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RESIDENTIAL
NURSING HOMES
A Proposal for legislators, and the good people of
the State of Michigan
Executive Summary
ichigan, like many other states, is looking for ways to save scarce healthcare dollars while still
meeting its citizens needs. The Michigan Department of Community Health Task Force on
Nursing Practice warns access to healthcare will become increasingly restricted for Michigan residents if
registered nurses (RNs) are not practicing to the full extent of their required education and
competencies. A very sensible and feasible method of saving money on healthcare is to address the
costs and deficiencies of institutionalized long-term and subacute care.
Allowing RNs to receive Medicaid and/or Medicare reimbursement for long-term and subacute skilled
nursing services, and implementing the concept of Residential Nursing Homes as outlined in this
proposal, will save Michigan tens, if not hundreds, of millions of dollars each year. In addition, care will
be greatly enhanced for those residents and patients.
A hybrid between Adult Foster Care and a Nursing Home, the fundamental idea of Residential Nursing
Homes is a proven concept. Greenhouse Project nursing homes are on a similar scale as Residential
Nursing Homes, however, they do not correct the low nurse-to-resident ratios and the high costs
associated with long-term or subacute care. Residential Nursing Homes correct low nurse-to-resident
ratios and significantly lower costs for both taxpayers and private pay individuals.
The risks and costs for implementing these Residential Nursing Homes will be extremely minimal for the
State of Michigan, or other stakeholders. Although no down-payment loans and loan guarantees will be
required for RNs who wish to open a Residential Nursing Home, the loan will be secured by the value of
the home. Furthermore, Residential Nursing Homes will be easily transferable to another RN in the
event the previous RN wishes relinquish his or her Residential Nursing Home practice.
With approximately 100,000 Michiganders turning age 65 every year for the next 10-20 years, these
individuals will soon develop a need for skilled nursing in long-term and subacute care facilities. If
nothing is done to address this issue, not only will access to healthcare become increasingly restricted, it
will become financially unsustainable.
It is time to allow RNs to help Michigan enhance care for its vulnerable citizens, and reduce the burden
on taxpayers. It is time to implement the concept of Residential Nursing Homes.
Ken McIntyre Jr., RN
Page 1 of 21
Contents
The Residential Nursing Home Concept ...................................................................................................... 4
Should nurses be allowed to practice autonomously? ............................................................................. 4
What about special equipment and staffing?........................................................................................... 4
Michigan Department of Community Health Task Force on Nursing Practice .......................................... 5
Excerpts from the Task Force on Nursing Practice: Summary of Issue..................................................... 5
Task Force on Nursing Practice: Summary of Solution ............................................................................. 5
Saving Taxpayer Money ............................................................................................................................... 5
Medicaid ................................................................................................................................................... 6
Medicare ................................................................................................................................................... 6
How will Residential Nursing Homes Save Money?.................................................................................... 6
Combined Savings ..................................................................................................................................... 6
Minimal Financial Risk to Taxpayers ........................................................................................................... 6
Economic Impact on the State of Michigan................................................................................................. 7
Providing More Comprehensive Care .......................................................................................................... 7
How to provide better care: By the numbers ........................................................................................... 7
Are there enough nurses? ............................................................................................................................ 8
Incentives for Registered Nurses to Participate .......................................................................................... 9
Scalability .................................................................................................................................................. 9
What kind of residential home is needed? ................................................................................................. 9
Ideal Home ................................................................................................................................................ 9
Modifications ............................................................................................................................................ 9
How legislators and the State of Michigan can help................................................................................. 10
Assistance with Practice Start-Up Costs ................................................................................................. 10
Nursing Home Application Fee Waiver ................................................................................................... 11
Residential Nursing Homes Not reinventing the wheel ....................................................................... 11
A closer look at Greenhouse Project nursing homes ............................................................................ 11
Green House nursing home model deficits .......................................................................................... 12
Licensed Nurse to Resident Ratio ....................................................................................................... 12
Costs .................................................................................................................................................... 12
Money dictates choice between adult foster care, nursing home care ................................................. 12
Excerpts from an article in The Petoskey News, by Lorene Parshall .................................................. 12
Current Laws ............................................................................................................................................... 13
Page 2 of 21
Can Residential Nursing Homes comply with State and Federal Laws? ................................................. 13
Federal Law Excerpts impacting Residential Nursing Homes ............................................................. 13
483.75(i) Medical Director State Intervention Needed ............................................................. 14
State Law Excerpts impacting Residential Nursing Homes ................................................................. 14
R 325.20111 Amendment Needed ................................................................................................. 14
R 325.20712 Amendment Needed ................................................................................................. 14
R 325.20801, Rule 801 Amendment Needed ................................................................................. 15
R 325.21307 Amendment Needed ................................................................................................. 16
R 325.21307 Amendment Needed ................................................................................................. 16
R 29.1841 Amendment Needed ..................................................................................................... 16
ACT 368 Modifications .................................................................................................................... 16
Michigan Zoning Enabling Act Modifications Needed .................................................................... 17
Proposed Rules for Residential Nursing Homes ........................................................................................ 18
Staffing .................................................................................................................................................... 18
Visiting Hours .......................................................................................................................................... 18
Restricted Areas ...................................................................................................................................... 18
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Page 4 of 21
Page 5 of 21
The average Medicaid cost for long-term care in a nursing home averages around $179 per day, or
approximately $65,335 each year, per individual (Michigan Department of Health and Human Services,
2016). The average cost for Medicare subacute care in a nursing home is $492 per day (Centers for
Medicare & Medicaid Services, 2016, para. 4). The average 25 day stay in subacute care costs $12,300
or more.
