90 days, give or take, may sound like a lot of time, but when tackling something like PBJ reporting, it’s actually just around the corner. This blog will help you to identify the 8 tasks providers need to complete in order to be ready.
In the recent blog, published March 15th, we highlighted PBJ reporting requirements. We emphasized that reporting automation is vital to help providers, like you, not “waste critical time building reports and checking data.” However, automation is only as good as the data collected. So, here are 8 steps we recommend you take to fully leverage the PBJ reporting requirement:
- Go automated. Automated reporting tools, such as primeVIEW’s PBJ reporting tool, takes the data processing and reporting preparation time down to a minimum. It’s a no-brainer. With today’s advanced data processing technology already available, why reinvent the wheel or, worse yet, do it manually? Remember – it must be auditable and mistakes can be costly.
- Know the reporting requirements. Who does CMS consider to be direct care staff? The criteria involves individuals, including agency/pool/registry and contract staff who:
- Have interpersonal contact with residents or resident care management (This includes medical directors and consultants.)
- Provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well being
- Note: Physical plant maintenance and upkeep staff are not considered direct care staff
- The PBJ reporting system set-up requires four items
- Unique employee ID – avoiding any personally identifiable information (no social security numbers)
- Hire date – whether directly employed by the facility or under contract, this is the first date of employment by the facility and payment for services delivered at the facility
- Termination date – whether directly employed by the facility or under contract, this is the last date of employment by the facility and payment for services delivered at the facility
- Pay type code – identifies whether the staff member is an exempt or non-exempt direct facility employee or a contracted employee
Tracking this can be complicated. An employee’s job responsibilities can change throughout the day. Report hours worked based on each employee’s primary role tied to the employee’s position and shift. To make this somewhat easier, you may want to work with your staff scheduling, time and attendance, and payroll vendor(s) to see if job code assignment can be automated.
- Know what doesn’t count. Here are some things that CMS identifies that you should not count.
- Hours paid for any leave or work-related absence
- Overtime for exempt staff (ex: 40 hours per week hours paid, not hours worked)
- Hours that are billed directly to Medicare
- Hours for services provided to residents in non-certified beds
- Know what counts. This includes hours that your time and attendance application tracks for facility direct staff. You also need to track the following possible scenarios:
- Contract and agency
- Corporate staff who may be filling in for a staff memeber whose roles meet the CMS job categories
- Salaried staff who don't use the time clock
- Be reasonable. Now that’s what we would like to say to CMS, but actually that is what CMS is advising how your tracking and allocation systems need to be – reasonable – in accounting for, calculating, and reporting direct care hours. Keep in mind that an audit will likely review payroll and invoices tied to contracts.
- Plan carefully. Your team can work with the vendors mentioned above to create as audit-proof a set of procedures as possible. The plan should include objectives with a July 1st deadline for having all components in place.
- Staff according to needs. Flat PPD direct care budgets are great, but they are not usually responsive to aggregated resident needs. Check staffing levels every day and adjust accordingly to call-offs, time-off requests, no-shows, and the dynamics of census, activities, acuity, and workload.
Decide now on an auditable system to identify and retrieve those hours. Test. Test. Test. And learn. Then implement. This process begs another blog, but you get the idea. It will take time to prepare, but it will be well worth it.