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Assisted living directors and certified nurse aides (CNAs) working in life plan communities (formerly CCRCs) saw their wages increase during 2016, according to the new salary and benefits report issued by the Hospital & Healthcare Compensation Service (HCS) in cooperation with LeadingAge.

The 2016-2017 Continuing Care Retirement Community Salary & Benefits Report provides compensation data for more than 86,900 employees in 46 management and 53 non-management positions at 536 life plan communities.

Assisted Living/Personal Care Directors

Almost 60% of the life plan communities participating in the HCS research reported offering assisted living and personal care.

Directors of assisted living/personal care in these communities enjoyed an average pay increase of 2.29% in 2016, according to a report summary published by McKnight's Long-Term Care News.

The average national salary for these directors went from $69,758 in 2015 to $71,357 in 2016. During 2016, salaries for this position ranged from $58,178 to $83,990 across the country.

The HCS report documents regional variations in salaries for assisted living/personal care directors at life plan communities:

  • On the high side, average salaries in New Jersey, New York, and Pennsylvania ranged from $63,597 to $94,010.
  • On the low side, average salaries in Illinois, Indiana, Michigan, Ohio, and Wisconsin ranged from $51,824 to $74,861.

Certified Nurse Aides

Ninety-five percent of life plan communities employ certified nurse aides (CNA), according to the report.

Being certified translated into higher pay for CNAs working at life plan communities. HCS reports these national average hourly rates for aides:

  • $14.10 for lead CNAs
  • $13.03 for CNAs
  • $11 for non-certified nurse aides

The national average salary for CNAs increased 2.33% in 2016, according to the report. The national hourly rate for lead CNAs increased 2.05%, while the hourly rate for non-certified nurse aides increased 1.50% during that same period.

To encourage CNAs to become certified:

  • 13.78% of survey participants reported paying the cost of CNA certification.
  • 43.90% reported paying a premium for nurse aides who were already certified.

CNA pay also varied by core-based statistical area (CBSA):

  • CNAs in the Oklahoma City CBSA received the lowest pay: $10.99 per hour.
  • CNAs working in the Boston-Cambridge-Quincy CBSA in Massachusetts received the highest pay: $16.00 per hour.

About the Report

The HCS report presents compensation data from life plan communities in a variety of categories:

  • Revenue size
  • Total unit size
  • Geographic region
  • State
  • Core-based statistical areas (CBSA). CBSA data is new to this year’s report

The report also includes data on:

  • Fringe benefits
  • Turnover rates by department
  • Projected salary increases by department for 2016 to 2017

Purchasing the Report

The 2016-2017 Continuing Care Retirement Community Salary & Benefits Report is available to LeadingAge members for a discounted price of $250.

To order the publication, visit the HCS website or call (201) 405-0075.

The Bipartisan Budget Act of 2015 required Department of Labor (DOL) agencies to adjust civil penalties for violations on or before July 1, 2016.  Accordingly, the DOL published an Interim Final Rule on July 1, 2016 in which civil penalties for five DOL agencies, including the Occupational Safety and Health Administration (OSHA), will be increased substantially beginning with penalties assessed on or after August 1, 2016.  The jump in civil penalties results from a one-time “catch up” adjustment to account for inflation since 1990 when penalties were last increased.  Going forward, however, penalties will be adjusted on an annual basis according to the Consumer Price Index for all Urban Consumers.  The annual adjustment, however, will be limited to 150% of the amount then in effect. 

The table below summarizes the increases for OSHA penalties on or after August 1:

Type of Violation 
Current Maximum Penalty 
New Maximum Penalty

Serious
$7,000 per violation
$12,471 per violation

Other-Than-Serious
$7,000 per violation
$12,471 per violation

Posting Requirements
$7,000 per violation
$12,471 per violation

Failure to Abate
$7,000 per day beyond the abatement date
$12,471 per day beyond the abatement date

Willful or Rebated     
$70,000 per violation   
$124,709 per violation

DOL has made available a table outlining the changes for all five agencies covered by the July 1 rule.  

