The practical answer
Review a filing in three lanes: errors you can prove, questions the facility must resolve, and evidence still missing. A missing document is not a passed check. Start with source coverage, then review identities, reportable hours, and the final totals.
Separate an error from an unanswered question
| Category | Example | Next action |
|---|---|---|
| Blocking error | Invalid date or a record outside the filing quarter | Correct the record or document why it is excluded |
| Needs review | Two source IDs may belong to one employee | Confirm identity from facility records before linking |
| Missing evidence | Meal treatment or a shared-facility allocation is unclear | Obtain the time record, policy, or allocation support |
Give each finding an owner, resolution, and supporting source. If the underlying hours change, review the affected finding again and generate a new export. Keeping a previous approval attached to changed data makes the audit trail misleading.
Find missing agency hours and incomplete payroll files
- Match every expected payroll period and agency delivery to a received file.
- Investigate days with unexplained gaps; distinguish missing data from confirmed zero reportable hours.
- Compare roles present in the filing with the facility’s staffing sources.
- Look for overlapping payroll and agency files, repeated uploads, and correction files counted as additions.
- Reconcile totals by file, employee, and work day. A balanced grand total can hide offsetting errors.
Keep an explicit list of unresolved items for the reviewer. Do not fill a gap with estimated staffing records just to make a chart look complete.
If an agency sends a total invoice without daily staffing detail, request the supporting time records. If the same hours appear in payroll and the agency file, compare the employee and work date before excluding a duplicate. Start with the PBJ reporting source-file checklist when you are unsure what to collect.
Download a PBJ review checklist your team can use
Download the free PBJ review checklist (CSV). Keep an owner, status, evidence reference, and correction note for each check. The worksheet is a preparation aid, not a CMS form or proof that a filing has passed review.
| What you see | What to inspect | Before closing the issue |
|---|---|---|
| A missing day or agency file | Source register and daily time records | Obtain the missing evidence; do not assume zero hours |
| The right total but the wrong employee | Employee IDs, work dates, and source rows | Reconcile the detail as well as the total |
| Two lines for overtime | Base hours and premium-pay definitions | Confirm whether the premium adds hours or only pay |
| A daily-hours error | Linked IDs, duplicates, meals, and midnight splits | Correct the source or mapping; preserve the reason |
| Records rejected after upload | Final Validation Report and exported revision | Correct and verify the resulting CMS records before the deadline |
For a professional second check, request the $49 PBJ consultant review: one facility’s quarterly filing, written findings, and one follow-up check of corrections. Confirm timing before relying on it for a deadline.
Review meals, leave, training, and additional hours
Meals: CMS excludes paid and unpaid meal time and requires at least a 30-minute deduction for each full shift; longer meal breaks require their actual time removed. Check deductions already present in payroll before applying another. Policy manual §2.2(d).
Example: an eight-hour shift with a 30-minute meal already removed in the payroll export has 7.5 hours before any other exclusions. Subtracting the same half hour again would understate that source record. Keep the payroll evidence supporting the treatment.
Leave and training: exclude leave hours. Training time is not reportable when the employee is unavailable to perform their primary role. Additional salaried hours need qualifying pay evidence tied to the extra work. CMS FAQ, questions 2, 14, and 20.
Overtime and bonuses: inspect whether a source line contains hours, dollars, or a pay premium on hours already listed elsewhere. Do not count the same work twice or treat a dollar amount as hours.
Shared work: obtain support for facility allocation, primary roles, and contract duties. A department name or payment code alone is not enough to decide the reporting treatment. Compare the actual situation with policy manual §2.2.
Check linked identities and the daily hour limit
CMS’s August 2026 iQIES update introduced error -1025 when a System Employee ID exceeds 22.5 hours in one day, including its linked employee IDs. Review the person’s combined hours across roles and sources. CMS iQIES update.
If a result exceeds the limit, investigate duplicate files, overlapping shifts, incorrect midnight allocation, meals, and mistaken identity links. Do not cap the number automatically or move hours to another person to clear an error.
When payroll IDs change, CMS provides a linking workflow. The IDs remain separate records tied to a common system identity, and linking applies within a facility. Prepare the old-to-new ID crosswalk from confirmed employment records. CMS linking methodology.
Make the final sign-off specific
Record the facility, quarter, filing revision, reviewer, unresolved items, and submission mode. Confirm that the XML totals agree with the review workbook and audit package. For a replacement, verify that the intended replacement covers the complete quarter.
Use the submission guide to record the CMS result against that exact export. EasyPBJ supports review and follow-through; it does not establish universal regulatory compliance or submit automatically to CMS.
Official sources
Prepared with AI assistance using the CMS materials below and EasyPBJ’s filing workflow. Check CMS for later updates; facility-specific decisions require your team’s review. EasyPBJ is independent software and is not endorsed by CMS.
- CMS PBJ Policy Manual, version 2.8
August 2026 edition, posted September 11. CMS describes iQIES updates and clarifications without changes to PBJ policies. Checked September 14, 2026.
- CMS PBJ Policy Manual FAQ
August 2026 update, posted September 11. Checked September 14, 2026.
- CMS: Staffing Data Submission — PBJ
Deadline table and September 11, 2026 policy-manual and FAQ update. Checked September 14, 2026.
- CMS: Changing employee identifiers in PBJ
CMS employee-linking methodology and worked examples. Checked September 6, 2026.
Put the checklist to work.
Prepare and review your quarter in EasyPBJ free. Downloads are free up to 25 employees per facility per quarter; larger quarters are $149 every three months. Import payroll, review the details, and prepare your filing package.
Want a professional second check? Add a $49 PBJ consultant review for one facility’s quarterly filing, written findings, and one follow-up check of corrections. Your team confirms timing and payment with us before the review starts.