Earlier this year, CMS published their latest PBJ policy manual. While no big changes were announced, a few key details were noticeably specified as new to the manual:

1. Nursing homes are expected to run their CMS Census reports and check for accuracy prior to every submission deadline.

   The MDS Census that CMS tracks is a critical piece of HRD calculation. PBJ auditors are increasingly checking for accuracy between the CMS census and a nursing home's internal census. The inclusion of this language in the policy manual underscores the importance of this trend.

2. Any single employee should never have more than 22.5 hours submitted for any given day.

   Factoring in the required removal of meal breaks (most commonly .5 hours for every 8 hours worked), 22.5 is the maximum amount of hours that should be submitted for any staff on a single day.

3. For nursing staff, only hours worked onsite can be submitted for PBJ purposes.

   This has been the constant guidance of CMS over the last few years, even during the time period of the public health emergency and includes administrative nursing hours as well. Including this in the policy manual clearly supports CMS' expectations around reporting hours for direct-care staff.