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 hospices hold site-based licenses, meaning all staff working at each hospice site must be fingerprinted and listed with LARA under that specific site’s license. This may affect organizations if hospice employees are currently listed under a hospital license rather than a hospice license or are only listed at one hospice location but work at multiple sites.
Key Considerations
- 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.
- Staff already listed on the hospice license require no further action. Staff not listed on the hospice license have two options:
- If hired within the last year, background check and fingerprinting results may be shared with the hospice agency.
- 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.