-based self-service application.
- Biometric Time Clock – clocking in and out is recorded by simply placing a finger on a biometric scanner.
- Text Alert Clocking – employees send a text message containing their ID number to a virtual mobile phone which is then transferred to the Mitrefinch attendance system.
- Mobile Phone Clocking – employees download an app and record hours worked on their mobile device.
- Land-line Clocking – employees use a landline to call a 1-800 reverse billing number to clock in and out.
For a company’s PBJ submissions to be compliant they will need to be able to record when and where the employee administered care and how long it lasted for. It is vitally important all the information submitted contains the correct job category and job title codes.
If the timekeeping system is not linked to the payroll system this could complicate your process and require manual intervention.
Mitrefinch systems are cloud-based solutions that allow you to streamline your processes and procedures. The system allows employees to manage their time directly reducing the number of touchpoints between recording, storing and processing the data.
One key strength of Mitrefinch solutions is that the reports and outputs are totally customizable and integrate seamlessly with third party HR and payroll software programmes.
One of the biggest headaches in dealing with PBJ is recording non-standard activity of staff.
As mentioned previously, night shift work will need to be recorded as 2 separate date entries.
Equally, if an employee performs one type of role in the morning and a different in the afternoon, this requires different job category and job title codes.
In addition, for salaried staff you can only record the 40 hours work they will be paid for regardless if they work extra hours to complete a task.
Mitrefinch systems can automate even the most tedious of manual processes. Rules can be created within your application to make sure all employee data is recorded in accordance with PBJ guidelines. Our systems are flexible and adopt to change too.
The easiest way to ensure compliance with the Labor laws regarding PBJ is by having a robust Time & Attendance System.