Note: This is a reprint of a story written by Dr. Cheryl Phillips and published by LeadingAge on Dec. 6, 2016.

The Payroll-based Staffing Journal, affectionately known as “PBJ”, was rolled out for nursing homes by the Centers for Medicare and Medicaid Services (CMS) earlier this year to meet the requirements stated in the Affordable Care Act. The first mandatory report period began July 1, 2016 with the report submission due no later than November 14, 2016.

LeadingAge has long supported the concept of electronic staffing data. We know that our members often have higher staffing ratios that lead to better quality. According to a GAO report, nonprofits tend to have higher than average staffing ratios. We also recognize that with the emphasis the CMS 5-star Nursing Home Rating System places on staffing, it is essential to have a process that is accurate and auditable.

Does the current PBJ hit the mark? We don’t think so. In a letter to CMS Administrator Andy Slavitt, we laid out a list of concerns, all of which have proven to be valid post-PBJ rollout.

Common issues we have heard from our members include:

  1. How do we address time worked, rather than time paid for exempt staff?
  2. How do we capture the required data from contract providers?
  3. Given that census data is only captured for the last day of each month, how does that accurately reflect the census and staffing needs for an entire quarter?
  4. Many of our providers have moved towards a person-centered model of “universal workers”, yet there is no mechanism in this PBJ system to capture their work and hours.

These are just a few of the elements of the current PBJ program that need to be addressed and changed. We don’t want to go back to the flawed and potentially inaccurate 671 forms for nursing home staff level reporting, but we also don’t believe the current staffing reporting comes close to working for our members, for CMS, and most importantly, for consumers to understand.

As we look into 2017, with new changes in the Administration, fixing PBJ is high on our action and ask list. We appreciate all your comments and questions regarding the status of PBJ and promise to keep you informed of our progress in making it better.

SDAHO members were recently surveyed about post-PBJ implementation and reported spending up to 15 hours per month complying with PBJ requirements, equating to as much as a $3,000 monthly impact. Member concerns are similar to those outlined by Dr. Phillips, noting also that PBJ efforts divert staff time away from resident care and detract from innovative staffing models that are necessary to address workforce shortages and continue to deliver high-quality care. SDAHO has remained actively involved in advocacy efforts with LeadingAge to highlight the flaws in the PBJ system.

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