AI StaffingAI Labor LawAI AdmissionsAI DSD & HRBlogLaunch Workspace
Back to the Blog
Staffing10 min read

PBJ Submission Checklist: Due Dates and iQIES

Last updated:

A practical PBJ submission checklist for skilled nursing operators: quarter deadlines, what hours count, iQIES access steps, validation timing, and the controls that keep a file from failing after upload.

Direct answer

PBJ staffing data for covered nursing homes is due by 11:59 p.m. Eastern Time on the 45th calendar day after each federal fiscal quarter, and as of October 23, 2026 it must be submitted through iQIES, not QIES. The checklist applies to Medicare- and Medicaid-certified long-term care facilities subject to 42 CFR Part 483, Subpart B.

Key takeaways

  • PBJ is a quarterly federal filing for covered long-term care facilities, and the next deadline for July 1 through September 30, 2026 data is November 14, 2026 at 11:59 p.m. Eastern Time.
  • As of August 17, 2026, PBJ submissions moved to iQIES; QIES became read-only that day and PBJ in QIES was retired on September 15, 2026.
  • Operators should verify iQIES access before quarter end because PBJ Submitter access requires a HARP account, role request, facility selection, and PSO approval.
  • PBJ hours must reflect paid hours delivering services by calendar day, exclude meal breaks and leave, and split overnight hours at midnight.
  • An upload is not the finish line; CMS says the Final Validation Report can take up to 24 hours, and missed submissions can produce a one-star staffing rating for the quarter.

Last updated: October 23, 2026

A nursing home's PBJ file usually goes sideways before upload night. The submitter cannot get into iQIES, a payroll export still includes meal breaks, an overnight shift was not split at midnight, or recent discharges were not closed in MDS and the denominator now makes staffing look thinner than the floor felt. The fix is a quarter-end checklist that starts before day 45, not a last-minute upload.

What is the PBJ deadline for nursing homes?

PBJ submissions are due by the end of the 45th calendar day after each federal fiscal quarter, and CMS states the cutoff is 11:59 p.m. Eastern Time. For data from July 1 through September 30, 2026, the filing deadline is November 14, 2026. CMS also states that the system will not accept submissions after the deadline.

PBJ quarter-end dates and controls

Quarter or checkpointDate or timingWhat to finishWhy it matters
July 1-September 30, 2026 dataNovember 14, 2026, 11:59 p.m. ETUpload, review validation output, correct rejected records, rerun checksCMS will not accept late PBJ submissions
Every PBJ quarter45th calendar day after quarter endConfirm access, reconcile hours, check MDS discharge timeliness, archive proofThe deadline is fixed even if access or data issues surface late
After each uploadUp to 24 hours for Final Validation ReportReview validation results and PBJ reportsUpload alone does not prove accepted, clean data

Who has to file PBJ, and who does not?

PBJ applies to long-term care facilities subject to 42 CFR Part 483, Subpart B. CMS guidance says the requirement does not apply to swing beds. For operators, the first checklist question is not whether payroll exported cleanly. It is whether the facility is actually in PBJ scope and whether the submission is tied to the correct facility record.

What changed with PBJ in iQIES in 2026?

The filing obligation stayed the same, but the system changed. CMS launched PBJ in iQIES on August 17, 2026, made QIES read-only for PBJ that day, and retired PBJ in QIES on September 15, 2026. If your internal SOP still tells staff to finish PBJ in QIES, that workflow is out of date.

What access does a facility need before it can submit PBJ in iQIES?

Current CMS and QTSO guidance points to four access steps: create a HARP account, request the appropriate iQIES PBJ role, select the organization by CCN or Facility ID, and obtain approval from the facility's Provider Security Official. PBJ Submitter access allows upload, edit, and view functions. PBJ Viewer access is view-only. Vendors and corporate users still need facility-specific approval.

iQIES access checkpoints for PBJ

Access itemWhat CMS/QTSO saysWhy to test it before deadline week
HARP accountRequired before requesting iQIES accessNo HARP account means no PBJ role request can move forward
PBJ rolePBJ Submitter can upload, edit, and view; PBJ Viewer is view-onlyA viewer cannot finish a filing if the submitter is unavailable
Organization selectionUser must add the facility by CCN or Facility IDA user with the wrong organization selected cannot work the right facility file
PSO approvalProvider Security Official must approve role accessAccess delays can stop filing even when payroll data is ready

What staffing data has to be in the PBJ file?