While the Centers for Medicare & Medicaid Services (CMS) have provided an updated manual (Version 2.1) for implementing their payroll-based journal (PBJ) ruling, nursing facilities have questions on certain situations that were given minimal guidance. For instance, specific PBJ reporting programs for time and attendance and payroll systems have not yet been fully developed to properly create the files needed to upload to the CMS PBJ entry tool. Similarly, therapy and other outsourced care providers have struggled to create tools that will automate the proper reporting of their time to their nursing customers. These situations have left nursing facilities uncomfortable about meeting the PBJ requirements by July 1, 2016, according to CliftonLarsonAllen.

Nursing facilities face software challenges

Reporting software is a common hurdle for many providers. Some facilities have received PBJ file creation programs from their time and attendance systems that have allowed them to successfully submit a practice submission for employee hours. A handful of third-party software providers have also tried to meet the market need with innovative programs that can accept a multitude of file formats from timekeeping systems for both employees and contracted care providers. A few of these programs can even calculate the proper time split between calendar days for those who work over a midnight cutoff. While there are some signs of progress, most nursing facilities still have work to do.

Successful implementation requires planning

PBJ implementation requires planning and executing a fairly long to-do list that will include tasks such as:

  • Plan in detail now for a July implementation, rather than focusing on the November 14, 2016, deadline for first quarter PBJ submissions.
  • Develop and document reasonable allocation methods for specific hours worked. This will alleviate the potential burden of daily time tracking for staff who do not spend 100 percent of their time working in the nursing facility.
  • Review and amend contracts with outsourcing firms to enhance the auditability of hours reported in PBJ.
  • Request contractors (especially therapy providers) to provide readable backup files of hours worked along with XML file formats and test the upload of these electronic files to the CMS PBJ tool.
  • Update job position codes and job descriptions to reduce errors in PBJ reporting.
  • Determine frequency of PBJ payroll data collection and upload (after each payroll, monthly, quarterly) and create a process that allows for easy reconciliation and auditability of payroll and contract records.

As nursing facilities move forward, several key concerns can be closely monitored by asking the following questions:

  • Are the files produced by your PBJ reporting solution accurate, and do they coincide with your latest CMS 671 reports?
  • Are you getting the proper credit for all the care and services you provide, and do you have tools that allow you to review your inputs and calculate your staffing ratios each time you upload PBJ data?
  • Do you have a backup plan for easily capturing and uploading time from contracted and outsourced medical or care staff if your providers are not able to provide an electronic file?
  • Have you accounted for all time spent in your community providing care, including staff who may spend time among several locations and do not appear on your community’s payroll?
  • Is the PBJ data you can currently provide auditable back to the proper documentation that connects to payroll (not just timekeeping systems) as required by CMS?
  • Will you provide the optional information requested by CMS PBJ regulations?

How we can help

Nursing facilities need to ensure that all of the components required by PBJ are addressed, and this requires consistent project management. If you are struggling with some of the questions above, CLA can help you understand your options, including how to outsource the reporting process. We provide PBJ readiness assessments and recommendations that can help organizations prepare for the PBJ data collection and submission process.

CLA professionals can help you:

  • Obtain a QIES log in
  • Obtain registration for PBJ
  • Review labor categories for direct care staff
  • Establish a unique ID for every facility and contracted employee
  • Assess and document the organization’s PBJ reporting systems for compliance
  • Establish a record of all direct care hours for the skilled nursing facility or nursing facility compliance
  • Evaluate outsourced solution(s) to fulfill this regulatory requirement

 

The PBJ requirements will require the time and attention of nursing facility leadership. The deadline is approaching fast.

