Home Health Agencies

State Operations Manual (SOM) Chapter 2

SOM Appendix B for HHA Regulations

SOM Appendix Z for Emergency Preparedness

To voluntarily become a Medicare certified provider, you will need to complete the following steps and submit the paperwork electronically to LARA-BSCSupport@michigan.gov, unless otherwise noted in the instructions.

• Complete Provider Enrollment Application (CMS-855A) and submit to Medicare Administrative Contractor (MAC).
• The MAC will provide you a recommendation letter once the initial review is complete.
• An e-mail confirming a successful electronic submission of your Civil Rights Clearance for Medicare Provider Certification from the Office for Civil Rights (OCR).
• A signed Health Insurance Benefit Agreement (CMS-1561).
• Currently, CMS has prioritized initial surveys as a lower tier work. Following the guidance of the CMS Mission and Priority Document, Michigan is currently not performing initial surveys. A provider can become accredited to obtain certification.
• Contact Accrediting Organization (AO) to schedule survey  *Once the deeming survey is complete, please ensure the Department of Licensing and Regulatory Affairs (LARA), Bureau of Survey and Certification (BSC) receives a copy of the survey report and final approval letter from your deeming authority.
• Once all of the above documents have been received your application will be deemed complete, the Bureau of Survey and Certification will review and forward the packet to the MAC for final determination and issuance of the Medicare provider number.
• Please note, this process can take up to 30-60 days from the day of receipt by the MAC.

• Complete Provider Enrollment Application (CMS-855A) and submit to MAC within 90 days of the move.
• The MAC will provide you a recommendation letter once the initial review is complete.
• Complete the Branch Application and submit to LARA-BSCSupport@michigan.gov.
• For deemed providers, please submit the accrediting agency survey report that includes the new site(s).
• Once all of the above documents have been received and deemed complete, the Bureau of Survey and Certification will review and forward the packet to the MAC for final determination and issuance of final approval letter.
• Currently, additional practice location reviews are Tier 4 work according to the CMS Mission and Priority Document (MPD). Please be aware that onsite survey work takes priority over this type of request.

The informal dispute resolution process is available to home health agencies for condition-level federal regulation deficiencies cited at Title 42, Chapter IV, Subchapter G, Part 484, of the Code of Federal Register (CFR). Chapter 10 (Survey and Enforcement Process for Home Health Agencies) of the State Operations Manual describes the mandatory elements of IDR.

An agency may request an IDR for each survey that cites condition-level deficiencies. However, if IDR is requested for deficiencies cited at a subsequent survey, an HHA may not challenge the survey findings of a previous survey for which the HHA either received IDR or had an opportunity for it. Condition-level deficiencies that are not corrected and that are carried forward on a subsequent survey are not eligible for the IDR process. Condition-level deficiencies identified on a subsequent survey that are new are eligible to be reviewed through the IDR process.

iMPROve Health (a peer review organization), contracted by the Bureau of Survey and Certification (BSC), will conduct the IDR review. Submissions for IDRs must be received by iMPROve Health within ten calendar days from the date of issuance of CMS’ 2567 by the State Agency. You will waive the right to an IDR request if the required information is not received timely.

Per CMS, agencies may not use the IDR process to delay the formal imposition of sanctions or to challenge any other aspect of the survey process. An ineligible/inappropriate request for a dispute that will be denied includes:

• The severity assessment of a deficiency(ies) at the standard level that constitutes substandard care or immediate jeopardy.
• Sanctions imposed by the enforcing agency.
• Alleged failure of the survey team to comply with a requirement of the survey process.
• Alleged inconsistency of the survey team in citing deficiencies among agencies.
• Alleged inadequacy or inaccuracy of the informal dispute resolution process.

Informal Dispute Resolution (IDR)

A home health agency must complete the HHA IDR Request Form and upload all supporting documents to iMPROve Health’s portal at www.improve.health/idr. When appropriately requested, the written request must include an explanation of the specific deficiencies that are being disputed.

Information that is NOT acceptable to submit includes copies of the federal standards, de-identified documents, information dated after the survey exit date or information on actions that took place after the survey exit date, and legal arguments or briefs.

Telephonic = IDR Conference Call

In addition to a desk review, a home health agency may also request a conference call with iMPROve to present your case and answer any questions about the submitted information in support of the agency’s position.  Because the conference call is not required by CMS, the home health agency will incur all costs associated with this option.

If a conference call is requested, the call will be scheduled in advance and the home health agency will be invoiced a fee to cover the cost.  The iMPROve Reviewer will host and lead the call.  BSC will designate one representative to join in listen-only mode.

Once iMPROve Health completes the review, their recommendations are sent to BSC to make the IDR decision and notify the HHA of that decision.  The agency will be notified of the bureau's decision in a letter that will accompany the final CMS 2567.

Contact

iMPROve Health
IDR/IIDR Section, Bureau of Survey and Certification

Submission of IDR/IIDR request forms and supporting documents are done electronically via the iMPROve Health’s Portal. The web address for instructions and a link to the portal is www.improve.health/idr. For questions, please contact Charlene Kawchak-Belitsky at 248-465-1038 or Aris Rhodes-Bond at 248-465-7405.

Other questions can be sent to the Bureau of Survey and Certification via LARA-BSC-IDR@michigan.gov