The governing rule requires complete and accurate direct-care staffing information, including agency and contract staff, the category of work for each direct-care person, hours worked by day, turnover or tenure information, and whether each worker is a facility employee or outside staff. In practice, the quarter needs both the daily hours and the worker classification to be complete.

What hours count for PBJ, and what hours should stay out?

CMS instructs facilities to report hours paid to deliver services for each day worked. Meal breaks, leave, and other non-worked paid time should not be counted, and overnight shifts must be split at midnight because PBJ is reported by calendar day. Current technical guidance also requires fileSpecVersion 4.10.0 for file submissions and caps reportable hours at 22.5 hours per day per staff member.

  • Deduct meal breaks from reportable hours.
  • Do not count vacation, sick leave, or other leave hours as worked hours.
  • Split overnight shifts at 12:00 a.m. so hours land on the correct calendar day.
  • Check for any employee ID over 22.5 hours in one day before upload.
  • Confirm job code and employee-versus-agency status before final submission.

Why does MDS discharge timing affect PBJ staffing results?

Because CMS currently uses MDS data to calculate the PBJ resident census rather than a current PBJ census entry. CMS warns that failure to submit discharge assessments can overstate census, which then lowers calculated staffing levels. A building can feel appropriately covered on the floor and still look thinner in PBJ if the census denominator is inflated.

That is why PBJ is not only a payroll or scheduler task. Payroll, staffing, MDS, and whoever closes discharges all affect the final quarter. If your team waits until after upload to look at the denominator, the reporting problem is already baked in.

What should the quarter-end PBJ checklist look like?

A workable checklist has three layers: access, data, and acceptance proof. Access means the submitter can get into iQIES now, not on deadline night. Data means the file reflects reportable hours and correct worker categories. Acceptance proof means the facility reviewed the Final Validation Report and the post-submission PBJ reports rather than treating upload as the finish line.

Quarter-end PBJ submission checklist for a skilled nursing facility

StepOwnerWhat to verifyProof to keep
1. Confirm filing scope and quarterAdministrator or staffing leadFacility is PBJ-covered and the correct quarter is selectedInternal quarter-close checklist
2. Test iQIES accessPBJ submitter or vendorHARP account active, PBJ role approved, facility linked, PSO available if changes are neededScreenshot or access confirmation email
3. Reconcile staffing source dataPayroll, scheduler, vendorEmployee, agency, and contract hours match source records by dayPayroll reports, invoices, contracts
4. Review counting rulesPayroll or compliance leadMeal breaks removed, leave excluded, overnight shifts split at midnightReconciliation notes or exception log
5. Check MDS discharge timelinessMDS coordinatorRecent discharges submitted so census denominator is not overstatedMDS completion report
6. Validate file formatVendor or submitterFileSpecVersion 4.10.0 used if filing by file; ZIP under 5 MB; correct quarter availableExport settings or file log
7. Upload earlyPBJ submitterSubmission completed before the deadline, leaving time for correctionsUpload confirmation
8. Review Final Validation ReportPBJ submitterRejected or warning records addressed before cutoffValidation report archive
9. Review PBJ reportsStaffing or compliance leadStaffing and census reports look reasonable for the quarterSaved report PDFs or screenshots
10. Archive audit trailAdministrator or compliance leadSource records can be traced back for auditRetention folder with payroll, invoices, contracts, and reports

What does a simple PBJ dry run look like before deadline week?

