F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
F

Inconsistent Weekend Staffing in Facility

Menomonee Falls Health ServicesMenomonee Falls, Wisconsin Survey Completed on 05-01-2024

Summary

The facility did not ensure consistent staffing on weekends to meet the needs of the 30 residents residing in the facility. During the review of the payroll-based journal (PBJ) staffing data for the first quarter of the federal fiscal year 2023, the facility was flagged for excessively low weekend staffing. The facility's assessment indicated that the average daily census was between 28 to 32 residents, requiring 5 licensed nurses and 8 certified nursing assistants (CNAs) to provide direct care. The staffing requirements included having one registered nurse (RN) or licensed practical nurse (LPN) per shift, with specific ratios for day, PM, and night shifts. However, the facility's PBJ data revealed a discrepancy in staffing levels, particularly on weekends. The Director of Nursing (DON) stated that the facility's staffing needs are determined by the census and acuity of residents, using a scheduling program called Smart Linx. Despite the program's algorithm creating an ideal schedule, the facility was still triggered for low weekend staffing. The Regional Vice President (VP) acknowledged that the facility was automatically down 16 hours on weekends due to the absence of certain staff roles, such as the Minimum Data Set (MDS) nurse and Social Services. Additionally, a systemic issue was identified where agency staff hours were not being accurately pulled into the PBJ reporting, affecting the reported weekend staffing hours. This issue was attributed to a checkbox in Smart Linx not being checked, which led to agency hours not being integrated into the system, impacting the facility's staffing data.

Penalty

Inspection fine: $55,4198 days payment denial
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The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.

Resources

Below are regulatory guidelines relevant to this citation:

See other F0851 citations
Incomplete and Inaccurate PBJ Staffing Submission
C
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

Incomplete and Inaccurate PBJ Staffing Submission: The facility failed to submit complete and accurate PBJ staffing data based on payroll and other auditable records. CMS PBJ reports showed excessively low weekend nurse staffing across multiple FY quarters, while review of weekend nursing schedules and working hours showed adequate staffing. An admin staff member stated the administrator and corporate staff were responsible for PBJ submission, and the facility policy required PBJ data to be submitted in a uniform format to CMS.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Incomplete PBJ Staffing Reporting and Daily Census Posting
F
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

The facility failed to consistently include the daily census on nurse staff postings and had PBJ staffing data that triggered survey review for low weekend staffing and LNs available 24 hours per day. Although posted schedules showed licensed nursing coverage 24/7, the staffing coordinator said they only entered agency staff, and the administrator stated corporate submitted PBJ, contract/agency staff may not have been entered, and nurse manager hours may have been coded incorrectly when worked on the floor.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Incomplete PBJ Staffing Reporting
C
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

Incomplete PBJ staffing reporting led to a trigger for excessively low weekend staffing. CMS PBJ data for FY 2026 Q1 and Q2 showed low weekend staffing, but review of nursing schedules showed adequate staffing on duty. An Administrative Nurse stated the Administrator submitted the PBJ nursing information and that weekends were always staffed well, including with agency staff when needed. The facility’s PBJ policy required reporting payroll data for employees, agency, and contract staff.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Inaccurate PBJ Staffing Submission
C
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

Inaccurate PBJ staffing submission: The facility failed to electronically submit complete and accurate direct care staffing data to CMS through PBJ. Review of the PBJ Staffing Data Report showed excessively low weekend staffing for multiple quarters, but the nursing schedule and payroll data did not reflect lower weekend staffing than weekdays. An admin staff member stated corporate changed the PBJ report to code admin nurses' weekend hours as direct care, even though staffing levels were the same on weekends and weekdays.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Failure to Submit PBJ Staffing Data
F
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

Failure to submit PBJ staffing data. Review of staffing data reports showed the facility did not submit direct care staffing information for Quarter 2, and an interview with Administer E1 confirmed there was no further documented evidence of submission.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
Incomplete and inaccurate PBJ staffing submission
F
F0851 F851: Electronically submit to CMS complete and accurate direct care staffing information, based on payroll and other verifiable and auditable data.
Short Summary

The facility failed to submit complete and accurate PBJ staffing data to CMS for Q4. Review of the PBJ discrepancy report showed the payroll system underreported total nursing hours by 1,606.80 hours because extra break time was deducted and one employee lacked a CMS job title code, so those hours were not counted. The Administrator stated the software did not correctly carry over LPN and CNA hours and that accurate coding would have met the 3.4 HPRD and produced correct census and staffing hours.

No penalty information released
tooltip icon
The penalty, as released by CMS, applies to the entire inspection this citation is part of, covering all citations and f-tags issued, not just this specific f-tag. For the complete original report, please refer to the 'Details' section.
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