Healthcare compliance guide

Payroll-Based Journal (PBJ) Staffing Submission

CMS scores every quarterly Payroll-Based Journal submission, publishes the result as the staffing star rating on Care Compare, and audits it against payroll.

Quick answer

PBJ reports direct care hours per employee, per calendar day, per job code for a full fiscal quarter, due by 11:59 PM Eastern on the 45th day after quarter end. It must be built from payroll and other auditable data, so reconcile hours, job codes, and contractor records before upload.

Every Medicare or Medicaid certified nursing home files a quarterly account of who was paid to deliver care, on which days, and for how many hours. That filing is the Payroll-Based Journal. CMS scores it, publishes the result as the staffing star rating on Care Compare, and audits it against payroll.

This guide covers what the submission contains, when it is due, the parts that go wrong, how the file is validated, how the data drives the staffing rating and turnover measures, and how to build it from payroll and time data with reconciliation checks that catch problems before CMS does. Rules are drawn from the CMS PBJ Policy Manual version 2.8 (August 2026), the CMS PBJ FAQ (August 2026), and the Care Compare Five-Star Technical Users' Guide (July 2026). References are at the end.

What PBJ is

PBJ is the CMS system for collecting direct care staffing hours from every long-term care facility subject to 42 CFR Part 483 Subpart B. The requirement dates from a final rule of August 4, 2015; it does not apply to swing beds. Data is reported per employee, per calendar day, per job code, for a full fiscal quarter, and the manual is explicit that it must be "based on payroll and other auditable data."

CMS uses the data for three things: the staffing component of the Five-Star rating, computed as hours per resident day against a census CMS derives from MDS assessments; the staff turnover measures, computed from gaps in the daily hours rather than from termination dates; and audits that compare the submission to payroll, invoices, and contracts.

The calendar

PBJ runs on the federal fiscal year. Submissions are due by 11:59 PM Eastern on the 45th calendar day after the quarter ends.

Fiscal quarterReporting periodDue dateCare Compare update
1October 1 to December 31February 14Last Wednesday in April
2January 1 to March 31May 15Last Wednesday in July
3April 1 to June 30August 14Last Wednesday in October
4July 1 to September 30November 14Last Wednesday in January

A facility may submit as often as it likes; the last accepted submission before the deadline is final. Nothing is accepted after the deadline and the manual states there are no exceptions. The Final File Validation Report can take up to 24 hours, so a file uploaded on deadline day that fails cannot be fixed in time. Land the first full upload at least two working days early.

For 2026, submissions moved from QIES to iQIES on August 17: quarter 4 files are accepted only in iQIES, QIES retired on September 15, uploaders need a PBJ role in iQIES, and an iQIES account unused for 60 days is deactivated.

Build PBJ Files From Auditable Payroll Data

Praisidio assembles daily direct care hours by job code from payroll and time data, with reconciliation checks before upload.

See PBJ Reporting →

What must be reported

The facility supplies two data sections. Census is not one of them.

Employee records. One record per person paid to deliver services, direct employees and contract or agency staff alike. Each gets an Employee ID that is unique across all current and former staff, contains no personal information such as a Social Security number, and never changes during employment. A facility that changes vendors and cannot keep its IDs must use the CMS employee ID linking method. Hire and termination dates are optional in the current manual; if supplied they must be facility-level dates, the first and last day paid for services at that facility.

Staffing hours. One row per employee, per calendar day, per job code, with hours paid to deliver services on site, and a pay type code: 1 exempt, 2 non-exempt, 3 contract. Contract covers individuals under contract and staff supplied through a contracted agency; each still needs a unique Employee ID.