Medicaid
For individuals requiring skilled nursing in a long-term care facility, the savings from utilizing Residential
Nursing Homes would amount to approximately $10,585 per year, per person. There are roughly 39,000
people living in Michigans nursing homes (Kaiser Family Foundation, 2014). Permitting 20% of these
people to live in Residential Nursing Home would result in a savings of $82,563,000 each year. Allowing
50% of these people to live in a Residential Nursing Home would result in a yearly savings of
approximately $206,407,500.
Medicare
For individuals requiring subacute care, a Residential Nursing Home could also provide more thorough
and comprehensive care at a substantial savings.
In 2014, there were 92,116 stays averaging 28 days each in subacute care, costing Medicare over
$922,437,000. This amounted to 2,579,248 patient days spent in subacute care at an average cost of
$357.63 per patient day. If 20% of these patient days, (515,849 patient days), were diverted to
Residential Nursing Homes, the savings would be roughly $184,483,000 each year.
Combined Savings
Under this proposal, if 20% of Medicare and Medicaid beneficiaries were diverted to a Residential
Nursing Home, the approximate savings would be over $267,000,000 each year. To meet this goal, just
over 1,800 Residential Nursing Homes, each with 6 licensed beds would be needed. This is not an
unrealistic goal. Please read the Are there enough nurses? section.
Page 6 of 21
In some instances, an insurer who pays for long-term or subacute care may elect to lend, or guarantee a
loan for a registered nurse who would provide care exclusively for their beneficiaries.
study noted, the medication administration process accounts for a substantial portion of nursing time
(Thomson et al., 2009, p. 271). This observation is also relevant today.
During a 12-hour shift, I spent nearly 10 hours preparing and administering medications, eye drops,
tube-feeds, breathing treatments, and responding to requests for non-scheduled pain medication. After
re-stocking the medication cart, checking in medications delivered from the pharmacy, and completing
essential treatments such as replacing dressings on 4 5 residents, I had approximately 1 to 1.5 hours to
provide care for the remaining 47 48 residents. That means the other residents each received
approximately 2 minutes of my time. This scenario is repeated on the day shift, with the exception that
a resident may get 5 minutes of skilled nursing care because there are two nurses on duty to care for 51
residents.
Residential Nursing Homes address this issue by reducing the number of residents per nurse to a
maximum of 6. Time-with-patient will increase to hours, instead of minutes, as currently experienced by
those individuals residing in skilled nursing homes.
15%
39%
Yes
Strongly consider
Not sure
No
38%
Page 8 of 21
Scalability
The nurse can choose the type of care and number of people to care for. Like their larger counterparts,
Residential Nursing Homes can be flexible the home can take either individuals that require long-term
skilled nursing, short term subacute care, or a combination of both. In addition, the nurse can
determine their participation in indirect care.
Modifications
Many homes in Michigan that fit the requirements of a Residential Nursing Home are currently on the
market, and could easily be modified at a comparatively minimal cost. The three most expensive
modifications to a current residence, or standard new construction would be:
1. In homes that have residents on a second floor, an elevator will be required. Residential home
elevators vary in cost depending on the style wanted or capacity needed based on the acuity of
the residents house in the home. A typical residential elevator would cost approximately
$16,000 plus installation costs (Ameriglide, n.d.). The total estimated cost would be in the range
of $30,000 to $32,000, and as high as $60,000 (Personal communication, Jerry Minchella, June
17, 2016)
2. A back-up generator that automatically engages when utility power is lost would cost
approximately $4,000 plus installation costs (The Home Depot, n.d.). The estimated total cost
would be in the range of $7,000 to $8,000.
Page 9 of 21
3. Fire sprinklers will be required throughout the home. The cost to retroactively install a
residential fire sprinkler system would be approximately $1.35 per square foot. (National Fire
Protection Association, 2013). A 7,500 square foot home would cost approximately $10,125 to
retrofit. New construction should be slightly lower.
