New CMS Staffing Data Requirements

Transcription

1 New CMS Staffing Data Requirements PBJ may be hard to swallow! Lori Brunholtz, CPA Managing Director, BKD, LLP

2 Staffing Data Collection ACA requires facilities to begin regularly submitting staffing & census information electronically Direct Care including agency & contract Specific categories RN, LVN, CNA, therapist, & other medical personnel Resident census & case mix Capture employee turnover & tenure Report hours of care Auditable data Uniform format 2 Staffing Data Collection CMS developed the Payroll-Based Journal PBJ FY2016 SNF PPS Proposed Rule April 2015 FY2016 SNF PPS Final Rule August 2015 PBJ data to be submitted through QIES Voluntary October 1, 2015 Mandatory July 1, 2016 Quarterly submission Data will eventually be used in 5-Star Quality ratings Not until after FY2016 Continue to complete the CMS-671 form for staffing during survey until transition to PBJ data 3

3 Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html 4 Definition of Direct Care Staff Per CMS Direct Care Staff are those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well-being. Direct care staff does not include individuals whose primary duty is maintaining the physical environment of the long term care facility (for example, housekeeping). 5

4 Detailed Staff Information Individual employee IDs Hire date Termination date Pay type exempt, non-exempt, contract Labor category primary role Hours split if multiple roles performed Enter each employee s hours worked DAILY Night shift hours spanning midnight must be split EXCLUDE paid leave time, inservice & training EXCLUDE paid meal time Short breaks throughout the day may be included 6 Detailed Staff Information Salaried employees report only base hours, even if more hours worked Medical Directors, other specialists & contractors, corporate personnel reasonable methodology for reporting facility time related to resident care DO NOT report attending physician or patient care time that the physician or contractor can bill for separately Exclude non-snf/nf time (hospital, ALF) Exclude volunteers 7

5 1 Exempt 2 Non-exempt 3 Contract Unique identifier do NOT use SS# or Employee Name If contract or agency, first day at the facility If contract or agency, last day at the facility, if known. If unknown, leave blank.

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7 Staffing Data Collection 1 of 5 pages of categories in Table 1 PBJ Manual

8 Staffing Data Collection 2 of 5 pages of categories in Table 1 PBJ Manual

9 Staffing Data Collection 3 of 5 pages of categories in Table 1 PBJ Manual (Red text indicates change from previous version of the Manual)

10 Staffing Data Collection 4 of 5 pages of categories in Table 1 PBJ Manual

11 Staffing Data Collection 5 of 5 pages of categories in Table 1 PBJ Manual

12 Detailed Census Information Month-end snapshot only Only count residents in facility on last day of the month By payer Medicare, Medicaid, Other

13 Staffing Data Collection Data can be uploaded electronically interface must be in XML format technical IT specifications on CMS PBJ website Due 45 days after each quarter end Submissions/corrections accepted after deadline, but not used for staffing measures Data also viewable through CASPER PBJ data Audits to be conducted by individuals or entities who are subject matter experts in this area 16 Getting ready Download PBJ Policy Manual Review Job Titles & Labor Categories Create separate accounts within each department for non-worked pay PTO, vacation, sick, holiday, inservice, etc. Evaluate potential electronic interface capabilities of your time & attendance system or your payroll vendor Determine how to capture non-payroll contract & agency time Medical director, therapists, pharmacist, dietician, phlebotomists, agency staff, etc. 17

14 Getting ready Start accumulating and setting up individual employee & contractor information ID numbers, hire dates, pay type Develop internal policies to review, reconcile & verify accuracy of data entered Questions can be submitted to CMS at 18 Getting ready Register for access to PBJ system Obtain user ID for PBJ users Obtain PBJ provider ID for CASPER & PBJ system access Review PBJ training modules on QTSO e-university Log in and start entering data 19

15 Time & Cost Burden CMS estimates: Facilities with automated payroll system $500 - $1,500 upfront plus $500 - $1,500 maintenance cost per year 1 hour of staff time per week Facilities entering manually 4 hours of staff time per week Initial year - $4,100 to $6,800 Subsequent years - $2,700 to $4,200 To help mitigate potential cost for facilities, we [CMS] will be providing a system for facilities to enter and submit data manually at no cost. 20 Staffing Data Collection Facilities that fail to submit accurate, verifiable data will be considered noncompliant and subject to enforcement actions by CMS submission of staffing information is a condition of participation for Medicare or Medicaid 21