Michelle Roepke, Director Federal Survey and Certification Division of the Michigan Bureau of Community Health Services (BCHS) shared additional information and clarification regarding Directed Plans of Correction (DPOC) for F-880 citations.
Ms. Roepke clarified that Enforcement Letters (EL) issued likely are confusing as they must contain information addressing the requirements for a DPOC for F-880 when applicable, along with requirements for submitting a Plan of Correction (POC) for any other citations. Some guidelines to follow if receiving notice of a DPOC:
- The 11 required elements of the DPOC are included in your Enforcement Letter
- Your response and plan to address these 11 elements should be submitted within 15 calendar days of receipt of your EL. Providers will not be penalized for a late submission past the 15 calendar days, however should simply be aware the enforcement window will remain open for an extended period.
- Submission of the plan to address the 11 elements of the DPOC constitutes alleged compliance with the DPOC directives and will be used as a basis for a desk review, if eligible. The Survey Manager may request additional documentation at the time of review to support compliance with the plan.
- The provider must contract with a clinical consultant meeting criteria as outlined in the EL.
o BCHS is clarifying the definition and length of time as it pertains to "affiliation" with an organization or individual provider
o Organizations / Providers may work together to share clinical consultants between organizations as a means of meeting the criteria
- Date of compliance for a DPOC should be established using current criteria and submitted as part of your DPOC plan.
HCAM is working with department leadership to re-evaluate the DPOC elements as they apply to citations ranging from a scope & severity of D to L. As additional information or changes are available we will share with members.
Medicaid Resumes Processing of Cost Report Settlements and Repayment Schedules
MDHHS issued a notice through file transfer to all Medicaid providers of their decision to resume the processing of cost report settlements and repayment schedules. The processing of settlements and repayment schedules were halted in March as a response to the pandemic. Below is the announcement regarding this resumption. Facilities should watch in file transfer for the notices regarding the processing of these settlements.
On March 25, 2020, MDHHS temporarily suspended the collection of LTC settlements (both initial and final). Since that date, the LTC Reimbursement and Rate Setting Section (RARSS) has continued to calculate LTC settlements and send settlement notices to providers as they were completed, however no recoupments have been processed.
The purpose of this announcement is to share that RARSS will begin recoupment on the LTC settlements that were previously suspended for settlement notices that were sent on or after March 25, 2020. In addition, RARSS will resume normal settlement procedures for all new LTC cost settlements and rate adjustments again in accordance with MDHHS policy.
Providers will be given 15 calendar days from this announcement to respond with concerns for any settlement notices that were previously sent via File Transfer before recoupments are processed. We are expecting processing to commence on August 6, 2020. Any questions regarding this announcement can be sent to DARS at DARS@michigan.gov.
MDHHS Extends LOCD Provisions & Flexibility
The Michigan Department of Health & Human Services (MDHHS) issued L 20-43 today, extending Level of Care Determination (LOCD) end dates. Due to the ongoing COVID-19 public health emergency, MDHHS will extend the end date of existing LOCDs in the Community Health Automated Medicaid Processing System (CHAMPS) where the end dates fall between July 1, 2020 and October 31, 2020. No action is needed by the provider or agency. Providers should not conduct LOCDs during this time frame if there is an existing eligible LOCD in CHAMPS for the beneficiary.
The extended end dates will be visible in CHAMPS no later than July 31, 2020. The following LOCDs will be extended 180 days - existing eligible Door LOCDs (Doors 1-8, 67, 77) with end dates of July 1, 2020 to October 31, 2020.
Governor Whitmer Announces Move to Improve Equity Across the Healthcare System
Governor Gretchen Whitmer today signed Executive Directive 2020-7 which directs the Department of Licensing and Regulatory Affairs (LARA) to begin developing rules that will require implicit bias training as part of the knowledge and skills necessary for licensure, registration and renewal of licenses and registrations of health professionals in Michigan. Implicit bias training was one of the recommendations made by the Michigan Coronavirus Task Force on Racial Disparities, which Governor Whitmer created in response to the devastating and disproportionate impact the pandemic has had on communities of color.
Under the Executive Order, LARA is required to consult with relevant stakeholders in the medical profession, in state government and elsewhere in the community to help determine relevant goals and concerns under the new rules. LARA will work in collaboration with the relevant professional boards and task forces to promulgate the rules.
For questions or concerns please contact Cathy Sunlin at CathySunlin@HCAM.org.
July 9, 2020
Directed Plan of Correction for F-880 Citations
