MDHHS Issues Letter Clarifying Time Study Submission Requirements (SNF)

The Michigan Department of Health and Human Services (MDHHS) released L letter 24-81 to remind nursing facilities that actual time spent taken from payroll records, assignment schedules, sign-in sheets, etc. are the preferred cost allocation method for Medicaid cost reporting. Providers wishing to use time studies in lieu of actual time keeping records must obtain approval from the Reimbursement and Rate Setting Section prior to changing the cost allocation method. The request must identify the reason for the change and demonstrate that the proposed method is representative of actual staffing costs within the facility and results in an equitable and accurate allocation of staffing costs. Accurate and complete information must be included in the submission of cost report data or upon request from MDHHS. Failure to submit accurate time study or time keeping records could result in associated costs being disallowed. The CMS provider reimbursement manual provides criteria regarding the appropriate use of time studies.