The rule is hours paid, with these carve-outs:

  • Paid time off of any kind is excluded: vacation, sick, holiday, jury duty, any paid non-work absence.
  • Unpaid time worked is excluded. A salaried employee who works 10 hours but is paid for 8 reports 8. Extra salaried hours count only if paid through a payment directly tied to those hours and distinguishable from other payments, not a performance or holiday bonus. A salary contracted for more than 40 hours a week may report the contracted hours minus meal breaks.
  • Meal breaks are excluded whether paid or unpaid, for exempt, non-exempt, and contract staff. A 30-minute break must be deducted from every full shift whether or not it was taken; a longer break is deducted at its actual length. An 8-hour shift reports 7.5 hours either way; a 16-hour double with two breaks reports 15. The manual expects the deduction on shorter shifts too.
  • Time is entered in fractions rounded to the nearest tenth using the CMS minutes table (1 to 6 minutes is 0.1, 7 to 12 is 0.2, and so on) or to the nearest hundredth. 7 hours 33 minutes is 7.6, never 7.33.
  • Midnight is the cutoff for a calendar day. An 11 PM to 7 AM shift reports 1 hour on the first date and 7 on the second. CMS does not expect facilities to change how they pay per shift and considers this in audits.
  • No Employee ID, or linked system ID, may carry more than 22.5 hours in one day. The system enforces this ceiling.

Practitioners who bill Medicare or another payer directly for visits are not reported. Salaried physicians, medical directors paid by the facility, and invoiced consultants are, using "a reasonable methodology" to convert fees into hours that is auditable against payroll, invoices, or the contract.

Census. The facility does not submit census. CMS computes daily census from MDS: a resident counts from the entry date on an admission assessment until the discharge date on a discharge assessment, and a resident with no assessment for 150 days is assumed discharged on day 150.

Job codes

Table 1 of the manual defines 40 job title codes under 15 labor categories; only the job title code is needed for upload. The nursing codes that drive the rating:

CodeJob title
5Registered Nurse Director of Nursing
6Registered Nurse with Administrative Duties
7Registered Nurse
8LPN/LVN with Administrative Duties
9LPN/LVN
10Certified Nurse Aide
11Nurse Aide in Training (first four months, state-approved program)
12Medication Aide/Technician

The rest cover the administrator (1), physician services (2, 3, 4, 13), clinical nurse specialist (14), pharmacist (15), dietitian and paid feeding assistant (16, 17), therapeutic services (18 to 31: OT, PT, respiratory, speech, recreation, activities, social work), and optional codes (32 to 40: dentist, podiatrist, mental health, vocational, laboratory, X-ray, blood services, housekeeping, other).

Reporting follows the employee's primary role and official title; helping out in another role does not change the code. Where a person fully changes role within a day, for example four hours as unit manager and four on the floor, two rows may be reported, code 6 and code 7. An assistant director of nursing running in-service training reports under code 6.

The hard parts

Title to job code mapping. Charge Nurse, Nurse Supervisor, Weekend RN, and RN Float each map to code 6 or 7 depending on whether the primary role is administrative. The mapping needs an owner who knows the roles and a review whenever titles are added. An unmapped title means dropped hours, and dropped RN hours can trigger the four-day zero-RN rule in section 6.

Shifts that cross midnight. A 7 PM to 7 AM shift splits into five hours and seven, less the break wherever it fell. The weekend measure is most sensitive, because Friday night spills into Saturday and Sunday night into Monday.

Meal breaks. The deduction is mandatory regardless of whether the break was taken or paid. Confirm at least 30 minutes came off each full shift; deduct the actual time for longer breaks; document the method. Leaving breaks in over-reports by about 6 percent per 8-hour shift and is the most common audit finding.

The 22.5-hour ceiling. Double punches, a midnight split applied twice, or one shift coded to two job codes will breach it and reject the file.

Agency and contract staff. Hours come from invoices or the scheduling system, not payroll, and need day and job code detail plus Employee IDs that persist when the same agency nurse returns.

Salaried exempt staff. No punches. Report contracted paid hours per worked day minus the break, typically 7.5 hours per weekday, removing paid absences from an exempt exception calendar.

Census timing. A late discharge assessment leaves a departed resident in the denominator until day 150. Only the MDS coordinator can fix that.

The XML file

The submission is an XML file conforming to the CMS NHPBJ schema, currently specification 4.10.0 with its XSD; CMS also publishes an Excel-to-XML template. The file has a header (CMS certification number, fiscal year and quarter, specification version, submission type), an employee section (one element per Employee ID, optional hire and termination dates), and a staffing hours section (one element per employee, date, and job title code, with hours and pay type). There is no census section.

