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Reimbursement Alert

May 18, 2016

Electronic Submission of Staffing Data (PBJ)


The Kentucky Association of Health Care Facilities (KAHCF) and the American Health Care Association (AHCA) has kept members apprised over the past six months and prior on developments on electronic submission of staffing data, or Payroll Based Journal (PBJ) issues.  Early this year, AHCA's Mark Parkinson issued a letter to CMS requesting PBJ be delayed, due to PBJ being a "flawed system".  However, submission of staffing data will become mandatory effective July 1, 2016 and facilities have been encouraged to submit voluntary test data to ensure compliance.  Kentucky currently has over 35% of providers that have not registered for PBJ, according to a listing by state provided by AHCA.

On an Open Door Forum conference call, CMS provided the steps needed to register for PBJ data submission and included the web site containing updates and additional information on PBJ.  In March 2016, CMS issued a State Survey Agency Memorandum providing background information, resources available for providers and enforcement measures that could be taken.  Following the issuance of the Memorandum, AHCA provided a webinar giving additional information on direct care workers, required data submission and frequently asked questions.   Based on questions received, AHCA compiled a listing of FAQs for providers to utilize in preparation for PBJ implementation.

In April, the Association hosted a webinar for facilities, presented by Robin Bleier giving an overview of PBJ, resources for facilities related to PBJ, an overview of the PBJ draft policy and discussion of staffing categories.  Ms. Bleier also provided a more in-depth discussion of PBJ at the Quality Summit in Owensboro later that month.  The Association is working with Ms. Bleier on additional questions received from providers as they have begun the process of submitting voluntary data and working through time and attendance and payroll system requirements.  The AHCA recently issued a list of time and attendance vendors for PBJ data submission.  Please note neither the AHCA nor KAHCF attests to these vendors' ability to meet CMS requirements.  However, this listing may be useful to providers who need alternatives to meet CMS requirements.

If you feel an additional webinar would be useful prior to PBJ implementation or if you have PBJ questions, please email Wayne Johnson at the Association.  Questions received will be answered via a Q&A document that will be sent to member facilities.

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