PBJ isn’t hard because it’s complicated.
PBJ is hard because it exposes messy processes.

If you’re using agency, PRN, or local “contract” coverage to stabilize staffing, PBJ forces you to answer (with receipts):

• Who worked?
• In what role?
• For how long?
• And can you prove it?

CMS designed PBJ to collect staffing information on a regular basis using auditable data, including agency and contract staff.

This guide breaks PBJ into a simple workflow you can actually run, plus what to demand from staffing partners so you aren’t stuck rebuilding documentation during a survey.

Key takeaways

• PBJ includes agency and contract staff, and the data is auditable.
• PBJ deadlines are consistent each quarter—missing them creates avoidable risk.
• Your biggest PBJ problems usually come from timekeeping gaps, role mapping, and reconciliation, not “PBJ itself.”
• The best defense is a repeatable process: capture time → map roles → reconcile → submit → archive proof.

What PBJ is

CMS uses PBJ staffing data (combined with census information) to report staffing levels, turnover, and tenure, and PBJ is auditable to ensure accuracy.

In plain English: if your staffing documentation isn’t clean, PBJ is where that shows up. Who PBJ applies to: Medicare/Medicaid-certified long-term care facilities subject to federal requirements (SNF/NF). PBJ FAQs also clarify that it does not apply to swing beds.

PBJ deadlines (write these into your calendar)

CMS states submissions must be received by the end of the 45th calendar day after the last day of each fiscal quarter, and lists these due dates:

• Q1 (Oct–Dec) Feb 14
• Q2 (Jan–Mar) May 15
• Q3 (Apr–Jun) Aug 14
• Q4 (Jul–Sep) Nov 14

Don’t wait for week 6. Most PBJ “emergencies” happen when someone tries to fix timekeeping in the final 72 hours.

The PBJ truth that trips facilities up: agency/contract staff count

CMS explicitly notes that PBJ requires facilities to submit direct care staffing information, including agency and contract staff.

That means:

• You can’t treat contingent labor as “off the books” operationally.
• Your staffing partner’s invoice is not enough.

You need shift-level time mapped to the right role categories.

What PBJ requires you to get right (without drowning in details)

1) Hours: paid vs worked (and what counts)

Facilities report hours paid for services performed onsite, excluding paid time off like vacation, sick time, etc. 

2) Role/category mapping

PBJ is sensitive to role definitions. A correct time record in the wrong category is still a problem.

3) “Onsite” clarification (watch this)

Industry summaries of the June 2025 PBJ manual update highlight clarifications that nursing hours reportable through PBJ must be worked onsite, including administrative RN hours.

Operational takeaway: if you have nurses doing offsite admin tasks, treat PBJ reporting rules as something to verify and document (don’t assume).

The PBJ workflow: a simple process that prevents 90% of issues

Here’s the facility-friendly PBJ process that actually holds up during audits.

Step 1: Choose ONE timekeeping method for agency/contract labor

This is where most facilities break PBJ.

Pick a method and standardize it:

• badge swipe + assignment records
• timeclock + supervisor confirmation
• staffing partner digital time capture + facility verification

Rule: If it can’t be verified, it’s not PBJ-safe. Cascade’s client portal makes PBJ reporting easy by automatically tracking all of the information you need to report on our agency staff.

Step 2: Create a Role-mapping Cheat Sheet

Make a simple internal document: 

• “CNA shifts map to ___”
• “Medication aide maps to ___”
• “RN admin vs RN direct care: here’s how we treat it in our system.”
• “Agency LPN maps to ___”

 The easiest PBJ errors are data that’s “technically complete” but categorized wrong.

Step 3: Reconcile Weekly, Not Quarterly

PBJ is quarterly, but reconciliation shouldn’t be.

Each week:

• Pull facility time data for agency/contract staff
• Reconcile against staffing partner records/invoices
• Fix mismatches immediately (missing start/end times, wrong unit, wrong role)

The goal is to make the end of your quarter as boring as possible.

Step 4: Run PBJ Validation Checks Before Submission

CMS specifically tells providers to check the “Updates” section for changes to maintain technical submission requirements on the PBJ page.

Practical Checks:

• Do all agency employees have IDs?
• Are any employees exceeding plausible daily max hours?
• Do job categories align with reality?
• Does the census look right?

Step 5: Archive proof (your survey insurance policy)

Keep a quarterly PBJ folder with:

• Submission confirmation
• Reconciliation notes
• Staffing partner hours report
• Your timekeeping export
• Explanation of any anomalies (storms, outbreak surge, etc.)

Important 2026 Technical Update to be Aware of

CMS posted an update (Feb 6, 2026) stating it strongly encourages users to begin using PBJ fileSpecVersion 4.10.0, and that XML files submitted with versions other than 4.10.0 on or after April 1, 2026, will be rejected.

What this means for you:

• If you use a payroll/timekeeping vendor or third-party PBJ tool, ask now:
  • “Are we 4.10.0-ready?”
  • “When are you switching fileSpecVersion?”
  • “Do we need a new Excel/XML template?”
• If you submit manually, this matters less—but your partner/vendor still should know.

What to demand from staffing partners (so PBJ doesn’t become your problem)

If a staffing partner supports SNFs, they should be able to provide:

• accurate, shift-level time data you can reconcile
• clear role mapping (CNA/LPN/RN, etc.)
• documentation you can pull quickly
• fast correction when errors appear
• a consistent process for agency/contract workforce tracking

If they can’t produce clean reporting, PBJ becomes your operational burden.

All of these are possible on the Cascade client portal, which is changing staffing visibility and tracking.

Common PBJ pitfalls (and quick fixes)

Pitfall 1: Treating invoices as “proof”

Fix: reconcile invoices to timekeeping, weekly.

Pitfall 2: Job categories are guessed or inconsistent

Fix: create a role-mapping cheat sheet and enforce it.

Pitfall 3: Submitting late leaves no room for edits

Fix: submit early and build a schedule (week 2 validation, week 4 pre-check).

Pitfall 4: Offsite hours confusion

Fix: document what is onsite vs not reportable and align teams to the same rule set.

FAQs

Does PBJ include agency and contract staff?

Yes, CMS notes PBJ requires reporting of direct care staffing information, including agency and contract staff, and PBJ is auditable.

What’s the PBJ submission deadline each quarter?

CMS states submissions must be received by the end of the 45th calendar day after the quarter ends.

Do facilities report hours paid or hours worked?

Facilities report hours paid for services performed onsite, excluding paid time off.

What should we do right now to reduce PBJ risk?

Standardize timekeeping for agency/contract staff and reconcile weekly. Most PBJ issues come from inconsistent workflow, not “PBJ complexity.”

Want staffing support that won’t create PBJ headaches?

If you’re using agency/contract labor in an SNF, clean documentation and verified timekeeping matter. We’ll help you stabilize coverage with processes built for compliance.