Michigan's home health care industry operates within a unique regulatory environment that does not require state licensure for home health agencies, though Certificate of Need requirements apply for Medicare certification. With major HCBS program transitions underway for 2026, a phased minimum wage increase reaching $15 by 2027, and new CNA continuing education requirements, understanding Michigan's home health care landscape is essential for agencies navigating this evolving market.

Home Health Agency Requirements in Michigan

Michigan is one of only three states (along with Iowa and Massachusetts) that does not require a state license for home health agencies. However, agencies seeking Medicare/Medicaid participation must navigate Certificate of Need and certification requirements.

State Licensing:

  • No state license required for home health agencies
  • Individual health professionals must check licensure requirements with Bureau of Professional Licensing

Certificate of Need (CoN) Requirement:

  • CoN required from MDHHS before applying for Medicare certification
  • One of the biggest hurdles for new agencies entering the market

Medicare/Medicaid Certification:

  • LARA evaluates compliance with federal regulations under CMS contract
  • Accreditation from ACHC, CHAP, or The Joint Commission required for Medicare certification
  • Agencies may be deemed or non-deemed providers
  • Note: FY2026 CMS priorities have deprioritized initial surveys

Staffing Requirements:

  • Qualified Administrator required
  • Director of Nursing (DON) must be an RN with home health care experience
  • LARA has specific experience and credentialing requirements for leadership roles

Contact: [email protected]

Certified Nursing Assistant (CNA) Certification

Michigan CNA certification is administered by the Department of Licensing and Regulatory Affairs (LARA) Bureau of Community and Health Systems. New continuing education requirements take effect in March 2026.

Training Requirements:

  • Minimum 75 hours in state-approved Nurse Aide Training Program (NATP)
  • At least 59 hours of classroom instruction and lab practice
  • Minimum 16 hours of classroom instruction before direct resident contact
  • At least 16 hours devoted to skills training

Eligibility Requirements:

  • Generally must be 18 years old for employment in long-term care
  • High school diploma or GED preferred by most programs
  • Must understand, speak, read, and write English
  • Criminal background check required by employer
  • Health examination including TB test required

Competency Examination:

  • Administered by Headmaster, L.L.P.
  • Written (or oral) exam and skills evaluation
  • Minimum 70% passing score on both components
  • Application fee: $20 via MI-NATES System

Michigan Nurse Aide Registry:

  • Maintained by LARA Bureau of Community and Health Systems
  • Contact: (517) 284-8961 or [email protected]

Certification Renewal:

  • Valid for 2 years
  • Biennial fee: $40 (effective March 2024)
  • Must have worked at least 40 hours as CNA in past 2 years
  • 12 hours of continuing education required

NEW: Continuing Education Requirement (Effective March 2026):

  • Attestation of 12 hours annual CE required within renewal period
  • Must include training on abuse, neglect, and care plans
  • Ensures continuing competence of nurse aides

Lapsed Certification:

If certification lapses more than 24 months past expiration, or employment requirement cannot be met, the individual must retake full training and examination.

Home Health Aide (HHA) Certification

Home health aides working for Medicare-certified agencies in Michigan must meet federal HHA competency requirements.

Federal HHA Requirements (Medicare-certified agencies):

  • 75 hours of training covering required competency areas
  • At least 16 hours of supervised practical training
  • Competency evaluation covering all required skill areas
  • Annual in-service training of at least 12 hours

Michigan Medicaid and Home Care Services

Michigan Medicaid provides home and community-based services through the MI Choice waiver program and other initiatives. A major transition is underway for January 2026.

Key Medicaid Home Health Services:

  • Home health skilled nursing
  • Home health aide services
  • Physical, occupational, and speech therapy
  • Personal care services
  • MI Choice waiver services

MI Choice Waiver Program

The MI Choice waiver program, which began in 1992 as the HCBS/ED waiver, provides Medicaid-covered long-term care services in home or residential settings for individuals meeting nursing facility level of care.

Eligibility:

  • Elderly or physically disabled
  • At risk of institutionalization
  • Meet nursing facility level of care (NFLOC)

2025 Financial Eligibility:

  • Income: Up to $2,901/month
  • Assets: Up to $9,660
  • Spousal income allowance: Up to $3,948/month

2026 Financial Eligibility:

  • Income: Up to $2,982/month
  • Assets: Up to $9,950 single
  • Community Spouse Resource Allowance: $162,660

MI Coordinated Health (MICH) Program - 2026 Transition

Major changes are underway for Michigan's HCBS system with the transition from MI Health Link to MI Coordinated Health.

