On November 1, the Centers for Medicare & Medicaid Services (CMS) released Payroll-Based Journal (PBJ) data to the public through files posted online. These files contain preliminary data submitted by providers for the first and second quarters of calendar year 2017. CMS will continue to publicly post data for subsequent quarters. Any provider that did not submit data prior to the submission deadlines or submitted data that failed to pass quality checks is not included in the public use file (PUF). These providers are flagged on Nursing Home Compare (NHC).  

What you should know

The information presented below is based on the initial analysis that AHCA has completed on the PUF. PBJ data is only reported for 89% (13,483) of providers nationwide. The providers not included are missing either because they failed to submit the data or because their data appears to have significant errors. More information on the exclusion criteria can be found here. The data is presented aggregated at the facility level for each day. It contains hours per day for the following categories: director of nursing, registered nurse, licensed practical nurse, licensed practical nurses with administrative duties, certified nurse aides, nurse aides in training, medication aide/technician. The data also include daily resident census calculated from the MDS. 

Initial calculations by AHCA of the data posted this week shows the following hours per resident day for the various staffing categories. CMS has indicated they will generate a new set of measures and use a new risk adjustment methodology for the PBJ data.  AHCA will continue to inform you as we learn more. At present, it is not clear how CMS will translate this data into the Five-Star Rating or any other calculations. AHCA will continue to advocate for the meaningful and appropriate use of this data.

Table 1 below represents PBJ data from second quarter 2017. You can compare your second quarter 2017 results to the national median, 25th and 75th percentiles listed in this table. This will tell you, without risk adjustment, if your staffing levels are higher or lower than half of other SNFs (compare to median) or to at least 75% of other SNFs or 25% or other SNFs (the 25th and 75th percentile rates, respectively).   

Table 1: PBJ Data, Second Quarter 2017

As CMS notes, it is not expected that data from the PUF will match data reported on Nursing Home Compare, nor should the two data sets be compared. Each of these data sources is unique and they should not be compared for several reasons including:  

• The CMS-671 data reported on Nursing Home Compare is only captured for a two-week period prior to a center’s annual survey, which occurs at a different time for each center; on the other hand, the PBJ data is captured daily.
• The definitions for some of the job categories are different in the two sources.
• The PBJ data only allows for facilities to submit hours that staff are paid to work. This means capping hours at 35 or 40 hours per week (typical work week), which impacts salaried employees who work more than the typical work week such as nurses and directors of nursing who cover extra shifts or spend extra time at the end of the day helping with patient care. 

Resources to help

AHCA will continue to advocate on behalf of our members to improve this system and provide updates on PBJ as they become available.

In the meantime, members are encouraged to submit their PBJ data frequently and check its accuracy via the available CASPER reports. The next PBJ reporting deadline is November 14, 2017 for the reporting period July 1-September 30. 

Members should pay attention to making sure all discharges have an MDS discharge assessment completed. Not completing an MDS discharge assessment will make your daily census look higher than actual, which will cause your staffing hours per day, to appear lower than they actually are. 

Please contact the AHCA PBJ team with any questions.