Other modifications may be ground-floor bedrooms and bathrooms to avoid the installation of an
elevator for patient or resident use.
Page 10 of 21
Page 11 of 21
and stress in their work (Loe & Moore, 2011, p. 758). Nevertheless, there are two significant shortfalls
in the Green House nursing home model.
Costs
The secondary shortfall is costs. Green House nursing homes have higher operating costs, higher costs
for the private-pay consumer, and are cost neutral for Medicaid. A recent study found an analyses
indicated that although Green House (GH) nursing costs were higher than the national average, other
operational costs were lower, with the adjusted total operating expenses of GH homes being 7.6
percent higher than the national average (Jenkens et al. 2011, as cited in Zimmerman et al., 2015,
p. 478). In the Green House publication A Long-Term Care Model that Improves Lives and Bottom
Lines, the brochure states, Research shows that 61 percent of caregivers would pay 5 percent to more
than 25 percent more to have their family members live in a Green House home, with three-fourths of
those caregivers willing to pay 10 to 25 percent more (The Green House Project, n.d., p. 6). There
needs to be a bridge between Adult Foster Care and Nursing Homes
Money dictates choice between adult foster care, nursing home care
Excerpts from an article in The Petoskey News, by Lorene Parshall
Richard Bottomley is facing a difficult issue encountered by millions of adult children in the U.S.
His mother, Dorothy, 93, can no longer make her own decisions, and he wants to insure that her
final years are comfortable.
I moved her to Rocking Chair Home Care, Bottomley said. It is licensed for four residents, and
its a family-type setting. Clients and staff eat together, and my mother is able to have her own
room. The owner is an LPN (licensed practical nurse).
Shes happy and gets good care, he said.
As his mothers guardian, Bottomley realized recently that she would run out of her savings
within a year and would need to go on Medicaid. He has researched and found that it would be
easier to place her in a nursing home where Medicaid will pay an average of $6,618 rather than
keep her at the AFC home where she is thriving.
He feels the move to a nursing home would be traumatic to his mother. She wouldnt be able to
have her own room and there would be a lower ratio of staff to clients to provide services. It
Page 12 of 21
also would cost taxpayers far more money, which doesnt make sense to him in these difficult
economic times (Parshall, 2012).
Residential Nursing Homes can bridge the skilled nursing care gap between Adult Foster Care (AFC) and
conventional nursing homes. Not all AFC homes are run by a nurse, but all Residential Nursing Homes
will be.
Current Laws
Can Residential Nursing Homes comply with State and Federal Laws?
All Federal laws can be complied with, or meet strict allowances for waivers. Very few State laws will
need to be amended. Laws needing amendment are in red.
Page 15 of 21
Page 16 of 21
Residential Nursing Home means a residential home that is a primary residence, either owned, rented,
or leased by a register nurse licensed in the State of Michigan, providing skilled nursing care for
individuals needing sub-acute or long-term care.
AMENDMENT NEEDED Act 368
Amend Public Health Code, Act 368 of 1978, Part 222, Certificates of Need, 333.22224 Certificate of
need not required, Sec. 22224.
To include:
(3) A health facility required to be licensed as a Residential Nursing Home is not required to obtain a
certificate of need in order to be granted a license.
AMENDMENT NEEDED Act 368
Amend Act 368, 333.21720a, Sec. 21720a, (2) from:
An employee designated as a member of the nursing staff shall not be engaged in providing basic
services such as food preparation, housekeeping, laundry, or maintenance services
To say:
An employee designated as a member of the nursing staff shall not be engaged in providing basic
services such as food preparation, housekeeping, laundry, or maintenance services to An employee
designated as a member of the nursing staff shall not be engaged in providing basic services such as
food preparation, housekeeping, laundry, or maintenance services in nursing homes with greater than 6
certified beds.
Amend Article II, Zoning Authorization and Initiation, 125.3206 Residential use of property; adult foster
care facilities; family or group child care homes.
To include:
Article II, Zoning Authorization and Initiation, 125.3206 Residential use of property; residential nursing
homes, adult foster care facilities; family or group child care homes.
Visiting Hours
(1) The Residential Nursing Home shall establish visiting hours of no less than 12 hours per day, 7 days
per week, from the hours of 0900 (9 am) to 2100 (9 pm), and other hours by appointment by mutual
agreement between the registered nurse and the visitors.
(2) The Residential Nursing Home may limit the number of visitors for each resident or patient allowed
at any one time.
Restricted Areas
(1) The Residential Nursing Home may restrict patients, residents, and visitors to specific areas of the
home, however, the unrestricted areas must meet minimum square footage regulations for sleeping and
living areas.
Page 18 of 21
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