The MHA has been working with the Michigan HomeCare & Hospice Association to raise awareness of upcoming enforcement by the Michigan Department of Licensing and Regulatory Affairs (LARA) related to background check and fingerprinting requirements. Implementation is expected later this year, with the exact date to be determined.

Michigan hospice facilities are licensed by site, which means staff must be fingerprinted and registered with LARA under each specific hospice license. This may affect employees who are listed under a hospital license instead of a hospice license, or if an individual works at multiple hospice locations but are only registered at one.

Key Considerations

1. All employees working in a hospice program, including part-time, float and PRN staff, must be listed under the hospice license and affiliated with each individual hospice site if more than one site is operated. Organizations may also list employees under a hospital license; however, they must be listed under the hospice license.
   • Per LARA, state and federal fingerprint-based criminal history record checks are required for employees, independent contractors and individuals granted clinical privileges who have direct access to patients or residents and are under the facility’s control. “Direct access” includes access to a resident or resident’s property, financial information, medical records, treatment information or other identifying information.
2. Staff already listed on the hospice license require no further action. Staff not listed on the hospice license have two options:
   1. If hired within the last year, background check and fingerprinting results may be shared with the hospice agency.
   2. If hired more than one year ago, a new background check and fingerprinting must be completed, as results cannot be shared across entities after one year.

At this time, hospice residences cannot comply with this requirement, as they are not yet established in LARA’s system. LARA recommends following the steps above and completing background checks and fingerprinting under the hospice agency license. Once hospice residences are established in the system, those results may be shared.

Feedback Requested

Organizations holding a hospice license are encouraged to complete a brief survey. Feedback will help inform support efforts to ensure staff complete required background checks and maintain compliance.

Members with questions may contact Kelsey Ostergren at the MHA.

Phone: (517) 323-3443
Fax: (517) 323-0946

Phone: (517) 703-8601
Fax: (517) 703-0628