LeadingAge Michigan Leadership Institute August 12, Understanding the State Licensing and Federal Certification Processes
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1 LeadingAge Michigan Leadership Institute August 12, 2015 Understanding the State Licensing and Federal Certification Processes Presenters: Larry Horvath, Director Bureau of Community and Health Systems
2 Presentation Overview State Organizational Structure Understanding the State Licensure Process Understanding the Federal Certification Process What to Look for in the Future Questions and Answers
3 State Organization Structure Bureau of Community & Health Systems (BCHS) Effective July 6, 2015 State Licensing of Health Facilities, Agencies and Programs Federal Certification of Providers and Suppliers on Behalf of the Centers for Medicare and Medicaid Services (CMS) State Licensing of Child Care Centers State Licensing of Adult Foster Care/Homes for the Aged Construction Permits of State Licensed Health Facilities Life Safety Code Inspections of Long Term Care Facilities
4 No. of Providers Type 10,058 Child Care Centers Michigan Covered Providers (As of April 2015) * Some federal oversight for organ procurement organizations (1) and federally qualified health centers (196). 8,348 Clinical Laboratory Services 4,291 Adult Foster Care Homes 1,284 Substance Use Disorder Programs 1,031 Adult Foster Care/Child Camps 646 Home Health Agencies 452 Nursing Homes/LTC Facilities 218 Homes for the Aged 197 Dialysis Centers (ESRD) 169 Hospitals 162 Outpatient Physical Therapy (OPT)/Speech Pathology 160 Rural Health Clinics (RHC) 133 Freestanding Surgical Outpatient Facilities/ASC 131 Hospice Agencies 59 Inpatient Psychiatric Hospitals/Units 30 Psychiatric Partial Hospitalization Programs 18 Hospice Residences 9 Organ Transplant Facilities 9 Portable X-Ray Providers 6 Comprehensive Outpatient Rehab Facilities (CORF)
5 State Federal Type YES No Child Care Centers BCHS State/Federal Oversight by Covered Providers YES* YES Clinical Laboratory Services YES NO Adult Foster Care Homes YES NO Substance Used Disorder Programs NO YES Home Health Agencies YES YES Nursing Homes/LTC Facilities YES NO Homes for the Aged NO YES Dialysis Centers (ESRD) YES YES Hospitals NO YES Outpatient Physical Therapy (OPT)/Speech Pathology NO YES Rural Health Clinics (RHC) YES YES Freestanding Surgical Outpatient Facilities/ASC YES YES Hospice Agencies YES YES Inpatient Psychiatric Hospitals/Units * No state license required as of October 1, YES* NO Psychiatric Partial Hospitalization Programs YES YES Hospice Residences NO YES Organ Transplant Facilities NO YES Portable X-Ray Providers NO YES Comprehensive Outpatient Rehab Facilities (CORF)
6 Regulatory Overview Sample of Events Requiring State/Federal Approval: Initiation/renewal of a state license (required) Initiation/recertification for federal certification to participate in Medicare/Medicaid (voluntary) Change of ownership (change in licensee/owner) Relocation Multi-Site Locations Increase or decrease in beds Change in information (administrator/agency name)
7 Regulatory Overview Sample of Agencies Involved: Certificate of Need - DHHS (Hospice residences w/ LTC beds) Construction Permit - Health Facilities Engineering, BCHS, LARA (Hospice residences) Fire Safety Certification Bureau of Fire Services (BFS), LARA (Hospice residences) Bureau of Community and Health Systems (State Licensing/Federal Certification), LARA Health Professional Licensing, Bureau of Professional Licensing, LARA Centers for Medicare and Medicaid Services (CMS) WPS, NGS and AOs
8 General Overview State Licensure Initial licensure Routine Inspections Complaints Renewal Enforcement Federal Certification Initial certification Routine inspections Complaints Recertification Enforcement
9 Survey Process Overview Entrance conference Review of survey process and methodologies Request for documents Medical record review - EHR-Navigator Tour/observations Policy and procedure reviews Interviews Exit conference * Non-cooperation could end survey process and require state agency to recommend termination to CMS.
10 CMS Hospice Tier Workload for FY 2015 (Sample) (Impact Act 2014 All hospices surveyed within 36 months by April 2018): NON-DEEMED HOSPICES (34) Tier 1 Tier 2 Tier 3 Tier 4 Complaints non-ij high must be initiated within 45 days 36.9-Month maximum interval Federal Workload Priorities None 30.9-month average/goal 24.9 months Surveys of de-activated Hospices that have not billed Medicare for 12 months prior to re-activating Initial surveys following a CHOW where the provider agreement does not convey to the new owner New providers DEEMED HOSPICES (80) Tier 1 Tier 2 Tier 3 Tier 4 Validation surveys (2) Complaints non-ij high must be initiated None New providers Complaint prioritized as immediate jeopardy within 45 days
11 No. of Providers State 120 Illinois 143 Ohio 115 Missouri 114 Michigan 87 Indiana 87 Iowa 72 Wisconsin 71 Kansas 69 Minnesota 42 Nebraska CMS FY14 Midwest Data Hospice Average No. of Deficiencies Cited During Standard Survey State 12.3 Indiana 7.9 Kansas 7.6 Michigan 7.0 Iowa 4.9 Minnesota 4.3 Missouri 4.3 Illinois 1.1 Ohio 0.9 Wisconsin 0.5 Nebraska 3.2 National Average
12 CMS FY14 Midwest Data Nursing Homes No. of Providers State 959 Ohio 772 Illinois 531 Indiana 517 Missouri 451 Iowa 434 Michigan 393 Wisconsin 381 Minnesota 356 Kansas 223 Nebraska Percent of Surveys with Condition Level Citations State 9.3 Kansas 6.3 Minnesota 6.2 Wisconsin 5.9 Michigan 5.8 Indiana 5.8 Missouri 5.4 Illinois 5.4 Nebraska 4.0 Iowa 3.9 Ohio 5.7 National Average
13 What to look for in the future Current areas of need: Background checks Life safety code surveys Updates IDR/IIDR Public Act 104 of 2015 effective October 1, 2015 Areas for improvement?
14 Questions & Answers Bureau of Community and Health Systems Ottawa Building, 1 st Floor 611 W Ottawa Street Lansing, MI Main Line: (517) Thank you for your efforts to provide quality health care to Michigan residents.
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