by Bridget Piraino, Vice President Marketing, SmartLinx Solutions
June 1, 2016
By now, most long-term care providers have heard about the new, mandatory “Payroll-based Journal.” Introduced under the Affordable Care Act, the Payroll-based Journal, or “PBJ”, report is required by the Centers for Medicare and Medicaid (CMS) of long term care providers that receive their reimbursements.
Starting October 2015, CMS has been accepting PBJ reports under a voluntary reporting program. Submitted via the “Quality and Improvement Evaluation System” portal, aka. QIES, long term care facilities have been encouraged to test out the system, and their own processes for gathering, verifying, and preparing PBJ data to be submitted.
CMS has been clear that they will not be using any of the data submitted during the voluntary reporting period. The idea has simply been to offer a means for nursing homes to prepare for mandatory reporting that kicks in on July 1st, 2016.
Voluntary Reporting – How Many Have Already Submitted PBJ Data to CMS?
Despite the voluntary reporting period ending soon, SmartLinx Research has discovered some surprising results in its research into PBJ readiness.
Very few of over 400 attendees of its recent PBJ webinar, “What You Should Know About Payroll-Based Journal Compliance, Management and Reporting,” have attempted to submit PBJ data during the voluntary reporting period.
Across the board, organizations of all sizes had yet to take advantage of voluntary reporting. In fact 89% of Large companies with over 20 facilities, 82% of Medium firms with 6-20 facilities and 85% of Small organizations with fewer than 6 facilities, to be specific.
PBJ Compliance Solutions – Buy, Build, or Manual Data Entry?
SmartLinx Research found that 38% of organizations plan to purchase a payroll-based journal solution, and a sizable 33% were still undecided on their approach. Only 18% currently plan to take the home-grown approach, and a mere 11% plan to enter employees daily hours by role manually using the CMS QIES system.
The bottom line is that nursing homes that have not leveraged the voluntary period may be in for a few surprises.
PBJ reports are much more than the 671 reports many facilities submit today. The Payroll-based Journal details direct care staffing by person, by day, by position worked. Facilities also need to submit start dates for everyone providing reimbursed direct care, including agency staff. To adequately capture and verify the data required to submit, particularly with regard to agency staff, process changes should be expected. Also, if an organization currently counts shifts that overlap midnight as being fully on the start date of the shift – they’ll now have to report for CMS each portion of the shift on the actual day worked. This should, of course, be reported using the job category and title codes provided by CMS, not their own codes.
An Integrated Approach
Leveraging a vendor solution that tracks hours worked across all types of staff and can produce a PBJ report with accurate, real-time information in just a few clicks, makes a lot of sense, especially for medium and large sized organizations. 44% of the SmartLinx Research survey respondents agreed, stating they plan to purchase a PBJ compliance solution.
SmartLinx has helped a number of its clients already submit PBJ reports to CMS using the WorkLinx ACA Director product. Available since the beginning of the optional PBJ reporting period, ACA Director enables users to configure staff, making on-demand PBJ reports available in just a few clicks.
See a demo of WorkLinx ACA Director for PBJ reporting:
Prepare Now! Mandatory Reporting Starts July 1st, 2016
Regardless of your approach to CMS PBJ compliance, it’s imperative to make a plan, and start implementing that plan as soon as possible.
Countdown to MANDATORY PBJ reporting, starting JULY 2016:
Learn more about Payroll-Based Journal Compliance, Management and Reporting:
Attend a SmartLinx PBJ Webinar in June.