CMS has issued S&C 17-45-NH announcing its plans to make Payroll-Based Journal (PBJ) public.  On November 1st, CMS will post a public use file on https://data.cms.gov with PBJ staffing data timely submitted for CY 2017 quarters 1 and 2. The first public use file will include the total number of hours submitted for nursing services job categories for each day and the facilities’ census for each day in the quarter as calculated utilizing MDS submissions. It will only contain raw numbers that providers have submitted, no calculated measures. CMS will expand the type of data reported in the public use file in the future.

The release of the public use file in November will not directly impact the Nursing Home Compare website or the Five-Star Quality Rating System yet. CMS will continue to rely upon the CMS-671 form for the Five-Star Rating and to post information on the Nursing Home Compare website to indicate the status data submission by providers. However, CMS has stated that they may update the methodology to encourage more complete and accurate PBJ data submissions including potentially suppressing the overall and staffing star ratings on Nursing Home Compare.

Moving forward, CMS intends to utilize PBJ data to replace the current staffing measures in 2018. They are currently analyzing the data and working on a methodology to calculate staffing measures such as the level of hours per resident day and rates of turnover and tenure. These new measures will eventually replace the existing source and methodology for posted staffing information for the Five-Star Quality Rating System and on the Nursing Home Compare website.

CMS has determined that the daily census for the new staffing measures will be calculated from MDS data, not PBJ. Therefore, CMS is making the submission of resident census data in PBJ optional. CMS encourages all providers to ensure that they comply with the requirements found in Chapter 2 of the MDS RAI Manual so that their MDS census is calculated correctly.

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Rachel Monger, JD, LACHA is President/CEO. Rachel joined LeadingAge Kansas in 2011 as the Director of Government Affairs and has been a powerful voice for our membership ever since. Rachel is a Kansas licensed attorney and adult care home administrator. She received her bachelor’s degree from Bard College at Simon’s Rock in Great Barrington, MA, and her Juris Doctorate from the University of Kansas School of Law. Over the years, Rachel has served in many volunteer roles in her community and in the state of Kansas to support senior needs, aging services education, and community mental health services. She is also a member of the Board of Governors for the Kansas Health Care Stabilization Fund. As an award-winning trial lawyer, turned award-winning senior care advocate, she has spent nearly two decades passionately supporting quality of care and quality of life for Kansas seniors. When not at work, Rachel loves reading, crafting, volunteering with her church, and spending time with her partner Steven. You can reach Rachel directly at 785.670.8046.