New Michigan Medicaid Enrollment and Billing Requirements for Nurse Practitioners and Certified Nurse Specialists

Posted by donna@healthlawcenterplc.com in Jun, 2019

The Michigan Department of Health & Human Services recently published new enrollment and billing requirements for nurse practitioners (NP) and clinical nurse specialists (CNS) who participate in Michigan’s Medicaid program.   These new guidelines were effective June 1, 2019 and require:

Enrollment Requirements for Clinical Nurse Specialists –

• Enroll in the Medicaid Program with a collaborating physician, pursuant to a written collaborative practice agreement;
• Attest to having a valid collaborative practice agreement in place with a Medicaid enrolled physician; and
• Report the NPI of the Medicaid enrolled collaborating physician.

Medicaid Billing Requirements for Clinical Nurse Specialists –

• Claims for services must include the NPI of the CNS and the NPI of the supervising physician; and
• Fees-for-service reimbursement for the CNS will be based on the limits and rates associated with physician services.

Collaborative Agreement Requirements for Nurse Practitioners and Certified Nurse Specialists

• Written collaborative agreement must be with a Medicaid enrolled physician;
• Include the effective date of delegation and subsequent review dates;
• Maintained the collaborating agreement in the primary location of services by the NP/CNS;
• Have the collaborating agreement available to the Michigan Department of Health & Human Services upon request;
• Outline the process of communication, availability and decision making, including an emergency plan between the NP/CNS and collaborating physician;
• Only include tasks and functions that NP/CNS or physician is qualified to perform based on education, training or experience and which is within their scope of their practices/licenses;
• Designate an alternative physician for consultation when the collaborating physician is not available;
• Description of the duties and responsibilities of the NP/CNS and physician based on education, training, and experience;
• Collaborative agreement must include a termination provision; and
• Collaborative agreement must be signed by the NP/CNS and collaborating physician.

Next Steps — 

• Update existing collaboration agreements to meet new Michigan Medicaid requirements and ensure professional claims are submitted in accordance with the new requirements. If there are any questions regarding collaborative agreements or claims submission requirements, contact Donna J. Craig, RN, JD at The Health Law Center, PLC.

Read Michigan Medicaid Program Bulletin MSA 19-10 for more information.