Home › Guides › PBJ reporting requirements for nursing homes
PBJ reporting requirements for nursing homes
Published ; updated .
PBJ is still a federal reporting obligation for nursing homes, even after the 2026 minimum staffing rule changed. The mistakes that matter most happen in the handoff from the schedule to paid hours, then into the file CMS receives.
The PBJ rules that affect your file
LTC facilities subject to 42 CFR Part 483, Subpart B must submit direct-care staffing information, including agency and contract staff, through PBJ. Swing beds are excluded.Source: CMS PBJ Policy Manual v2.7
Each federal fiscal quarter's PBJ submission is due by 11:59 PM Eastern on the 45th calendar day after the quarter ends. The system rejects late submissions.Source: CMS.gov, Staffing Data Submission
A full 12-hour shift paid to work 12 hours is reported as 11.5 PBJ hours after CMS's required 30-minute meal-break deduction, even if the break was not taken.Source: CMS PBJ Policy Manual v2.7
PBJ XML files submitted with a specification version other than 4.10.0 on or after April 1, 2026 are rejected, including files submitted by third-party vendors.Source: CMS.gov, Staffing Data Submission
The PBJ Final Validation Report is automatically generated within 24 hours after a successful file submission; certain fatal errors can prevent automatic generation.Source: QTSO, PBJ Error Message Reference Guide v1.0
iQIES prevents a System Employee ID, including linked employee IDs, from exceeding 22.5 hours in one day.Source: CMS.gov, Staffing Data Submission
Think of PBJ as an evidence trail. CMS expects the reported hour to be traceable to payroll or another auditable record, assigned to the right employee and job title. A planned 12-hour shift is not automatically a reportable 12 hours. A night shift is not one PBJ day just because it appears on one schedule row.
The 2026 staffing-rule change does not make this data optional. PBJ still supports Five-Star staffing, and the reporting obligation comes from the Affordable Care Act and 42 CFR 483.70(p). A facility can miss its staffing target without a PBJ error, or staff well and report badly. Those are different failures.
Put the quarter on your calendar first
PBJ uses federal fiscal quarters, not calendar quarters. The due date is a hard cutoff, so leave time to review the PBJ Final Validation Report. It is automatically generated within 24 hours after a successful file submission. Certain fatal errors can prevent automatic generation.
Fiscal quarter
Reporting period
CMS due date
Q1
October 1 to December 31
February 14
Q2
January 1 to March 31
May 15
Q3
April 1 to June 30
August 14
Q4
July 1 to September 30
November 14
You may submit during the quarter. The last accepted file is final. If a vendor sends it, the facility still owns the obligation. Set the internal review date earlier when an agency invoice or payroll correction is open.
Count paid hours by PBJ day
PBJ reports hours paid to work, by calendar day. It does not report the hours that were originally scheduled. Meal breaks and paid leave are excluded. Hours are submitted as decimal fractions rounded to the nearest tenth, or optionally to the nearest hundredth.
For a 12-hour shift paid as 12 hours, the calculation is simple: 12 - 0.5 = 11.5 PBJ hours. That deduction applies to a full shift even when the employee did not take the meal break. If the employee was paid for only 8 hours, report 8 hours instead.
Midnight is the second trap. CMS's example of an 11:00 PM to 7:00 AM shift records 1 hour on the first date and 7 hours on the next date. Do not place the full shift on the date when it started. Apply the meal-break rule to the full shift as required by the PBJ manual, then verify that the date-level entries agree with the underlying paid record.
Worked example: One RN day shift, two CNA day shifts, and one LPN night shift are each paid for a full 12-hour shift. The reportable total is 46.0 hours, not 48.0.
Staffing line
PBJ job code
Calculation
Reportable hours
RN
7
1 x 11.5
11.5
CNA
10
2 x 11.5
23.0
LPN/LVN
9
1 x 11.5
11.5
Total
4 x 11.5
46.0
Map each person to the right job code
The title used in a schedule is not enough. PBJ records a labor category and a job title code. The nursing-services codes below are the ones most likely to affect a nursing-home schedule.