Upload is through iQIES, directly or via a registered vendor. Validation is structural, then logical: the file must parse against the XSD, dates must fall in the quarter, every Employee ID in the hours section must exist in the employee section, job codes must be from Table 1, no employee-day may exceed 22.5 hours, and hours may not fall outside supplied hire and termination dates. The Final File Validation Report lists rejected records with error numbers. A rejected file does not count as submitted.

Audits and the staffing rating

Hours per resident day. CMS sums reported hours for the quarter and divides by the summed MDS census, counting only days with at least one resident. Four measures feed the rating: case-mix adjusted RN hours (codes 5 to 7) and total nurse hours (codes 5 to 12) per resident day, each computed over all days and over weekend days only.

Exclusions for improbable data. Staffing shows as "Not Available", sometimes with a one-star rating, when total nurse staffing is zero for the quarter or the weekends, when it exceeds 12 hours per resident day for the quarter or the weekends, or when aide staffing (codes 10 to 12) exceeds 5.25 hours per resident day for the quarter or the weekends.

Scoring exceptions that force one star. Failing to submit any data by the deadline: one star for the quarter. Four or more days in the quarter with no RN hours (codes 5 to 7) while at least one resident was present: one star for the quarter. Failing to respond to a CMS audit, or an audit finding significant discrepancies between reported and verified hours: one star for three months, extended if repeat audits find the same problem.

Turnover. Three measures are scored: RN (codes 5 to 7), total nurse (codes 5 to 12), and administrator (code 1). CMS does not use hire or termination dates. It identifies people by Employee ID and facility, includes anyone who worked at least 120 hours in a 90-day window from their first observed workday, and counts a departure when there is a gap of 90 or more consecutive days with no hours. Six consecutive quarters of data are required. Changing Employee IDs looks like the whole staff left; a day with 100 percent daily turnover excludes the facility from the measure, and the guide names ID changes as the usual cause. A missing or invalid quarter removes the facility from turnover reporting until it ages out of the six-quarter window, and QSO-25-01-NH (October 2024) assigns the lowest turnover score to facilities that fail to submit or submit erroneous data.

Audits. CMS requests payroll registers, time records, agency invoices, contracts, and the mapping, rebuilds the submission, and compares.

Building the submission from payroll and time data

Treat PBJ as a report generated from source tables, not a spreadsheet assembled each quarter. Inputs: time cards for hourly staff with punch pairs, break punches, and job; contracted paid hours per weekday for exempt staff with an exception calendar; an uploaded agency file per period with a stable ID per worker; the job title to CMS code mapping with effective dates; employee records with Employee ID, exempt flag, and facility-level dates if reported; and the MDS census report from iQIES, not for submission but for running CMS's own checks.

The build produces one row per employee per day per job code: punch pairs split at midnight and the quarter boundary, breaks removed at 30 minutes per full shift or the actual longer break, hours rounded to tenths, exempt contracted hours added for worked days, agency rows appended with pay type 3.

Before generating the file, run the reconciliation checks:

  • Reported nursing hours against paid nursing hours by job code group; the gap should equal breaks plus excluded paid time off.
  • Hours with no employee record; hours outside supplied hire and termination dates.
  • Employee-days over 16 hours, and over 22.5, which will be rejected.
  • Days with at least one resident and zero RN hours; four in a quarter is an automatic one star, so the target is zero.
  • Overnight shifts with one side of the midnight split empty.
  • Payroll titles with hours but no mapping.
  • Agency invoices with no matching hours.
  • Employee IDs changed since last quarter without a linking record.
  • Quarter and weekend hours per resident day against the CMS plausibility bands using the MDS census report.

When every list is empty, the report becomes the XML file.

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How Praisidio helps

Praisidio treats the PBJ submission as a report over data it already holds, with the facility-specific parts kept as configuration.

