CMS Releases Updates to PBJ Manual and FAQs

• By: Maureen Carland
• On: 07/07/2025 09:24:25
• In: Quality/Regulatory

The Centers for Medicare & Medicaid Services (CMS) has released an updated version of the Payroll-Based Journal (PBJ) Manual (Version 2.7, June 2025), along with revised Frequently Asked Questions (FAQs). These updates aim to clarify reporting requirements and support compliance with federal staffing data submission standards.

PBJ Manual – Version 2.7 Key Updates

• Resident Census Accuracy: Facilities are reminded to run census reports and verify resident census data prior to the quarterly submission deadline to ensure accuracy.
• Maximum Daily Hours: No single individual may be reported for more than 22.5 hours of work in a single day. This limit accounts for the federal requirement that a minimum 30-minute meal break must be deducted for every 8 hours worked—regardless of whether the break was taken. If longer breaks are taken, the full break time must be deducted from reported hours.
• On-Site Work Requirement: The manual clarifies that nursing hours may only be reported if the work was performed on-site.

Updated FAQs – Key Clarifications
The revised FAQs address common questions and provide additional guidance on PBJ reporting policies:

• RN Coverage and Meal Breaks: Surveyors are aware of the PBJ meal break requirement. Facilities will not be cited if they demonstrate that an RN was on-site for eight consecutive hours, seven days per week. Facilities with an RN waiver should submit documentation to CMS to avoid a downgrade to a 1-star staffing rating.
• Reporting Extended Workweeks: If an employee's contract specifies a workweek exceeding 40 hours, all hours worked—excluding meal breaks—may be reported.
• PBJ Audits: Three new FAQs address PBJ audit processes, including guidance on:
  • How to submit reconsideration requests,
  • Common triggers for a failed audit,
  • Differentiating official audit communications from CMS versus its contractors.

Providers are strongly encouraged to review both the updated PBJ Manual and FAQs in full to ensure compliance.
Resources from AHCA

To assist providers with PBJ compliance, the American Health Care Association (AHCA) offers several helpful tools:

• Reporting Hours in PBJ Checklist
• Reporting Hours in PBJ for RNs
• PBJ Frequently Asked Questions (FAQs)

Staff Contact: mcarland@mehca.org