September 2 Newsletter

 

 

 

 

September 2, 2026

 

 

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Bill Introduced Would Require Nursing Facilities to Report Additional Information

Introduced last week, House Bill 6267 would require nursing facilities to report additional information about payments to related parties on their Medicaid cost reports. The bill follows assertions made in a report published last year by the Michigan Elder Justice Initiative (MEJI), which claims providers can conceal profits through payments to related parties and recommends several policy changes.

HCAM maintains that oversight bodies already have tools to promote transparency and protect the integrity of the Medicaid program. The association will continue educating policymakers about the existing oversight framework and will engage as needed if the bill progresses.

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House Passes Bill Allowing for CNA and Med Aide License Fee Increases

Senate Bill 569 allows the Department of Licensing and Regulatory Affairs (LARA) to increase, within specified limits, the annual fees for nurse aides, nurse aide trainers, medication aides and medication aide trainers. The bill also authorizes LARA to impose a $75 late fee for renewal applications submitted after a permit expires. The Senate passed the bill on July 3 as part of budget negotiations with the House. The House passed the bill last week, and the Governor is expected to sign it.

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NDM Facilities Can Exceed the 100-Bed Limit Under Certain CON Standards

CON Standards Update: Nursing facilities designated as New Design Model (NDM) facilities under the Certificate of Need (CON) standards may exceed the 100-bed limit in certain circumstances.

The Michigan Department of Health and Human Services (MDHHS) uses the New Design Model (NDM) through the Medicaid program and CON standards to encourage semi-private and private rooms and modernize nursing facilities. Several sections of the current CON standards limit NDM facilities to 100 beds. However, Section 8, which governs the relocation of beds from one facility to another within the same planning area, does not include that limitation.

This distinction gives providers greater flexibility to respond to clinical and market changes while supporting quality care for residents.

CON staff previously interpreted the standards as a whole to limit NDM facilities to 100 beds. HCAM engaged with CON staff to clarify the standards and establish that providers can add relocated beds beyond that limit.

HCAM supports this flexibility and believes the CON standards should provide similar operational flexibility in Sections 6, 7 and 9. HCAM will request that CON staff review the standards during the next review process and clarify the allowance in those sections.

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MDHHS Extends Current Non-Available Bed Plan Policy Through December 31

The Michigan Department of Health and Human Services (MDHHS) temporarily extended the current Nursing Facility Non-Available Bed Plan (NABP) policy through December 31, 2026.

MDHHS issued MMP 26-38 on September 1, extending the policy that was scheduled to expire September 30. According to MDHHS, this three-month extension will allow time to review feedback received during the public comment period before issuing a final version of proposed policy 2630-NF.

What Facilities Need to Know
♦ Existing NABPs: Facilities that have an existing NABP and want to continue their plan must submit an extension request to MDHHS by October 30, 2026.
♦ New NABPs: Facilities may continue to submit requests for new NABPs during the extension period.
♦ Expiration date: Any extension or new NABP approved during this period will expire December 31, 2026, regardless of when it was approved.
♦ Current requirements remain in effect: All other provisions of the current MMP 25-35 policy will remain in effect through December 31.

Proposed Changes Delayed
The extension also means the changes included in MDHHS’ recently proposed NABP policy will not take effect October 1 as originally proposed.
Facilities should continue to follow the existing NABP requirements while MDHHS completes its review of stakeholder comments. The proposed changes include revisions related to:
♦ Non-contiguous and private rooms
♦ The length and extension of NABPs
♦ Other NABP plan requirements

MDHHS will issue further guidance when a final policy is released. HCAM will continue working with MDHHS throughout this process and advocate for a final NABP policy that provides nursing facilities with greater flexibility in managing their non-available beds. HCAM will keep members informed as additional guidance and the final policy become available.

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Medicaid Long-Term Care Reimbursement Rates Effective October 1

The Michigan Department of Health and Human Services calculated the Medicaid Annual Provider Reimbursement Rates effective for dates of service on or after October 1, 2026. The notices are now available to providers, by accessing MILogin and entering the CHAMPS application. The reimbursement rate calculation and notice are under the “Archived Documents” section for each provider under the provider’s National Provider Identification number. If you have trouble accessing MILogin or Archived Documents, please email [email protected] or call (800) 292-2550. Direct questions regarding your provider specific reimbursement rate calculation notice to [email protected].

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New HCAM Member Benefit: Michigan SNF Billing Network Online Forum

HCAM is excited to launch the Michigan SNF Billing Network, a new private online community designed specifically for skilled nursing facility billing professionals. Hosted through AHCA/NCAL Connect, this member-only forum provides a secure space to ask questions, share resources, discuss payer issues and connect with peers across Michigan. Participation is included with your HCAM membership, and members can customize how they receive discussion notifications, including real-time emails or daily digests. If you are interested in joining the Michigan SNF Billing Network, email Michael Batts for more information and enrollment details.