Example: a building closes its internal PBJ review 7 days before the CMS deadline and has 3 rejected records after its first upload. If the team uploads on day 44 instead of day 45, it still has time to correct those records, wait up to 24 hours for the Final Validation Report, and confirm the accepted file before the 11:59 p.m. Eastern Time cutoff. The numbers in this example are invented, but the timing risk is real.

What if the facility uses a PBJ vendor?

A vendor can handle part of the mechanics, but CMS says the nursing home remains ultimately responsible for the submission. That means vendor use should not replace the facility's own acceptance check. The building still needs its own filing calendar, a backup access plan, and a saved copy of the validation and follow-up reports.

If you are deciding between PBJ via a vendor platform vs direct iQIES submission, make the handoff explicit: who reviews rejected records, who watches the 45-day clock, and who confirms the final file actually cleared.

What should a facility review after the upload finishes?

Review the Final Validation Report first, because CMS says it may take up to 24 hours to appear. Then review the PBJ staffing and census reports in iQIES for reasonableness. A successful upload is not the same as a clean quarter. The real finish line is accepted data that matches the facility's underlying records.

How does this connect to daily staffing operations?

ePeople AI, compliance software for skilled nursing facilities, fits the operating problem behind PBJ rather than the filing screen alone. AI PPD Staff Planning & Scheduling schedules against the building's PPD requirement and flags a staffing gap while the shift can still be filled.

What changes when software does this work is not that CMS disappears. It is that the team can see coverage risk, open shifts, and missing hours earlier, while the schedule can still be corrected. That gives quarter-end PBJ review a better starting point than a last-minute reconstruction from payroll exports.

For adjacent staffing questions, operators usually look next at PBJ audit prep, weekend PPD gaps on Care Compare, and how public staffing outputs can misread a building when denominator or submission workflow issues are present in Care Compare PPD gaps in skilled nursing.

Frequently asked questions

When is PBJ due each quarter?

PBJ is due by 11:59 p.m. Eastern Time on the 45th calendar day after the end of each federal fiscal quarter. For July 1 through September 30, 2026 data, the deadline is November 14, 2026. CMS states that the PBJ system will not accept submissions after the deadline.

Do nursing homes still submit PBJ through QIES?

No. As of August 17, 2026, PBJ submissions must be made in iQIES. CMS made QIES read-only for PBJ on August 17, 2026 and retired PBJ in QIES on September 15, 2026. Any internal PBJ SOP that still points staff to QIES should be updated.

What hours should be excluded from PBJ reporting?

PBJ should reflect paid hours worked delivering services, not every paid hour on payroll. CMS says to exclude meal breaks, leave, and other non-worked paid time, and to report hours by calendar day. Overnight shifts must be split at midnight so each day is reported accurately.

Does PBJ require reporting agency and contract staff?

Yes. The PBJ rule requires complete and accurate direct-care staffing information that includes agency and contract staff, along with the category of work and whether the person is a facility employee or outside staff. Leaving outside labor out of the quarter can make the submission incomplete.

Why can MDS errors affect PBJ staffing results?

CMS currently uses MDS data to calculate the PBJ resident census denominator. If discharge assessments are missing or late, census can appear higher than it should, which makes staffing levels appear lower. That is why PBJ review should include MDS discharge timing, not just payroll and schedule reconciliation.

What report should a facility review after uploading PBJ data?

The facility should review the Final Validation Report after upload and then check the PBJ staffing and census reports in iQIES. CMS says the validation report may take up to 24 hours. Uploading a file is not enough if rejected records or unreasonable totals still remain in the quarter.

Sources

ePeople.ai logo

Keep PBJ cleanup from starting on day 45

[ePeople AI](https://epeople.ai), compliance software for skilled nursing facilities, helps staffing teams work from the schedule instead of rebuilding quarter-end proof by hand. [AI PPD Staff Planning & Scheduling](/staffing-perfection/) schedules against the building's PPD requirement and flags a staffing gap while the shift can still be filled.

15-minute focused walkthrough Β· We respect your privacy β€” your information is never shared