3.4 HPRD Direct Care Reporting Requirements

3.4 HPRD Direct Care Reporting Requirements

As part of SHB 2678, 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 Center for Medicare and Medicaid Services (CMS) is collecting this information via the Payroll Based Journal (PBJ).  Up till now, the Department has 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.



There will be a transition period. This is due to the timing of the availability of the data from CMS. The PBJ data is available to the Department approximately two quarters after the quarter that the data was due. This means that as we switch to the PBJ data, there will be a two-quarter lag on the data the Department receives. This lag will start immediately. 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. This does not mean those quarters will not be counted. All quarters will still be counted, but there will now be a longer period of time between when the quarter data that is submitted to CMS and our Departments examination of those hours, as the Department will not receive the data until approximately two quarters after it was submitted to CMS. Thus, the 3rd quarter, 2018, 3.4 data will be examined in January 2019.  Full information about the transition can be found in this Dear Admin 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.


For informational purposes, we are providing a comparison of the 3.4 HPRD totals for 2017 submitted to DSHS vs PBJ so you can get an idea about how the switch may affect your facility.


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 Jamie Franzen, HPRD Lead, at (360) 725-2438 or Jamie.Franzen@dshs.wa.gov, or Tiffany Hills, Nursing Facility Rates Manager, at (360) 725-2472 or Tiffany.Hills@dshs.wa.gov.

Upcoming Deadlines if turning in a survey sheet or geriatric hours

1st Quarter – Due to DSHS by May 30th each year

2nd Quarter  – Due to DSHS by August 29 each year

3rd Quarter – Due to DSHS by November 29th each year

4th Quarter – Due to DSHS by March 1st each year


Forms and Documents

Letter to Facilities dated 10/10/2018

Survey Sheet

Geriatric Behavioral Health Sheet

2017 HPRD Totals - DSHS vs PBJ Comparison

Letter to Facilities dated 2/23/17

3.4 HPRD 2016 Quarter 3 Results

3.4 HPRD 2016 Quarter 4 Results

3.4 HPRD 2017 Quarter 1 Results

3.4 HPRD 2017 Quarter 2 Results

3.4 HPRD 2017 Quarter 3 Results 

3.4 HPRD 2017 Quarter 4 Results

3.4 HPRD 2018 Quarter 1 Results

3.4 HPRD 2018 Quarter 2 Results