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MSA 18-13 - Clarification of Home Health Face-to-Face Requirements

Michigansub_regulatoryMichigan Department of Health and Human Services (MDHHS), Medical Services Administration· effective 2018-07-01

What this rule requires your agency to do

  • 1Home health aide services must be medically necessary and ordered by the attending physician, and must not be used solely for personal care needs, respite, heavy cleaning, household repairs, or beneficiary convenience.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 2MI Choice nursing services shall not duplicate services available through the Medicaid home health benefit, and MI Choice waiver agencies cannot authorize State Plan services.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 3HHAs that choose to provide equipment and medical supplies (beyond routine supplies) must enroll with Medicaid as a DME provider and comply with all federal and state DMEPOS provider rules.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 4The plan of care must identify all ordered components (skilled nursing, therapy, home health aide, medical supplies) as identified in the Medicare Conditions of Participation and Medicaid policy to validate medical necessity, and must clearly outline the duties to be performed by the home health aide.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 5The certifying physician must document that a face-to-face encounter related to the primary reason for home health services occurred, identify any allowed non-physician practitioner who conducted it, and sign and date the encounter stating the primary reason for services.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 6It is the responsibility of the HHA to assess the ability and willingness of the family/caregiver/another entity to perform personal care; for beneficiaries enrolled in Home Help or MI Choice Waiver, the HHA must contact the adult services worker or waiver agent to ensure coordination and verify there is no duplication of care.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 7Home health services may not be subject to a "homebound" requirement and may not be limited to services furnished in the home; they may be provided in any setting where normal life activities take place other than a hospital, nursing facility, ICF/IID, or inpatient room-and-board setting.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)
  • 8Initial ordering of home health services must occur not more than 90 days before or 30 days after the start of services.(MSA 18-13 - Clarification of Home Health Face-to-Face Requirements)

Applies to: personal care

MDHHS bulletin implementing the CMS Home Health Final Rule (CMS-2348-F), clarifying home health face-to-face encounter requirements, decoupling home health aide services from skilled nursing/therapy, and requiring coordination with Home Help and MI Choice Waiver to avoid duplication of personal care.

Regulatory information, not legal advice — always confirm against the cited official source. Verification reduces error; it does not certify compliance.