Learn how to prepare for the PBJ requirements. Watch CliftonLarsonAllen’s webinar

Carl Moellenkamp, Director, Health Care, carl.moellenkamp@CLAconnect.com or 630-954-8112

This article was reprinted with permission from CliftonLarsonAllen.

With quality of care, financial performance and employee morale all directly tied to labor management, a focus on staffing can drive a competitive edge in 2016.

That's why we have put together a guide on staffing best practices that will allow you to tackle your challenges.

Read the following whitepaper to learn the actionable concepts such as:

  • How to identify staffing gaps and manage open shifts or call-offs
  • What to consider when using part-time and per diem staff
  • Why and how you should automate schedule creation
  • How to implement flexible staffing to meet changing demand
  • How to improve staff utilization and control overtime cost

 

 This article was reprinted with permission from OnShift. 

The first deadline for Payroll-Based Journal (PBJ) is looming. Mandatory collection of PBJ data begins July 1st. Submissions must be received by the end of the 45th calendar day (11:59 PM Eastern Standard Time) after the last day in each fiscal quarter in order to be considered timely – making the due date for the first PBJ submission November 14, 2016. As the deadline approaches, CMS and skilled nursing providers are still trying to clarify some of the policies associated with this new process.

In April 2016, an update to the Payroll-Based Journal Long-Term Care Facility Policy Manual was released. The major change in the CMS’ PBJ reporting policy manual was that two job title codes previously required to be reported are now considered optional: Clinical Laboratory Services Worker and Diagnostic X-ray Services Worker. There are now a total of 35 required job codes that must be reported. The policy manual update also provided clarity on other issues including how to report hours for physicians and medical directors, therapy providers, corporate staff, and staff in training.

The process of submitting Payroll-Based Journal data is certainly complex, and as the PBJ deadline gets closer, the pressure mounts for providers to implement solutions and processes that will ensure a successful submission come October. Here are a few items providers should be thinking about now to be ready for collecting data July 1, 2016.

Mapping Job Codes

For every hour that is reported in Payroll-Based Journal, CMS job codes must be attached. Each shift and position should be assigned a job code. Often times, providers’ job codes don’t directly align with those provided by CMS.

Providers should work to map internal job codes to those that CMS provides by position and shift. This job code should be used and paired with the direct care staff, including agency and contract workers, which work those shifts.

Collecting Agency/Contractor Hours

While many of the Payroll-Based Journal reporting requirement’s direct care hours can be collected within a provider’s time and attendance system, often contractor and agency hours are not.

Providers should look to implement a process to collect those hours as they occur to help ensure their submission is complete. Larger therapy contractors we work with have indicated they will supply providers a report of the direct care hours provided to each facility. However, smaller contractors and most staffing agencies cannot. Providers should collect these hours as they occur by checking in and checking out each worker and recording their time for proper submission.

Reviewing for Data Accuracy

Accuracy is crucial when collecting and submitting data for PBJ. CMS has indicated it intends to audit the information that providers submit. Submitting inaccurate data might even lead to citations or fines in the future.

It is important for providers to gather all direct care hours into a centralized location in a format that can be easily consumed. We recommend establishing a regular cadence for submitting data, such as a week or two after payroll. Rather than waiting until the end of each quarter, regularly submitting PBJ data to CMS will help you recognize and address discrepancies more quickly.

CMS Payroll-Based Journal Reporting Success

Several skilled nursing sites are ahead of the game. In fact, multiple OnShift clients were able to successfully collect and submit Payroll-Based Journal reporting information using OnShift’s new PBJ reporting software.

Lancaster Rehabilitation Center is one OnShift client that has completed a Payroll-Based Journal submission. With 293 licensed beds, they are Nebraska’s largest skilled nursing provider. Using OnShift’s Payroll-Based Journal Reporting software, Lancaster was able to collect and classify the needed staffing data and successfully submit a PBJ report to CMS.

