517.374.2703 info@rwca.com

CON Process

MRI

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 RWC 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 Health and Human Services.

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.

Once a CON number is assigned, a processed LOI is valid up to 1 year. If no application is filed within 1 year the LOI must be resubmitted. If the Department determines during the LOI review that the proposed project does not require a CON application the Department will issue a waiver letter indicating no CON is required.

Waiver letters are beneficial when working with other state agencies when no CON is required, and may even be requested by state licensing/engineering and other state agencies. Waivers require that you submit supporting documentation and a $500.00 LOI waiver fee. Common waivers are for stock transfers, MRI upgrades, lease renewals, construction/renovation projects under the covered capital expenditure amount (currently $3,375,000), and bond issuance for non-CON covered services.

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 include 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.

Contact RWC Advocacy for Your Certificate of Need

Melissa D. Reitz
Principal
RWC Advocacy
ReitzM@rwca.com
517.749.9503
Twitter: #CONGoddess

Abigail L. Burnell
Government Affairs Consultant
RWC Advocacy
BurnellA@rwca.com
269.362.4324

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