Garbage in, garbage out, right? We have all heard that one before! Well, it appears it may apply to PBJ staffing data too. Nursing homes are required to submit staffing information to the Centers for Medicare & Medicaid Services (CMS) through the Payroll-Based Journal (PBJ). CMS and others then use that information to evaluate staffing levels, measure performance, identify potential noncompliance, and develop staffing measures. The problem? What happens when the information going in isn’t accurate?
According to a recent HHS Office of Inspector General audit, not all registered nurse staffing hours reported through PBJ were supported by documentation. OIG reviewed a sample of RN staffing hours reported for March 2024. Of the 100 items sampled, 45 included a net total of 748.5 unsupported hours. Another two items included 336 hours that auditors could not verify because the nursing homes did not provide supporting documentation.
And here is where it gets interesting. Based on the sample, OIG estimated that nursing homes reported approximately 938,000 unsupported RN hours for March 2024. That represented about 5% of the RN hours in the sampling frame and involved approximately 53,000 RNs. Why does that matter? CMS, consumers, regulators, and other stakeholders rely on PBJ information. If the data aren’t accurate, the picture they see may not be accurate either.
So, what happens now? OIG made several recommendations to CMS. These included using the audit results when selecting nursing homes for follow-up audits, verifying corrective actions from previous audits, educating nursing homes on updated PBJ guidance, and communicating common audit findings to providers. The issue was also highlighted by McKnight’s Long-Term Care News, which looked at reporting errors and the potential for tougher audits to improve PBJ reporting.
Bottom line, PBJ staffing data is only as reliable as the information submitted. When was the last time you reviewed your PBJ process? Do the hours you report match your payroll and other supporting documentation? More importantly, could you prove it if an auditor walked through your door tomorrow?
Take some time to review your process, educate the people responsible for submitting the data, and make corrections before someone else finds them for you!
Stay well and stay informed!