Sources. Time card and hour summary rows arrive from the time system through the existing connector, with punch times, break punches where recorded, and the payroll job on each entry. Hire dates, termination dates, exempt status, and job titles come from the HRIS record. Two small tables are maintained by the facility inside Praisidio: the job title to CMS job code mapping with effective dates, and the exempt schedule with its exception calendar. Agency hours are uploaded from the vendor file each period through a spreadsheet connector that assigns and remembers a stable Employee ID per agency worker.

The build. One report produces the per-employee, per-day, per-job-code rows for any fiscal quarter on demand. It splits punch pairs at midnight and the quarter boundary, removes the 30-minute break per full shift or the actual longer break, rounds to tenths, adds contracted hours for exempt staff on worked days, appends agency rows with pay type 3, and applies the mapping in effect on each date.

The checks. The section 7 reconciliations are prompts in the same collection, one per check, each returning the rows to fix: missing employee records, hours after termination, zero-RN days, employee-days over 16 and over 22.5 hours, unmapped titles, unsplit overnight shifts, agency invoices without hours, ID changes without links, and reported totals against paid totals by job code group. A final prompt computes RN, total nurse, and aide hours per resident day for the quarter and the weekends against the MDS census report, so the CMS plausibility bands are tested before CMS tests them.

The file and the calendar. The XML is generated from the validated report, so the data sent to iQIES is the data the checks passed on. The collection's data dictionary records the mapping, the break rule, the exempt assumption, and the specification version. The checks are scheduled two weeks before each CMS deadline and again after corrections, with results delivered to the administrator and the director of nursing.

Quarterly checklist

  • Confirm the deadline (February 14, May 15, August 14, November 14) and schedule the first full upload at least two working days ahead
  • Confirm iQIES access for every uploader; accounts unused for 60 days are deactivated
  • Review the job title to job code mapping for new or changed titles
  • Update exempt contracted hours and the exception calendar
  • Load every agency invoice for the quarter and confirm Employee IDs match prior quarters
  • Run the build and reconcile reported nursing hours to paid nursing hours within breaks and paid time off
  • Clear every reconciliation list: unmapped titles, missing records, hours outside dates, over-22.5 and over-16 days, zero-RN days, unsplit midnight shifts, agency invoices without hours, unlinked ID changes
  • Check quarter and weekend hours per resident day against the CMS plausibility bands using the MDS census report
  • Upload, wait for the Final File Validation Report, correct and resubmit any rejected records
  • Save the accepted file, the report behind it, and the mapping in effect as the audit record

Frequently asked questions

When is a PBJ submission due?

By 11:59 PM Eastern on the 45th calendar day after the fiscal quarter ends. Nothing is accepted after the deadline.

What data must PBJ be based on?

Payroll and other auditable data, reported per employee, per calendar day, per job code for the full quarter.

How does PBJ affect the star rating?

It drives the staffing component of the Five-Star rating through hours per resident day, and the staff turnover measures computed from gaps in daily hours.

See PBJ Submission Support on Your Data

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Sources and references

  1. CMS, Staffing Data Submission Payroll Based Journal (PBJ)
  2. CMS, PBJ Long-Term Care Facility Policy Manual, Version 2.8, August 2026
  3. CMS, PBJ Policy Manual FAQ, updated August 2026
  4. CMS, Design for Care Compare Nursing Home Five-Star Quality Rating System: Technical Users' Guide, July 2026
  5. CMS, PBJ Data Specifications V4.10.0 and NHPBJ XSD 4.10.0, linked from the program page
  6. CMS, PBJ Employee ID Linking Methodology
  7. CMS, QSO-18-17-NH (April 2018)
  8. CMS, QSO-25-01-NH (October 2024)
  9. CMS QTSO, What to Expect: PBJ Data Submission and Reporting in iQIES
  10. CMS, iQIES Staffing Data Submission PBJ User Manual
  11. Federal Register, SNF PPS final rule of August 4, 2015 (staffing data submission requirement)
  12. 42 CFR Part 483 Subpart B; 42 CFR 483.20 (resident assessment)
Threshold note: Statutory limits, state rates, and agency deadlines change. Confirm current values against IRS, SSA, Department of Labor, and applicable state or federal agency guidance before using them as audit rules.