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State of California—Health and Human Services Agency
California Department of Public Health

AFL 17-26
November 29, 2017

All Skilled Nursing Facilities

3.2 Nursing Hours Per Patient Day (NHPPD) Staffing Audits Use of Electronic Payroll Data.

All Facilities Letter (AFL) Summary

This notice is to inform skilled nursing facilities (SNFs) that the California Department of Public Health (CDPH) is supplementing its NHPPD audit process by using electronic payroll data.

​CDPH annually conducts unannounced audits in SNFs for compliance with the 3.2 NHPPD staffing requirement, mandated by Health and Safety Code (HSC) section 1276.5 and Welfare & Institutions Code (W&I) section 14126.022. To improve the collection of NHPPD staffing audit data, CDPH will begin using the electronic payroll data that SNFs submit to the Centers for Medicare and Medicaid Services’ (CMS) Payroll Based Journal (PBJ) system. This supplemental information will:

  • increase the accuracy of the audit process,
  • decrease the duration of on-site audits, and
  • expedite the delivery of final audit results.

Beginning December 1, 2017, CDPH will supplement the on-site audit process, as outlined in AFL 11-19, with PBJ data. CDPH will continue to request paper copies of payroll records to cross-reference with PBJ data to ensure accuracy.

SNFs not submitting PBJ data must continue to comply with the existing audit requirements specified in AFL 11-19.

For questions, e-mail L&



Original signed by Jean Iacino

Jean Iacino
Deputy Director

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