Update on Medicaid Certification of Medicare-Only Beds (SNF)

As we previously shared, the state fiscal year 2025 budget directed the Michigan Department of Health and Human Services (MDHHS) to update Medicaid policy by easing restrictions on the process for dual certification of Medicare-only beds. The previous Medicaid policy made it difficult for nursing facilities with Medicare-only beds to become dually certified. That policy had several requirements, including an 8-quarter lookback on survey issues, which limited Medicaid access throughout the state. As the state implements the updated the Medicaid policy, there are some unintended consequences — including denials for some providers looking to obtain Medicaid certification for their Medicare only beds. 

MDHHS is currently implementing the policy as follows:

• MDHHS checks with the Michigan Department of Licensing and Regulatory Affairs to see if a facility is in substantial compliance at the time of application (which generally occurs before the quarter due date, which is 45 days before the start of a new quarter). 
• If any survey activity occurs between the time of application and the quarter due date, MDHHS will check to see if there is an approved plan of correction.
• If there is survey activity and the facility has not received an approved plan of correction before the quarter due date, MDHHS will deny the application.

The department’s application of this policy means that a facility may be in compliance when they submit an application for dual certification of Medicare-only beds; however, that facility may then be denied based on subsequent survey activity that occurs after application submission. 

For example:

• A facility is in compliance as of 4/10 and applies for dual certification of MO beds.
• The facility has a complaint survey on 5/10.
• Facility receives an approved plan of correction on 6/1.
• This facility would be denied, as there was survey activity without an approved plan of correction as of 5/16.

We wanted to make you aware of this as you determine when to submit your application. HCAM is diligently working with MDHHS to modify this policy to prevent facilities from being denied because of how Plans of Correction are timed. MDHHS told us that they are receptive to addressing this issue.