August 18, 2022
Department of Licensing and Regulatory Affairs
Bureau of Community and Health Systems
Comments on Administrative Rules for Homes for the Aged
Rule Set 2022-21 LR
LeadingAge Michigan appreciates the Department of Licensing and Regulatory Affair’s (LARA) continued
efforts to improve incident and accident reporting for Homes for the Aged (HFA) providers. We would also like to
thank LARA for their communication and time conducting the workgroups and we will continue to follow these
rules changes as they make their way through the administrative rules process.
LeadingAge Michigan supports the changes to HFA incident and accident reporting and is excited that HFA
providers will now be conducting their own internal review of these reports. We feel that these changes will
improve an HFA’s ability to look at the root cause of an incidents and/or accidents while simultaneously
eliminating any existing rules that LARA does not have statutory authority to enforce.
However, we ask that the language used to describe these internal incident and accident reporting
entities/programs be changed from “Quality Assessment and Performance Improvement Program” (QAPI) to
simply “Quality Review Program” (QRP). In conversations with LeadingAge Michigan members, the notation of
these programs as “Quality Assessment and Performance improvement Program” has caused some confusion and
false expectation as many providers have experience with QAPI programs in other long term care settings. We feel
that the term “Quality Review Program” is simply a better descriptor for the nature of the work that these
programs will be conducting. Secondly, we feel that term “Quality Review Program” will coordinate better with
the current statutory language in the public health code by providing a clearer statutory definition for a review
entity/program with the confidentiality requirements that these entities/programs require.
In closing, LeadingAge Michigan would like to thank LARA and the workgroup for their time developing these rule
changes and support the rule changes, with an exception regarding the naming of the review entities/programs as
Quality Assessment and Performance improvement Programs. LeadingAge Michigan would like to see the
language changed to “Quality Review Program” to better reflect the nature of these entities/programs and the
work that they will be conducting.
Sincerely,
Dalton Herbel
Director of Public Policy
517-323-3687 (x104)
201 N. Washington Square | Suite 920 | Lansing, MI 48933
P 517-323-3687 | F 517-323-4569 | LeadingAgeMI.org
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