3.4 HPRD Direct Care Reporting Requirements

A letter regarding Quarter 1 and Quarter 2 fines can be found here.

Per RCW 74.42.360, it is now a requirement that facilities have 3.4 hours per resident day (HPRD) of direct care staff. For the purposes of this law, direct care staff are RNs, LPNs, and CNAs. Additionally, if you do not meet the 3.4 hours with the previously listed staff, you may count geriatric behavioral health workers, as defined in RCW 74.42.010. For the geriatric behavioral health worker exception, the worker must: (1) have at least three years’ experience providing care for individuals with chronic mental health issues, dementia, or intellectual and developmental disabilities in a long-term care or behavioral health care setting, (2) have advanced practice knowledge in aging, disability, mental illness, Alzheimer’s disease, and developmental disabilities, and (3) be supervised by an employee with a master’s degree in social work or a registered nurse if the worker holds less than a master’s degree in social work.

The Centers for Medicare and Medicaid Services (CMS) is collecting this information via the Payroll Based Journal (PBJ). Previously, the Department had been collecting information from each facility in order to determine compliance with the 3.4 requirements found in RCW 74.42.360. The RCW instructs the Department to utilize the data from the CMS Payroll Based Journal (PBJ) for oversight, but at the time of roll-out, this data was not available. CMS has begun releasing this data; therefore, the Department will now use PBJ data for determination of compliance.

The PBJ data is available to the Department approximately two quarters after the quarter that the data was due. This means that there is a two-quarter lag on the data the Department receives. You do not need to submit 3.4 HPRD reports to the Department starting with Quarter 3, 2018, as long as you submit the PBJ report to CMS. Full information about the transition can be found in this Dear Administrator Letter.

If for any reason, you are not required to submit payroll data to CMS, you must continue to submit your hours directly to the Department on a survey sheet. Additionally, if you are relying on geriatric behavioral health worker hours to meet the 3.4 requirement, those hours will need to be submitted directly to the Department, as they are not captured in the PBJ.

Survey sheets and geriatric behavioral health sheets should be submitted electronically to: nfrates@dshs.wa.gov, with the subject line saying: 3.4 HPRD Quarterly Reporting. If you have any questions about the survey sheet or the 3.4 HPRD requirement, please contact Melissa Ayala, HPRD Lead, at (360) 725-2416 or Melissa.Ayala@dshs.wa.gov, or Tiffany Hills, Nursing Facility Rates Manager, at (360) 995-2809 or Tiffany.Hills@dshs.wa.gov.