Code
Job title
Use it for
5
Registered Nurse Director of Nursing
Director of nursing hours; do not report those hours again under another code
6
RN with Administrative Duties
RNs principally performing administrative or RAI work
7
Registered Nurse
Direct-care RN work
8
LPN/LVN with Administrative Duties
Non-direct-care LPN/LVN work
9
Licensed Practical/Vocational Nurse
Direct-care LPN/LVN work
10
Certified Nurse Aide
State-approved CNA work; volunteers are excluded
11
Nurse Aide in Training
Eligible aide-in-training work during the first four months of employment
12
Medication Aide/Technician
State-approved medication aide work
14
Clinical Nurse Specialist
Clinical nurse specialist work in the nursing-services category
Agency and contract staff belong in the submission too. Keep the pay type and employee identity distinguishable, and do not let an agency RN inherit a generic "staff" code because that is how the person appears in the scheduling tool.
What changed on August 17
CMS launched PBJ in iQIES on August 17, 2026. All current PBJ submissions are completed there. FY2026 Q3, covering April 1 through June 30, was the last QIES quarter and was due August 14. FY2026 Q4, covering July 1 through September 30, is submitted in iQIES and is due November 14, 2026, at 11:59 PM Eastern.
CMS migrated 10 years of PBJ data. After 60 days without a successful iQIES login, iQIES revokes the user's roles, but the HARP account remains active. Keep PBJ access current before the deadline window.
PBJ XML files using a version other than 4.10.0 are rejected. iQIES also prevents a System Employee ID, including linked employee IDs, from exceeding 22.5 hours in one day. Check the vendor export version instead of assuming a successful export is compliant.
Use a reconciliation pass that someone else can follow
Before submitting, trace a sample from the published schedule to the paid record, then to the PBJ line. Keep the exception list with the quarter's submission packet. The review should answer these questions:
Was the person paid to work, or was the row actually leave, orientation off the unit, or another excluded absence?
Were the hours split across the correct calendar dates at midnight?
Was the 30-minute meal deduction applied to each full shift?
Does the job code describe the work performed?
Does any employee ID exceed 22.5 hours on one day across all job titles?
Has the PBJ Final Validation Report been reviewed before the hard cutoff?
Do not use PBJ to submit census. CMS derives the census used in PBJ staffing data from MDS submissions. The Daily MDS Census Report is a separate iQIES PBJ report. The general staffing-information rule still includes resident census data.
Where otherwise good submissions fail
Reporting scheduled hours instead of paid direct-care hours inflates the file.
Putting an overnight shift on its start date creates a date-level mismatch.
Skipping the 30-minute deduction overstates every full 12-hour row.
An administrative RN or LPN code can misstate direct-care work.
Submitting on the deadline leaves no time to review the PBJ Final Validation Report, which is automatically generated within 24 hours after a successful submission.
Duplicate employee IDs can hide the 22.5-hour cap until the file is rejected.
Keep the schedule traceable
Shiftd maps scheduled shifts to PBJ job codes, calculates reportable hours across the calendar, and keeps an audit record of schedule changes. Payroll and the final CMS submission still need your review, but the scheduling record starts with the right structure.
No. Electronic Staffing Data Submission is the CMS program or requirement. PBJ is the submission system. The PBJ Public Use File is its public dataset.
When is the PBJ report due?
By 11:59 PM Eastern on the 45th calendar day after the federal fiscal quarter ends. Published due dates are February 14, May 15, August 14, and November 14.
How many PBJ hours does a 12-hour shift produce?
A full 12-hour shift paid to work 12 hours produces 11.5 PBJ hours after the required 30-minute deduction. An overnight shift is split between its calendar dates.
Do agency and contract staff count in PBJ?
Yes. Include agency and contract staff, distinguish the pay type, and use the matching job title code.
Does PBJ still collect census?
No. CMS removed census tags from PBJ and derives census from MDS submissions. Do not add a census record to a current PBJ XML file.
Where do PBJ submissions go now?
All current PBJ submissions are completed in iQIES. FY2026 Q3 was the last QIES quarter, with an August 14, 2026 deadline.
