The Centers for Medicare & Medicaid Services has begun testing an audit process relating to care center submission of Payroll Based Journal (PBJ) data. CMS has hired the actuarial firm Granite Dolphin to conduct the audits, which will relate to data submitted on or before May 15, 2017, for the period January 1 to March 31, 2017.

This is a pilot phase only, and audit findings will not result in sanctions or negative actions against a facility. We do not yet know how many audits CMS intends to conduct during this pilot phase, but our assumption is that some Minnesota providers will be contacted. The audit teams will be auditing PBJ data only and will not be conducting a health and safety survey.

The LeadingAge national office has explained that some audits will be conducted off-site and others on-site. The on-site test audits are being announced beforehand so that the facility is aware that the auditors will be coming.

CMS has released materials that show what information the auditors will ask providers to submit as part of the audit process. The PBJ audit team will examine payroll records and other auditable data along with PBJ submission data to identify if staffing is being reported accurately based on hours staff are paid to work. This may include, but is not limited to, information from payroll, timekeeping systems, invoices for contracted staff, and interviews with staff responsible for PBJ data entry.