“OnShift has been an ideal partner helping us meet the Payroll-Based Journal reporting requirement,” stated Amy Fish, Administrator, Lancaster Rehabilitation Center. “OnShift has simplified a very complex process. Their expertise in PBJ combined with user-friendly software has made the process much easier for us. I would highly recommend the use of OnShift to my fellow skilled nursing providers across the country to help them comply with the new PBJ reporting requirements.”

 

 

This article was reprinted with permission from OnShift.

 

One reason it’s such a big challenge is “5G,” a newly coined term that describes the working population that currently spans five generations. Stark differences exist among the generations, according to a recent white paper by University of North Carolina Kenan-Flagler Business School executives.

“Today’s workforce is decidedly multigenerational,” write UNC’s Dan Bursch, program director, MBA@UNC and Kip Kelly, director, UNC Executive Development. “It is comprised of five generations—Traditionalists, Baby Boomers, Generation X, Generation Y (or Millennials), and a smattering of Generation Z—whose life experiences have left indelible marks on their values and work preferences. This rapid and unprecedented demographic shift has many business leaders wondering how organizations will adapt to the ‘5G’workplace.”

Many of the senior living executives I have spoken with describe the challenges involved in managing a multi-generational workforce. For example, what drives millennials and makes them happy at work can look a lot different than what it takes to keep a Baby Boomer engaged and satisfied.

That’s not to say there aren’t other operational challenges, but many tie back to managing across these five generations. Here are 4 keys to addressing multi-generational workforce challenges in senior living.

 

  1. Understand the “5G” workforce.

    Each generation has its own preferences when it comes to work. For example, Traditionalists (the oldest workers in the workforce today) view work as a privilege and have strong work ethic. Baby Boomers are motivated by rank and wealth and tend to be extremely loyal to their employers. Gen Xers prefer managers who are straightforward, genuine and “hands-off.” Millennials are known for being digital and educated and gravitate toward meaningful work. Finally, Gen Z is the most tech-savvy as the youngest workers in the 5G workplace.

    Got all that? Start by understanding the 5G workplace and its different components. This will help you manage the challenges stemming from the differences among these generations.

  2. Communicate appropriately.

    Make use of technology to appeal to the younger end of the workforce, while gearing communications for the older workers as they prefer to receive them. According to Bursch and Kelly, this means giving Gen X communication informally and effectively and offering feedback opportunities to millennials.

  3. Encourage flexible management.

    Managing through workforce challenges requires a varied approach and is anything but one-size-fits-all. Effective leaders will be able to practice both hands-off and hands-on approaches, depending upon the workers’ preferences.

  4. Create programs that lead to collaboration.

    Start by understanding the ways in which the different generations bring knowledge to the workplace and encourage employees to share their knowledge with one another. “Baby Boomers and Traditionalists, for example, are used to a more ‘siloed’ knowledge sharing experience,” Bursch and Kelly say. Yet the younger generations prefer information that is shared transparently and freely. Ignoring these differences can lead to lost information and communication breakdown.

    Studies show organizations lose time and money when their workers do not get along—often the case when generational preferences are not acknowledged. Follow these initial steps to help ensure your organization does not lose productivity due to misunderstanding or miscommunication.

 

This article was reprinted with permission from OnShift.

 

The mandatory Payroll-Based Journal (PBJ) reporting requirement to collect and electronically submit direct care hours starts July 1, 2016 – making daily staffing strategies critical to your success. 

Join this webinar exclusive to LeadingAge members on Thursday June 16, 2016, 2:00 PM-3:00 PM, to learn the ins and outs of the PBJ requirements and walk away with staffing best practices to collect, review and submit the required information to CMS. 

You will learn how to: 

• Gain an in-depth understanding of the new PBJ requirements 
• Find out what hours to count and what not to count 
• Learn staffing best practices you should implement today to get ready

Register Here.

 

This article was reprinted with permission from OnShift.

The National Low Income Housing Coalition has published its annual update on housing costs nationwide, showing a increasingly problematic trend of workforce being priced out of the current housing market.


