Bagby, Tammy (LARA)  
From:  
Sent:  
To:  
Robert Stein <rstein@miassistedliving.org>  
Thursday, August 11, 2022 8:53 AM  
LARA-BCHS-Training  
Cc:  
Bagby, Tammy (LARA)  
Subject:  
Proposed HFA Licensing Rule Revisions  
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Michigan Assisted Living Association (MALA) appreciates the opportunity to submit public comments on the proposed  
home for the aged (HFA) licensing rules. MALA represents HFAs throughout Michigan.  
Our comments are as follows:  
-
Rule 1(n) - Our organization recommends that the proposed definition under Rule 1(n) be revised to the  
following language: “Medication management” means assistance with the acquisition and administration of a  
resident’s prescribed medication.  
-
Rule 24(3) – Our organization recommends that proposed Rule 24(3) be revised to the following language: The  
program must be staffed by a multi-disciplinary team. The multi-disciplinary team shall consist of not less than 2  
personnel from the home and if needed additional staff who have training or experience with the type of the  
incident being evaluated.  
Thank you again for the opportunity to comment on the proposed HFA licensing rules.  
Robert L. Stein  
General Counsel  
Michigan Assisted Living Association  
Direct Dial: 734-525-2400  
1
Bagby, Tammy (LARA)  
From:  
Sent:  
To:  
Cc:  
Subject:  
LindaLawther@michcal.com  
Thursday, August 11, 2022 2:04 PM  
Bagby, Tammy (LARA)  
Horvath, Larry (LARA); Moore, Andrea (LARA)  
Proposed Rule Comments  
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Re: Notice of Public Hearing to take place on Thursday, August 18, 2022 at 9:00 am  
Williams Building, 1st Floor Auditorium, 525 West Ottawa Street, Lansing, MI 48933  
Comments on the proposed Homes for the Aged administrative rules changes  
The Michigan Center for Assisted Living would like to request a couple of small edits to the language based on review by  
our provider members.  
1. R. 325.1901 Definitions  
a. Rule 1(n), the following definition of “medication management” is preferred:  
“Medication management” means assistance with the acquisition and administration of a resident’s  
prescribed medication.  
This alternative definition avoids the need for the resident’s service plan to be modified whenever  
there is a change in medication. Alternatively, if stated as is in the current proposed language, each  
resident’s service plan would have to be updated every time there is a change of any kind in  
medication. We believe this is an unintended consequence and therefore strongly suggest our  
revised definition.  
2. R 325.1924 Reporting of incidents, quality assessment and performance improvement program  
a. Rule 24(3), the following language is preferred:  
The program must be staffed by a multi-disciplinary team. The multi-disciplinary team shall consist  
of not less than 2 personnel from the home and if needed additional staff who have training or  
experience with the type of the incident being evaluated.  
3. As a follow up comment we would like to be sure that there are plans for conducting training of the  
Bureau’s staff and HFA licensees with respect to the HFA rule revisions after their promulgation. We are  
happy to assist and support such training for our members and suggest that a training might be effective  
with licensing staff and providers in a combined training.  
Thank you for the opportunity to collaborate on the process and to offer comments.  
Warm regards,  
Linda Lawther  
President/CEO  
1
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Members find Current COVID-19 Updates at  
https://www.mcal.org/coronavirus/covid-19/  
Linda Lawther, MA, CALD, NHA  
7413 Westshire Drive, Lansing, MI 48917 · P: (517) 627-1561 · F: (517) 627-3016 · M: (734) 320-5810 · Email: LindaLawther@Michcal.com  
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2
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  
dalton@leadingagemi.org  
517-323-3687 (x104)  
201 N. Washington Square | Suite 920 | Lansing, MI 48933  
P 517-323-3687 | F 517-323-4569 | LeadingAgeMI.org  
Expanding the world of possibilities for aging.  
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