CON Application Process

Karmanos Cancer InstituteMRI_300px

Karmanos Cancer Center had been working for over a decade to become a separately licensed, independent hospital on the campus of the Detroit Medical Center. Certificate of Need hurdles continued to create barriers for the organization until they brought in RWC Advocacy to assist. In less than 1 year Melissa and her team were able to devise a strategy which provided Karmanos with a separate license and complete autonomy from the DMC.

The CON application process itself can be quite predictable when you have the guidance of an experienced professional. Our clients benefit a great deal from our years of experience learning what the State is looking for as well as our ability to streamline and simplify a complex system. From a high level perspective, the CON process is as follows:

Letter of Intent
The CON application process begins with the filing of a letter of intent (LOI) with the Michigan Department of Community Health. The LOI contains basic information about the applicant including the applicant’s name and address, the location where the covered service/beds will be located, and what the applicant is requesting (number of beds, type of service, etc.). The Department must process the LOI within 15 days from submission and once processed, provides the applicant with a CON application number as well as a list of forms and other information that must be included in the application.

Certificate of Need Application
Once the Department has processed the LOI, the CON application must be drafted and submitted. The application includes more detailed information about the project. Applications for covered clinical equipment must include supporting documentation like vendor quotes and lease proposals. Applicants must provide financial projections as well as documentation to substantiate that funding for the project is available. The application must also provide relevant documentation to show that the project meets the requirements of the relevant CON review standards. Upon filing the application, the Department reviews it for completeness. If they determine any items are missing, they will request those items within 15 days of receipt of the application, and allow 15 days to respond with the information. Once the information is received, the application is deemed complete and the Department review commences.

There are three types of CON applications:

1. Non-Substantive Review
These applications can be filed at any time following LOI processing and take up to 45 days to review. Projects that qualify for non-substantive review include acquisitions, relocations, and replacements. In addition, mobile CT and mobile PET host site initiations as well as some mobile lithotripsy host site initiations will qualify for non-substantive review.

2. Substantive Review
These applications must be filed on the first business day of any month (if filed any other day, they do not count as filed until the first day of the following month) and take up to 120 days to review. Projects that do not qualify for non-substantive review or comparative review are subject to substantive review. Typically this includes initiations of new services and expansions of existing services.

3. Comparative Review
These applications must be filed on the first business day of February, June, and October and take up to 150 days to review. Applications for beds (hospital, nursing home, and psychiatric) as well as services that are limited by the number allowed in the state or a planning area (transplantation services) are subject to comparative review.

 

Melissa-CuppMelissa D. Cupp
Partner
RWC Advocacy
Email: cuppm@rwca.com
Phone: 517.374.3877
Twitter: #CONGoddess

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