CMS Releases Electronic LTC Staffing Submission - Payroll-Based Journal Update
Staffing within long-term care (LTC) facilities significantly affects the type of care delivered to residents. In August 2015, the Centers for Medicare and Medicaid Services (CMS) amended the Requirements for Participation for LTC facilities to electronically submit staffing data to CMS. As of July 1, 2016, long term care facilities submit staffing data through the Payroll-Based Journal. Data submitted includes the number of hours direct care staff work each day, based on payroll and other verifiable information.
In a recent memorandum providing an update, CMS:
- Reminds providers that they have until the 45th day after the end of each quarter to submit data.
- Provides feedback on each facility’s data through their monthly Provider Preview reports.
- Informs providers that:
- The Nursing Home Compare website now reflects whether providers have submitted data by the required deadline.
- Providers that have not submitted any data for two consecutive deadlines will have their overall and staffing star ratings suppressed.
- Updates the data submission requirements related to hire and termination dates, and converted three job codes as optional for submission.
According to CMS, approximately 91% of LTC facilities submitted staffing data by the last deadline of February 14, 2017. Each facility is receiving feedback in their monthly Nursing Home Compare Provider Preview, which is available in each provder's CMS Certification and Survey Provider Enhanced Reports (CASPER) folder. The feedback includes analyses of the staffing data submitted by the facility for October 1, 2016 to December 31, 2016, that was successfully submitted by the deadline of February 14, 2017. The feedback includes:
- Whether a facility has reported nurse staffing information for each day in the quarter.
- Note: If a facility did not report hours for nursing staff for each day, CMS believes that may indicate that the facility has not submitted complete data.
- Whether a facility has reported over 80 hours worked for any one staff member over a one week period, or over 300 hours worked in a month.
- Note: While possible, CMS believe it is unlikely that a staff member works this many hours, and therefore this may indicate erroneous reporting.
- A comparison of the facility’s reported census information to a census calculated using Minimum Data Set (MDS) data.
- Note: CMS is exploring using this MDS data instead of using the facility’s reported census. This data can be used to calculate a census for each day within a quarter, instead of the census for only the last date of each month in a quarter, which is what is currently being collected. CMS believes this can improve accuracy and reduce provider burden.
CMS intends to provide additional feedback in future months, so providers can continue to improve the accuracy and completeness of their future submissions. Concurrently, CMS is developing an audit process that will include onsite and offsite audits to verify the accuracy of the data submitted.
StayAlert! will continue to monitor this topic and will publish addition information as it becomes available. Follow the link to the memorandum, below, to review the full CMS update.
Want to read the full alert and receive alert emails?