The Dept. of Health and Human Services (HHS) Office of Inspector General (OIG) issued a report last week declaring that the processes deployed by the Centers for Medicare and Medicaid Services (CMS) were not effective in ensuring the accuracy of staffing information reported in the Payroll-Based Journal (PBJ).

OIG issued four recommendations, two of which CMS agreed to, and two that are in limbo pending further action or clarification.

Nursing homes are required to electronically submit to CMS's PBJ information on direct-care staff, including the number of hours that each staff member was paid to deliver services for each day the staff member worked.

“This audit assessed whether RN staffing hours reported in the PBJ for March 2024 were supported in accordance with federal requirements,” the inspector said.

What’s the Problem?

What OIG found is that not all nursing homes’ RN staffing hours reported in CMS’s PBJ were supported in accordance with the rules. “For 45 of 100 sampled items, nursing homes reported a net of 748.5 hours that were not supported,” OIG said.

Further, for 2 of 100 sampled items, nursing homes reported 336 hours that could not be verified because the nursing homes did not provide supporting documentation.

“On the basis of our sample results, we estimated for our sampling frame that for March 2024 nursing homes reported approximately 938,000 hours [5 percent] for approximately 53,000 RNs [42 percent] in the PBJ that were not supported in accordance with federal requirements,” OIG said.

As a result of this and its finding related to the 336 hours that could not be verified, CMS and other stakeholders may not have the most accurate data for their use, OIG said.

What OIG Recommends

OIG made four recommendations to CMS. These are:

• OIG recommends that CMS consider the results of our audit when selecting nursing homes for follow-up audits by the CMS PBJ auditor.

• OIG recommends that CMS require the CMS PBJ auditor to verify whether nursing homes have taken corrective actions on findings identified in prior PBJ audits.

• OIG recommends that CMS educate nursing homes on the updated guidance available in the PBJ Policy Manual and PBJ Policy Manual FAQs.

• OIG recommends that CMS regularly communicate to nursing homes the trends in CMS PBJ audit findings (e.g., by providing information on frequently identified CMS PBJ audit findings during an Open Door Forum and on the PBJ web page).

CMS concurred with the first and third recommendations.

The report is (A-09-24-02005), “CMS’s Processes Were Not Effective in Ensuring the Accuracy of Staffing Information Reported in the Payroll-Based Journal.”

Comments or questions on this article? Contact Patrick Connole at pconnole@parkplacelive.com.