MDHHS Provides Reminder Regarding COVID Relief Facilities (SNF)

The Michigan Department of Health and Human Services (MDHHS) is reconfirming the recent changes for COVID Relief Facilities (CRF). MDHHS put a hold on the CRF renewals for state Fiscal Year 2023 until January 31, 2023. Further guidance on these facilities will be released in January.

During this interim period, your facility’s current CRF designation will remain the same. Below are links to the current policy along with information about when a capacity change is needed. The capacity change policy was recently updated, so please review these documents and only request changes if needed.

COVID-Relief Facilities

This is the current MDHHS Policy, MSA 21-40, along with the current Provider Letters, L 22-52: FY 23 Application Period Postponement and L 21-85: FY 22 Staffing Criteria.

MDHHS has received several capacity change applications that were not necessary based on the latest guidelines. Please follow the recently updated guidance outlined in L 22-52 as to when it is appropriate to submit a capacity change request.

For Tier 1 Facilities:

• Capacity change notice must be submitted for location changes of COVID unit.
• Capacity change notice must be submitted only if your facility requires a LARGE increase or decrease (more than 10 beds) to your COVID unit.
• Tier 1 facilities may flex their COVID unit down to 1 bed or up to an additional 10 beds WITHOUT a capacity change request. If an outbreak exceeds the additional 10 beds, the facility must then submit a capacity change notice.

For Tier 2 Facilities:

• Capacity change notice must be submitted for location changes of COVID unit.
• Capacity change notice must be submitted for any increase or decrease in the number of beds in their COVID unit — this includes a per-bed change.

The MDHHS Infection Prevention Resource and Assessment Team is available to support facilities with infection prevention guidance and best practices: [email protected]. MDHHS also provides additional guidance through resources on the Long Term Care COVID-19 Plan webpage.

CMS Posts Medicare Program Integrity Manual Updates (SNF) 

Changes Affect SNF Enrollment, CHOWs, and Reenrollment Beginning January 2023

CMS posted a display copy of updates to the calendar year Final Rule for the 2023 Medicare Physician Fee Schedule, other Medicare Part B policies, and Medicare and Medicaid provider enrollment policies. Many of these updates impact skilled nursing providers. 

Most notably – effective January 6, 2023 – SNFs that are initially enrolling or undergoing a change in ownership (CHOW) fall within the “high” screening category under 42 CFR § 424.518. SNF revalidations are processed at the “moderate” screening level. These changes include the addition of site visits for all SNF providers and fingerprint-based criminal background checks for 5% or greater direct and indirect owners at specific times. 

The Federal Register version of the Final Rule will be posted November 18.

AHCA/NCAL developed a detailed summary of the changes impacting SNF provider enrollment, revalidation, CHOW, and reenrollment. Note: A member login is required to view the summary. Please email Dan Ciolek with any questions.