CMS Targeting Facilities with Low Staffing in PBJ Data
According to the Centers for Medicare & Medicaid Services (CMS) Quality, Safety and Oversight Group Letter released on November 30, 2018, CMS will begin notifying state agencies and CMS regional offices with a list of facilities that report low staffing during certain dates within PBJ data. CMS has also provided an update to its PBJ manual and created new CASPER reports allowing facilities to verify daily census based upon MDS submission data.
This will be effective immediately, and CMS encourages providers to prepare accordingly, as this policy will be communicated to all survey and certification staff, their managers and State/Regional Office training coordinators within 30 days of this memorandum.
Staffing Concerns: Weekends and RN Onsite
The stance CMS takes is that staffing levels in long-term care facilities significantly impact the quality of care for residents. In reviewing the PBJ information over the past few periods, CMS continues to implement policies to address concerns they have within the PBJ data being submitted. Therefore, CMS will begin informing state survey agencies of facilities with potential staffing issues. The two criteria CMS will be targeting with this new process are:
- Low nurse staffing levels on weekends – this would comprise of all nursing disciplines included in the direct care staffing Five-Star rating calculation (i.e. RNs, LPNs, nurse aides). State surveyors will now be required to conduct 50% of “off-hours” surveys on weekends using the list of facilities provided by CMS.
- Several days in quarter with no RN onsite – this is to identify facilities at a greater risk of noncompliance with the RN staffing requirement. When conducting a survey, surveyors should investigate compliance with the current requirement of staffing an RN seven days a week, eight hours a day. This should correspond with PBJ data submitted.
PBJ Manual Guidance: Meal Breaks & Universal Worker
Furthermore, CMS is expanding its guidance in the PBJ Policy Manual and FAQ document related to meal breaks and universal care workers within long-term care facilities. Highlights related to these two areas include:
- Meal Break Policy – the manual and FAQ provide detail and examples of how to deduct meal breaks for staff. Across all facilities, CMS deems itself unable to verify the portion of meal breaks in which staff actually spend eating or working, so in order to measure all facilities equally, CMS requires the deduction of meal break time for all staff (i.e. exempt, non-exempt, contract).
- For staff paid and/or unpaid at meal-times who work 8 hours shall report 7.5 worked hours for PBJ
- For staff paid and/or unpaid at meal-times who work 12 hours shall report 11 worked hours for PBJ
- Universal Care Workers – some facilities employ universal care workers who are typically certified nurse aides performing a number of duties, including direct resident care, food preparation and housekeeping services. Prior to this update, CMS has broadly explained how to report hours for staff performing these roles. CMS has now added language stating the following:
- Facilities must use a reasonable methodology to allocate the appropriate number of hours related to performing certified nurse aide duties.
- Other duties, such as time related to dietary and housekeeping, shall not be reported as certified nurse aide hours.
- Hours related to other duties above can be reported to housekeeping or other services, but are not required to be reported per PBJ guidelines.
Census Reports – MDS
CMS has developed two new CASPER reports for providers to access within the reporting section of the PBJ QIES system site. These reports are to help ensure MDS data is submitted timely and accurately. The new reports are:
- MDS Census Summary Report – providers can retrieve the actual number of residents reported each day in the quarter using MDS-based census
MDS Census Detail Report – providers can retrieve a list of residents reported each day in the quarter using MDS-based census (Squared Business Solutions)