The Michigan Department of Health and Human Services (MDHHS) has made changes to the process for conducting a Level of Care Determination (LOCD) that become effective January 1, 2019. These changes are designed to make the process more consistent across all programs. In Michigan, that includes skilled nursing facilities, the MI Choice waiver program, the Program of All-Inclusive Care for the Elderly (PACE), and the MI Health Link waiver program.

The biggest change to the process is that all LOCDs must be conducted face-to-face by a qualified licensed health professional. This face-to-face LOCD must be conducted before the provider is eligible for Medicaid reimbursement for the individual. Nursing facilities still will have up to 14 days from the date the LOCD is conducted to enter it into CHAMPS. However, if there is a significant change in condition prior to the LOCD being entered into CHAMPS, then a new LOCD must be conducted. Both LOCDs must then be entered into CHAMPS. Providers still can use multiple methods for assessing LOCD criteria, including outside medical documentation, day-of observations, and resident and caregiver interviews.

Other key changes to the process include:
* Individuals seeking long-term services and supports are not required to be Medicaid eligible before professionals can conduct the LOCD;
* LOCDs will now be connected to the individual rather than the provider;
* When the passive redetermination process cannot confirm that the individual continues to meet LOCD criteria, the provider will receive notification in CHAMPS to perform a new face-to-face LOCD;
* The review process is changing to an immediate review of a random sample of initial LOCDs.

The full Medical Services Administration bulletin is available at the link below:
https://www.michigan.gov/documents/mdhhs/MSA_18-48_639607_7.pdf

Should you have questions or concerns, or need assistance with understanding the new LOCD requirements, please do not hesitate to contact a member of our Post-Acute Care practice group.

Michigan Department of Health and Human Services Changes to Level of Care Determination

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