LeadingAge has recently received questions regarding the use of off-site staff in nursing homes, such as off-site Minimum Data Set (MDS) coordinators. A recent Centers for Medicare and Medicaid Services (CMS) update to the Payroll-Based Journal (PBJ) Policy Manual and FAQs clarified that only hours worked on-site are permitted to be recorded in PBJ. While off-site staff may be used for administrative tasks, these hours may not be recorded, even for nurses with administrative duties.

Also recall that while off-site nurses may perform coding and transmission of MDS data, nursing homes must continue to meet assessment requirements, which include direct observation and communication with residents and collaboration with the inter-disciplinary team. Additionally, any off-site staff performing duties for the nursing home must be licensed to practice in the state in which the nursing home is located. This means that off-site MDS coordinators must be licensed in the state(s) of all nursing homes for which they are coding and transmitting data. Questions about MDS tasks and scope of practice should be referred to the state Resident Assessment Instrument (RAI) contact.