Nursing Home Compare, Five-Star Transition to PBJ Staffing Data

Regulation | April 09, 2018 | by Janine Finck-Boyle

The Centers for Medicare and Medicaid Services (CMS) has announced the schedule for transitioning to the use of payroll-based journal (PBJ) data to report nursing homes' staffing levels on Nursing Home Compare and the five star quality rating system.

On April 6, 2018, the Centers for Medicare & Medicaid Services, (CMS), Quality, Safety and Oversight Group posted QSO-18-17-NH, a memo outlining the transition to the Payroll-Based Journal (PBJ) staffing measure to replace the data source currently used to post staffing information on the Nursing Home Compare tool.  CMS will begin using the PBJ data to calculate staffing measures for posting on Nursing Home Compare and in the Five Star quality rating system in April, 2018. The calculations will be based on the data for the 2017 calendar, Quarter 4 that was submitted before the February 14, 2018 deadline. 

CMS will continue to post on Nursing Home Compare each facility’s measures for nursing staff and physical therapy staff as the number of hours per resident per day.  This will be calculated by summing the number of hours for the relevant job categories submitted for each day of the quarter, and dividing by the sum of each day’s census within the same quarter. To calculate staffing ratings, each facility’s staffing measure (HPRPD) is adjusted based on the expected level of staff needed given the number and acuity of the residents in the facility.

In April 2018, CMS states they will update the staffing domain ratings methodology using the RUG-IV system.  Currently, RUG version III is being used.  CMS will establish new ratings thresholds based on the existing distribution of ratings among nursing homes.  More details will be forthcoming, on or before May 1, 2018, in the Technical User’s Guide.

As the transition moves forward, CMS is encouraging facilities to review the following items for potential errors:

  • Exclude time for meal breaks;
  • Ensure each employee has their own identifier(ID);
  • Submit Minimum Data Set (MDS) assessments according to the appropriate completion and transmission requirements;
  • Exclude hours for staff that are shared with other types of service providers;
  • Respond promptly to any audit contractor inquires.

CMS is clear that facilities that have significant inaccuracies between the hours reported and the hours verified will be presumed to have low levels of staff and this will result in the facility receiving a one-star rating which will reduce the facility’s overall (composite) rating by one star for a quarter.

The memo also reminds nursing homes of the requirement to have an RN on site at least 8 consecutive hours a day, 7 days a week under sections 1819(b)(4)(C) and1919(b)(4)(C) of the Social Security Act, and 42 CFR §483.35(b).  Facilities reporting 7 or more days in a quarter with no RN hours will receive a one-star staffing rating, which will drop their overall (composite) rating by one star. This action will be implemented in July, 2018 after the May 15, 2018 submission deadline for  2018 Calendar Quarter 1 (January – March, 2018) data. Prior to July 2018, facilities meeting this criterion will have an icon placed next to their name on Nursing Home Compare to indicate their status related to RN staffing.

CMS will continue to provide technical assistance to nursing homes to improve their staffing and data submissions. As a helpful tool, CMS encourages nursing homes to run CASPER reports prior to submission as well as reaching out to Quality Innovation Network-Quality Improvement Organizations. (QIN-QIOs)

Lastly, the memo outlines the removal of the staffing portion on the CMS-671 form.  Facilities will no longer be required to complete the staffing section on page 2 of the CMS-671 as of June 1, 2018.

CMS ends the memo with a three-page question and answer section outlining all the areas of the memo and details to improve the staffing measure on Nursing Home Compare as well as contacts for help in correcting inaccurate data.  In the future, CMS plans to develop additional measures like staff turnover and post on Nursing Home Compare.  For now, CMS plans to use the new data to inform the survey process and help both surveyors and facilities identify underlying root causes for any quality issues.