Key Transition Details:

  • MI Health Link ends: December 31, 2025
  • MI Coordinated Health (MICH) begins: January 1, 2026
  • Waiver period: January 1, 2026 through December 31, 2029

MICH Program Scope:

  • Integrates long-term supports and services
  • Serves older adults (age 65+) and persons with disabilities (age 21+)
  • For individuals eligible for both Medicare and Medicaid (dual eligible)

Agencies should actively prepare for this transition and monitor MDHHS communications for implementation guidance.

Electronic Visit Verification (EVV)

Michigan has implemented Electronic Visit Verification in compliance with the federal 21st Century Cures Act. EVV is required for personal care services and home health services requiring an in-home visit.

Michigan EVV Requirements:

  • Captures type of service, member information, provider information, date, time in/out, and location
  • Implementation coordinated through Michigan Medicaid
  • Provider training and support resources available

Medicare Home Health in Michigan

Medicare-certified home health agencies in Michigan must comply with all federal Conditions of Participation. LARA conducts certification surveys under contract with CMS.

Payment Model:

Michigan Medicare home health agencies operate under the Patient-Driven Groupings Model (PDGM), which determines 30-day period payments based on:

  • Admission source and timing
  • Clinical grouping based on diagnosis
  • Functional impairment level
  • Comorbidity adjustment

Coverage Requirements:

  • Patient must be homebound
  • Services must be medically necessary
  • Patient must need skilled nursing or therapy services
  • Care must be provided under a physician's plan of care
  • Services must be provided by a Medicare-certified agency

Michigan Labor Laws for Home Care

Michigan has enacted significant wage increases with a phased approach reaching $15 by 2027. Importantly, home care workers are entitled to minimum wage and overtime protections.

Minimum Wage Schedule:

  • February 21, 2025: $12.48 per hour
  • January 1, 2026: $13.73 per hour
  • January 1, 2027: $15.00 per hour

Home Care Worker Protections:

  • Federal companionship services exemption does NOT apply in Michigan
  • Non-live-in home care workers entitled to minimum wage and overtime
  • Live-in employees exempt from overtime requirements

Overtime:

  • 1.5x regular rate after 40 hours per week
  • Also triggered after 12 hours per day/shift under IWOWA
  • Compensatory time option available for private employers (with written agreement)

Tax Benefits:

  • Michigan will not levy 4.2% income tax on tips or overtime (through 2028)
  • Signed by Governor Whitmer in October 2024

Workforce Challenges in Michigan

Michigan's home health care industry faces significant workforce challenges amid program transitions and wage changes.

Key Challenges:

  • Program Transition: MI Health Link to MICH transition creates uncertainty and adaptation requirements
  • Certificate of Need: CoN requirement limits new agency market entry
  • Geographic Diversity: Urban Detroit and Grand Rapids areas versus rural Upper Peninsula present different challenges
  • New CE Requirements: March 2026 continuing education requirements add compliance burden
  • Competition: Healthcare worker shortages create competition across care settings

Workforce Strategies for Michigan Agencies

Successful Michigan home health agencies are implementing creative strategies to recruit and retain quality caregivers.

Recruitment Approaches:

  • Partner with community colleges and vocational programs offering CNA training
  • Leverage phased minimum wage increases as competitive advantage
  • Emphasize overtime tax exemption benefit (through 2028)
  • Recruit across Michigan's diverse regions
  • Offer signing bonuses and referral programs

Retention Strategies:

  • Offer wages ahead of the phased minimum wage schedule
  • Support staff in meeting new CE requirements (effective March 2026)
  • Provide scheduling flexibility and work-life balance
  • Create career ladders and professional development opportunities
  • Consider compensatory time options where appropriate

Technology Solutions:

  • Implement efficient scheduling software
  • Use mobile apps for easy clock-in/out and EVV compliance
  • Streamline CE tracking with digital platforms
  • Prepare systems for MICH program transition

Resources for Michigan Home Health Agencies

Key organizations and resources for home health providers operating in Michigan:

  • LARA Bureau of Community and Health Systems: CNA registry, agency certification
  • MDHHS: Certificate of Need, Medicaid programs, MI Choice waiver
  • Michigan Nurse Aide Registry: (517) 284-8961, [email protected]
  • LARA Bureau of Professional Licensing: Individual healthcare professional licensure
  • Headmaster: CNA competency examination
  • Michigan HomeCare & Hospice Association: Industry advocacy and resources

The Bottom Line

Michigan's home health care environment is navigating significant transitions in 2025-2026, from the MI Health Link to MICH program change to phased minimum wage increases and new CNA continuing education requirements. While no state license is required, the Certificate of Need process creates barriers for new market entrants.

Success in Michigan's home care market requires proactive preparation for program transitions, competitive compensation strategies that stay ahead of mandated wage increases, and investment in staff development to meet new CE requirements. Agencies that embrace these changes while leveraging benefits like the overtime tax exemption will be best positioned to serve Michigan's population.