Out of Reach 2016: No Refuge for Low Income Renters emphasizes the aggravated situation caused by the continued shortage of housing affordable to those making the lowest wages. For the first time the report finds that In absolutely NO state, metropolitan area, or county in the United States can a full-time worker earning the prevailing minimum wage afford a modest 2-bedroom apartment.


In order to afford a modest 2-bedroom apartment at fair market rent, a full-time worker in America today must earn $20.30 per hour—a figure that is almost $5 more than the average hourly wage of renters in the U.S. A full-time worker needs to earn $16.35 per hour to afford a modest 1-bedroom apartment. 


Check out the interactive map and easy-to-read state level data.

Update - At the request of the judge presiding over a legal challenge, OSHA has agreed to extend the effective date of the anti-retaliation provisions of the final injury and illness electronic reporting rule to December 1, 2016. The agency previously had agreed to extend the deadline from August 10 to November 1, 2016. The provisions require employers to inform their employees of their right to report work-related injuries and illnesses without fear of retaliation; to implement reasonable procedures for reporting injuries and illnesses that do not discourage workers from making such reports; and prohibit employers from retaliating or discriminating against workers for reporting injuries and illnesses.


The Occupational Safety and Health Administration (OSHA) published a final rule on May 12, 2016 which it says will improve tracking of workplace injuries and illnesses.  Portions of the rule go into effect on August 10, 2016; while other portions of the rule will be phased in over time. 


Key Provisions of the Rule: 


  • Electronic Submission – The final rule calls for electronic submission of injury and illness reports; however, what needs to be filed generally is dependent on the number of employees employed at an establishment.  Part-time, seasonal and temporary workers at any time during the calendar year are to be included in the number of employees for purposes of the electronic submission requirement.

     
    • 250 or more employees – The employer must submit electronically OSHA Forms 300, 300A and 301 annually.

       

    • 20 or more but less than 250 in certain identified industries – The employer must submit electronically OSHA Form 300A annually.  Included in the list of identified industries are nursing care facilities (NAICS 6231), community care facilities for the elderly (NAICS 6233) and other residential care facilities (NAICS 6239).

       

    • Other employers who receive notification from OSHA to electronically submit their OSHA Forms 300, 300A and 301. 


     

  • Public Posting of Data – Data from the public submissions will be posted in a publicly accessible website.  Information that could be used to identify individual employees will be scrubbed from the website. 

  • Employee Injury and Illness Reporting Requirements – Employers must develop reasonable procedures for employees to report work-related injuries and illnesses promptly and accurately.  A procedure is not reasonable if it would deter or discourage a reasonable employee from accurately reporting a workplace injury or illness.   Additionally, employers must inform employees of the procedures it develops and that:  

     
    • Employees have a right to report work-related injuries and illnesses.

       

    • Employers are prohibited from discharging or in any way discriminating against employees for reporting work-related injuries and illnesses.

       
      • OSHA will now be able to enforce this provision through citation issued as a result of any OSHA inspection.  Previously, retaliation claims would have to be initiated in Federal court. 


       


     

Incentive Programs – Because of OSHA’s concerns that many commonly used incentive programs may deter reporting illnesses or injuries, or incentivize underreporting thereof, OSHA is warning employers that they must be careful in designing and implementing their incentive programs.  Employers should avoid incentive programs designed around lagging indicators, such as those that rewards employees for going a certain period of time without an injury or illness.  Rather, incentive programs should be designed very carefully around leading indicators, such as those that reward employees for identifying and reporting hazards or for participating in the employer’s safety committee.  Going forward, OSHA will assess the acceptability of incentive programs on a case-by-case and has no plans, at the present time, to provide specific guidance to employers. 


