CMS Releases Updated PBJ Manual to Allow for On & Off Site Medical Director Responsibilities to Count

March 25, 2016
Policy Snapshot

Last week, the Centers for Medicare & Medicaid Services (CMS) released survey and certification letter (S&C 16-13-NH) which reminds long-term care facilities that the mandatory submission period for electronic reporting on staffing begins on July 1, 2016. The Society for Post-Acute and Long-Term Care Medicine met with CMS and argued that the “on site” requirement for reporting Medicare Director hours could lead to inaccurate reporting. CMS has  amended this requirement it is recent changes to the Payroll-Based Journal (PBJ) - Implementation of required electronic submission of Staffing Data for Long Term Care (LTC) Facilities manual, which includes the removal of “on site” when describing the way Medical Directors hours are to be reported.  

The Medical Director section of the PBJ manual now reads:

“For medical directors, CMS understands it may be difficult to identify the exact hours a physician spends performing medical director activities versus primary care activities. Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on-site conducting primary responsibilities. For example, if a medical director is contracted for a certain fee (e.g., per month) to participate in Quality Improvement meetings and review a certain number of medical records each month, the facility should have a reasonable methodology for converting those activities into the number of hours paid to work.”

The updates to the PBJ manual also include clarification regarding “how facilities may report hours for staff who switch primary roles within a day.” 

The revised and final PBJ policy manual and related information can be found here.