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Focus on the F-Tag: Does my DNS Count or Not?

When reporting your staffing levels it is important to focus on accuracy of your measure. CMS will be using PBJ submitted data to focus state survey teams on facilities with missing or inconclusive data trends for staffing driven impromptu state surveys. Remember your DNS hours will be job coded in section 5 and added to your job code 6 and 7 hours from your PBJ report to make up your RN Hours Per Resident Day, total nursing hours include job codes 5-12 and CNA hours include job code 10, 11, 12.
When reporting your staffing levels it is important to focus on accuracy of your measure. CMS will be using PBJ submitted data to focus state survey teams on facilities with missing or inconclusive data trends for staffing driven impromptu state surveys. Remember your DNS hours will be job coded in section 5 and added to your job code 6 and 7 hours from your PBJ report to make up your RN Hours Per Resident Day, total nursing hours include job codes 5-12 and CNA hours include job code 10, 11, 12. See the attached CMS chart for the full breakdown of job codes. CMS uses a set of exclusion criteria to identify facilities with highly improbable PBJ staffing data and neither staffing data nor a staffing rating are reported for these facilities (displaying “Data Not Available” on the Nursing Home Compare website). These exclusion criteria include:
 
· The nursing home has 5 or more days with at least one resident but no nurse (RN, LPN or nurse aide) staffing hours reported. Because nurse aides in training cannot operate independently as nurses, nurse aides in training (job code 11) are not included.
· Total nurse staffing (job codes 5-12), aggregated over all days in the quarter with both nurses and residents is excessively low (12 HRD)
· Nurse aide staffing (job codes 10-12) aggregated over all days in the quarter with both nurses and residents is excessively high (>5.25 HRD)
 
CMS states in their policy manual that reporting shall be based on the employee's primary role and their official categorical title. It is understood that most roles have a variety of non-primary duties that are conducted throughout the day (e.g., helping out others when needed). Facilities shall still report just the total hours of that employee based on their primary role. CMS recognizes that staff may completely shift primary roles in a given day. For example, a nurse who spends the first four hours of a shift as the unit manager, and the last four hours of a shift as a floor nurse. In these cases, facilities can change the designated job title and report four hours as a nurse with administrative duties, and four hours as a nurse (without administrative duties).
 
Staff Contact:
Danielle Watford
Director of Quality Improvement & Regulatory Affairs
dwatford@mehca.org