October 15, 2018

Payroll-Based Journals

By Steven Lavenda, Partner, Advisory Services

Payroll-Based Journals

The Center for Medicare and Medicaid Services (CMS) recently issued a new Office of Inspector General work plan which intends to provide more oversight of nursing facilities staffing levels.

The CMS report, which is expected to be issued in federal fiscal year 2020, seems to be the result of the findings in a report issued1 by two national publications. The joint report found that the staffing data submitted quarterly through the nursing homes payroll records, known as Payroll-Based Journals (PBJ), showed lower staffing levels than those the facilities had self-reported. In fact, of the more than 14,000 skilled nursing facilities submitting payroll records, 7 in 10 had lower staffing than under the old method of reporting staff.

Prior to submitting staffing information through PBJ, nursing homes had to complete a staffing form at the time of annual inspection, which reflected the employees on staff for the previous two weeks. However, if management knew the time window of when the inspection would take place, they could add workers before the inspection, which would distort the true staffing level of the nursing home. Also, staffing levels under this method of reporting affected the number of stars the facility received under the CMS nursing home compare tool.

As of April 2018, CMS began using the PBJ data from the last quarter of 2017, which needed to be submitted by February 14, 2018, to determine if the facility was properly staffed and what star level to assign.

The report mentioned above showed there was a large enough discrepancy in the staffing data obtained between the old and new methods that CMS now wants to investigate.

Part of the difference may have been due to measuring two different time periods and the type of employees in the staffing count under the old and new methods.

The bottom line is that nursing home management needs to make sure that the employees who are part of the minimum staffing are in the proper payroll categories. In addition, since the amount of staffing is based on the level of care required, the nursing home needs to make sure that the Minimum Data Set forms are accurately completed.

If you have any questions regarding the above, please contact a member of Marcum’s healthcare group.


1. Stempniak, Marty. “Inspector General Investigating Nursing Home Staffing: Report.” McKnight’s Long-Term Care News, 31 Aug. 2018.
Thomas, Katie. “Medicare Star Ratings Allow Nursing Homes to Game the System.” The New York Times, 24 Aug. 2014.

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Steven  Lavenda

Steven Lavenda


  • Advisory
  • Deerfield, IL