How to Stay Compliant with MI Choice Waiver Billing in 2025

Avoid Claim Denials, Comply with EVV, and Stay Audit-Ready in Michigan

If you’re a provider working with the MI Choice Medicaid Waiver in Michigan, staying compliant with billing regulations in 2025 is more important than ever. As audits increase and documentation standards evolve, ensuring your billing practices meet MDHHS and waiver agency guidelines is key to protecting your revenue, your license, and your reputation.

Whether you operate an Adult Foster Care (AFC) home, a home care agency, or are part of a regional waiver provider network, this guide will help you avoid common billing mistakes and stay ahead of regulatory changes in 2025.

📌 What is the MI Choice Waiver Program?

The MI Choice Waiver Program allows eligible adults (typically age 65+ or with disabilities) to receive Medicaid-funded long-term care outside of nursing homes, including:

• Community Living Supports (CLS)

• Personal Care

• Respite Services

• Adult Day Health

• Nursing, Chore, and Homemaker Services

These services are coordinated by regional waiver agencies, under the oversight of the Michigan Department of Health and Human Services (MDHHS).

✅ Key 2025 Billing Compliance Priorities

1. Electronic Visit Verification (EVV) Is Now Required

As of 2024 and continuing in 2025, EVV is mandatory for personal care and related services under MI Choice.

What You Must Do:

• Use an approved EVV system (check with your waiver agency)

• Record:

  • Start and end times

  • Location of services

  • Caregiver identity

  • Services delivered

• Make sure EVV logs match your claims and progress notes

Tip: Mismatched EVV records and billed units are among the top audit flags.

2. Progress Notes Must Match Services Billed

Each billed service must have:

• A person-centered service plan authorizing it

• A dated, signed progress note describing what was done

• Staff initials and/or signatures

• Documentation that matches the units and codes billed

Watch Out For:

• Backdating notes

• Copy-paste errors across clients

• Billing for services not documented

• Progress notes missing key details (time, activity, result)

3. Authorization Alignment

Only services that are approved and authorized by the waiver agency can be billed.

Stay Compliant By:

• Verifying current service authorizations for each client

• Not exceeding units unless revised in the care plan

• Promptly notifying the waiver agent of any client status change

4. Timely Payroll & Premium Pay

If you receive DCW Premium Pay funds, you must:

• Show separate line items on pay stubs for premium vs. base wage

• Pay out premium wages within 30 days

• Keep clear records of hours and rates (e.g., $3.40/hour premium)

• Refund unused funds for employees who opt out

📂 Required Documentation to Keep on File

• Signed Service Plans

• EVV records and time logs

• Daily or shift-specific progress notes

• Pay stubs showing premium wage details

• Incident reports (if applicable)

• Proof of staff training and qualifications

Keep documents organized and accessible in case of an audit by MDHHS or your waiver agency.

🚨 What Happens If You’re Not Compliant?

• Delayed or denied payments

• Audit findings or corrective action plans

• Termination from provider networks

• Potential LARA or MDHHS enforcement actions

💡 Best Practices to Stay Audit-Ready

• Conduct monthly internal file audits

• Train your team on EVV and documentation standards

• Designate a compliance lead to track updates and policies

• Partner with experts (like Roseberri) for ongoing billing support

🤝 Need Help with MI Choice Waiver Compliance in 2025?

At Roseberri, LLC, we specialize in helping AFC homes, waiver agencies, and care providers navigate the complexities of Medicaid billing, EVV, staff training, and documentation audits.

💌 Contact us at roseberrimanagement@gmail.com 🖥️ Learn more at www.roseberri.com📍 Based in Michigan — serving providers statewide and remotely