08/21/2025

CMS Clarifies Rules for Off-Site Staffing in Nursing Homes

LeadingAge has received questions about the use of off-site staff in nursing homes, such as Minimum Data Set (MDS) coordinators. In a recent update to the Payroll-Based Journal (PBJ) Policy Manual and FAQs, the Centers for Medicare and Medicaid Services (CMS) clarified that only hours worked on-site may be recorded in PBJ. Hours worked off-site, even for licensed nurses performing administrative duties, may not be counted.

While nursing homes may engage off-site staff for certain administrative tasks, facilities must continue to meet MDS assessment requirements. These include direct observation of and communication with residents, as well as collaboration with the interdisciplinary team. Off-site nurses may perform coding and transmission of MDS data, but all staff completing this work must hold licensure in the state where the nursing home is located. For MDS coordinators serving multiple facilities across state lines, this means securing licensure in each applicable state.

CMS also emphasized that questions regarding MDS responsibilities and scope of practice should be directed to the state Resident Assessment Instrument (RAI) coordinator. A full list of state RAI contacts is available in CMS Appendix B.