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Study Highlights Medicare Advantage Challenges for High-Need Beneficiaries

A new study published in JAMA Health Forum found that Medicare Advantage (MA) beneficiaries are increasingly likely to leave their plans and return to Traditional Medicare after developing complex medical conditions such as Alzheimer’s disease, chronic kidney disease, congestive heart failure, stroke or COPD. Researchers found that disenrollment rates increased as beneficiaries’ medical needs became more complex, raising concerns about access to timely and medically necessary care. The findings add to ongoing concerns about prior authorization requirements and other administrative barriers that can affect access to post-acute and skilled nursing care. In response, AHCA/NCAL continues to support reforms aimed at improving transparency, accountability, and access to care within the Medicare Advantage program. Read the study in the JAMA Health Forum

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CMS Updates SNF Validation Process FAQs (SNF)

The Centers for Medicare & Medicaid Services (CMS) has updated its Skilled Nursing Facility (SNF) Data Validation Process Frequently Asked Questions (FAQs) with several changes providers should note. 

Key Changes 
♦ Quarterly selection schedule. CMS now specifies that SNF data validation selection notifications will be released in February, May, August, and November each year. In addition to posting the selection notice in the MDS 3.0 Provider Preview Reports folder in iQIES, CMS will also send an email alert to active email addresses associated with the selected SNF’s iQIES accounts. 
♦ Annual Validation Summary Reports. CMS previously indicated that facilities would receive Validation Summary Reports within three months of the medical record submission deadline. The updated FAQ states that reports will now be uploaded to iQIES annually. CMS also clarified that it will not provide case-specific explanations of individual validation findings. 
♦ New guidance on PII and PHI. CMS added guidance for situations in which personally identifiable information (PII) or protected health information (PHI) is inadvertently emailed to the SNF Data Validation Help Desk. Such emails will be flagged as a breach, and the sender will be instructed to delete the email and attachments and submit the information through the secure portal. 
♦ New Help Desk email. SNFs should now direct data validation questions to [email protected], which replaces the previous contractor email address. 

What Providers Should Do 
With the updated information in the FAQ document, SNFs should: 
♦ Monitor iQIES during February, May, August and November for selection notices. 
♦ Verify iQIES user accounts and email addresses are active and current. 
♦ Update internal materials (as applicable) with the new SNF Data Validation Help Desk email address. 
♦ Remind staff not to send PII, PHI, medical records or selection notices by email. 
♦ Plan for Validation Summary Reports to be posted annually rather than within three months of record submission

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AHCA Lauches Training on Expanded Risk-Based Survey Process (SNF)

As we previously reported, the Centers for Medicare and Medicaid Services (CMS) is expanding the Risk-Based Survey (RBS) process nationwide, creating a more focused survey experience for qualifying high-performing nursing facilities. New: The American Health Care Association (AHCA) launched an education program to help nursing facilities understand Risk-Based Surveys and strengthen readiness to qualify for and maintain RBS eligibility. Called Chasing the Trophy, the training explains how RBS differs from the traditional Long-Term Care Survey Process (LTCSP), the criteria used to determine and maintain eligibility, and the circumstances that may trigger disqualification or conversion to a standard survey. 

Participants will examine updated survey procedures, resident screening and facility tasks, and practical strategies for strengthening readiness in key areas, including Five-Star performance, PBJ reporting, MDS and schizophrenia coding, infection prevention, staffing and complaint management. Attendees will also learn how to use LTC Trend Tracker data to monitor performance, identify risks, and support continuous quality improvement. 

Designed for nursing facility administrators, clinical leaders, quality professionals, and regulatory staff, this session provides actionable guidance to help organizations pursue and sustain RBS eligibility. Registration is free to HCAM/AHCA members; $150 for non-members. Registration includes the three-part webinar series along with two additional handouts: a Risk-Based Survey FAQ and Resources Related to RBS Disqualifications.

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CMS Offers Two New Web-Based Training Options (SNF)

The Centers for Medicare & Medicaid Services (CMS) is offering two new web-based training programs:

SNF QRP Training on APU Compliance: Provides an overview of the Skilled Nursing Facility Quality Reporting Program (QRP), including its purpose, structure and the SNF QRP Life Cycle. It reviews required data collection and submission timelines, reporting requirements, data completion thresholds, and the Minimum Data Set (MDS) Data Validation Process. The course also addresses the Extraordinary Circumstances Exception (ECE) and the reconsideration request processes.  

MDS Education Resources for Assessment Types and Timing: Provides an overview of Chapter 2 of the Resident Assessment Instrument. The course reviews RAI requirements for OBRA and PPS assessments, including:  
♦ Assessment types  
♦ Timing and scheduling requirements 
♦ Discharge assessment determination 
♦ Interrupted stay considerations 
♦ And combined assessments

Questions about accessing resources or feedback about training? Email the PAC Training Mailbox. Content-related questions? Email SNF QRP Help Desk. 

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Bill to Change AFC Licensing Act Introduced (AFC)

On August 27, 2026, a three-bill package, HB 6320, 6321, 6322, was introduced to change the Adult Foster Care Facility Licensing Act. Recall that in 2025, a similar bill known as “Theresa’s Law” was introduced. The initial version of the bill introduced last year included staffing ratios, fines and stringent training requirements. While this year’s version is slightly less concerning that last year’s bill, there are still concerns about the negative impacts it would have on Adult Foster Care providers if signed into law. HCAM will continue advocacy efforts to engage with the bill sponsor, legislative leaders and the Department of Licensing and Regulatory Affairs.

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Michigan State Licensing System is Now Live (HFA)

The Michigan Department of Licensing and Regulatory Affairs Bureau of Community and Health Systems launched the new Michigan State Licensing System (MI-SLS). This will be used by Home for the Aged providers for licensing activities. The new system will start when you access your MiLogin account. Additional information can be found on the bureau’s website.

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