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Hospice Agencies & Residences

Overview

Hospice agencies and residences are required to be licensed. Once licensed, hospice agencies may choose to apply for certification to participate in Medicare/Medicaid programs.  The Centers for Medicare and Medicaid Services (CMS) contracts with LARA to evaluate compliance with federal regulations by conducting surveys and complaint investigations.  This page is designed to assist providers through the federal certification processes, as well as provide additional resources to maintain compliance.

The Centers for Medicare and Medicaid Services (CMS) contracts with LARA to evaluate compliance with the federal regulations by conducting surveys and complaint investigations.

Hospice agencies and residences must be licensed with the State of Michigan before Medicare certification is approved.  Please visit Hospice Agencies & Residences to obtain information for state licensing.

Administrator/Leadership Changes

Initial Certification

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 and our office 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.

Address Changes

  • Your state license for the Hospice Agency must be updated prior to completing the follow steps for federal certification.
  • Complete Provider Enrollment Application (CMS-855A) and submit to MAC within 90 days of the move.
  • Note-address/location changes should remain within the approved geographic area
  • The MAC will provide you a recommendation letter once the initial review is complete.
  • 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, Bureau of Survey and Certification will review and forward the packet to the MAC for final determination and issuance of final approval letter.
  • If you do not receive a final approval notice from the MAC within 90 days of submission, please reach out to LARA-BSCSupport@michigan.gov for assistance.

Multiple Location/Hospice Residence (Inpatient Program) Applications

  • 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 Application for Multiple Location 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, 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.
  • *Note-multiple locations are not state licensed, however hospice residences do require state licensing for each location.

IDR Process

The informal dispute resolution (IDR) process is available to hospice programs for condition-level deficiencies cited at 42 Code of Federal Regulations (CFR), Chapter IV, Subchapter B, Part 418. Chapter 10 (Informal Dispute Resolution and Enforcement Procedures for Home Health Agencies and Hospice Programs) of the State Operations Manual describes the mandatory elements of IDR.

A hospice program may request an IDR for each survey that cites condition-level deficiencies. However, if IDR is requested for deficiencies cited at a subsequent survey, a hospice program may not challenge the survey findings of a previous survey for which the hospice program 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. The hospice program request for IDR must be submitted to iMPROve in writing and include the specific survey findings that are disputed. The written request must be made within the same ten calendar day period the hospice program has for submitting an acceptable plan of correction to the surveying entity. The right to an IDR request is waived 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 (IJ).
  • 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 IDR process.



Informal Dispute Resolution (IDR)

A hospice program must read and complete the Hospice IDR Request Form and upload all supporting documents to iMPROve Health’s portal at www.improve.health/idr.

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 hospice program may also request a conference call with iMPROve to present the case and answer any questions about the submitted information in support of the provider’s position. Because the conference call is not required by CMS, the hospice program will incur all costs associated with this option.

If a conference call is requested, it will be scheduled in advance and the hospice program 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 hospice program of that decision. The provider will be notified of the BSC's decision in a letter that will accompany the final CMS-2567.


Contact

iMPROve Health:

Submission of IDR request forms and supporting documents are done electronically via 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

Change of Ownership (CHOW)

Discharge for Cause

The situations under which a hospice may discharge a patient are addressed in the regulation at 42 CFR 418.26 and include the following situations:

  • The patient moves out of the hospice’s service area or transfers to another hospice;
  • The hospice determines that the patient is no longer terminally ill; and
  • The hospice determines under a policy set by the hospice for the purpose of addressing discharge for cause, that the patient’s (or other persons in the patient’s home) behavior is disruptive, abusive, or uncooperative to the extent that delivery of care to the patient or the ability of the hospice to operate effectively is seriously impaired. 

The hospice must do the following before it seeks to discharge a patient for cause:

  • Advise the patient that a discharge for cause is being considered;
  • Make a serious effort to resolve the problem(s) presented by the patient’s (or other persons in the patient’s home) behavior or situation;
  • Ascertain that the patient’s proposed discharge is not due to the patient’s use of necessary hospice services; and
  • Document in the clinical record, the problem(s) and efforts made to resolve the problem(s). 

Prior to discharging a patient for any reason stated above, the hospice IDG must obtain a written physician’s discharge order from the hospice medical director. If a patient has an attending physician involved in his or her care, this physician should be consulted before discharge and his/her review and decision included in the discharge note.

NOTE:  The hospice notifies its Medicare administrative contractor (MAC) and SA (LARA-BSCSupport@michigan.gov) of the circumstances surrounding the impending discharge.

Contact Us

Bureau Phone: 517-284-0193

Bureau Fax Number: 517-763-0214

Help for general questions: LARA-BSCHelp@michigan.gov

Certification Support email (document submission): LARA-BSCSupport@michigan.gov