Post-Accident Drug and Alcohol Testing – The final rule promises to affect employers’ ability to perform post-accident and post-injury drug and alcohol testing, again because OSHA believes that broad testing policies deter employees from reporting workplace injuries.  As a result, the agency maintains that any deterrence to reporting ultimately results in misleading injury and illness statistics.  Under the final rule, employers may not use drug/alcohol testing (or the threat thereof) as a form of adverse action against employees who report injuries illnesses.  The rule, however, does not apply to post-accident testing required by Federal regulations or permitted by state workers’ compensation laws.  Some guidelines moving forward: 


  • Blanket testing policies are prohibited – Employers should limit post-accident testing to those situations in which drug or alcohol use is likely to have contributed to the accident.

     
    • If the injury or illness is such that there is no plausible connection to drug or alcohol use, testing should not be performed.  Examples of injuries/illnesses with no such connection include back or muscle strains caused by overexertion, carpal tunnel syndrome, animal bites, bee stings and the like.

       

    • OSHA states in the rule that “[e]mployers need not specifically suspect drug use before testing, but there should be a reasonable possibility that drug use by the reporting employee was a contributing factor . . . . In addition, drug testing that is designed in a way that may be perceived as punitive or embarrassing to the employee is likely to deter injury reporting.”  (emphasis added).  This statement is very troubling in that it is impossible for an employer to know beforehand what an employee perceives, and this seemingly gives employees who do not want to be tested wide latitude for objection on the basis that they perceive it to be punitive or merely embarrassing. 


     

  • At least a cursory investigation into the facts surrounding the accident should precede any decision to conduct a drug/alcohol test – The focus of such an investigation would be to rule out any condition attributable to the employer, especially if that condition would be an OSHA violation, and to determine if there are any facts indicating that drug or alcohol use could be a contributing factor. 

     
    • Employers should be mindful of Centers for Disease Control (CDC) parameters of 8 hours for alcohol testing and 32 hours for drug testing.

       


     

  • Employers must not tie drug and alcohol testing to whether (a) an OSHA recordable injury or illness is involved, or (b) an employee files a state workers’ compensation claim.  The accident and the circumstances surrounding it should be the trigger; not the injury. 

  • It is critical for supervisors to be trained to consult with HR personnel before ordering a post-accident drug or alcohol test so that the appropriate investigation can be undertaken. 

Effective Dates/Dates for Submitting Required Forms Electronically – As noted above, the rule has varying effective dates. 


  • August 10, 2016 – Employers must be in compliance with those provisions of the rule dealing with (a) employee injury and illness reporting policies, (b) informing employees of their right to report a work-related injury or illness, and (c) the prohibition against discharging or otherwise discriminating against employees for reporting an injury or illness. 

  • January 1, 2017 

     
    • Requirements relating to electronic submission of Part 1904 recordkeeping forms. 


     

  • July 1, 2017

     
    • Deadline for all employers with 250 or more employees in their establishment to submit their 2016 Form 300A electronically.

       

    • Deadline for all employers with at least 20 but less than 250 employees in their establishment within the NAICS categories listed above to submit their Form 300A electronically. 


     

  • July 1, 2018

     
    • Deadline for all employers with 250 or more employees in their establishment to submit their 2017 Forms 300A, 300 and 301 electronically.

       

    • Deadline for all employers with at least 20 but less than 250 employees in their establishment within the NAICS categories listed above to submit their Form 300A electronically. 


     

  • Beginning in 2019 and going forward, all forms must be submitted by March 2 of every year. 

Conclusion – The final rule presents significant compliance challenges to LeadingAge members as it does to all employers, particularly in the area of incentive program design and implementation and post-accident drug and alcohol testing.  Moreover, the ability of the public to access all electronic injury and illness reports will subject LeadingAge members to increased scrutiny, not just from OSHA inspectors but from employee advocates and interest groups as well.  Given the historically high rates of injuries and illnesses within the aging services field, LeadingAge members should be working with their workplace safety committees, consultants and legal counsel to meet these challenges now. 

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