THE REIMBURSEMENT OF COSTS FOR THE NURSE AIDE

Michigan Department of Health and Human Services

TRAINING AND COMPETENCY EVALUATION PROGRAM (NATCEP)

Frequently Asked Questions (FAQ)

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his FAQ outlines the goal of the Nurse Aide Training and Competency Evaluation Program

(NATCEP), explains how certified nurse aides (CNA) may be reimbursed for the costs of

participating in this program, and provides resources for additional information. The FAQ and

related NATCEP documents will be made available for your review on the MDHHS website at

www.michigan.gov/medicaidproviders. The NATCEP webpage

can be accessed through the

following links:

www.michigan.gov/medicaidproviders >> Billing and Reimbursement >> Provider Specific

Information >> Nursing Facilities >> Nurse Aide Training and Testing Reimbursement

The FAQ was last updated October 2018.

What is the NATCEP

Program?

NATCEP is a program that supports CNA training and testing

for nursing facility employment.

Does an individual have to

complete the program to

work as a CNA in a

nursing facility?

Yes, all individuals who will be or are working as nurse aides in

a nursing facility must complete the competency evaluation

program.

Can a CNA be reimbursed

for funds spent on

participation in the

program?

Yes, CNAs can be reimbursed for their training and testing

costs by their employer if they:

1. C

omplete the competency evaluation program; and

2. Are hired by or working for a Medicaid certified nursing

acility within twelve months of the completion of their

testing.

How can a CNA request

reimbursement from his or

her employer?

The CNA should retain the receipts and documentation from the

training and testing program. The CNA should request

reimbursement from his or her employer within the six month

time period. The CNA should complete form

MSA-1326, which

can be found on the website, and submit it to his or her

employer.

What are the “six month”

and “twelve month” time

periods?

A nursing facility has six months after the CNA’s hire date to

reimburse them for training and testing costs. A CNA must

secure employment with a certified nursing facility within twelve

months of completing his or her testing to be eligible for

reimbursement.

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Is a CNA who works for a

hospital, hospice provider,

Home and Community-

Based Service provider, or

independent living setting

eligible for reimbursement?

No, only nursing facilities are obligated to reimburse CNAs

under NATCEP.

How will a CNA be

reimbursed by his or her

employer?

The employer may either reimburse the CNA through a lump

sum payment or installments.

How much will a CNA be

reimbursed for training and

testing costs?

For training costs, a Medicaid certified nursing facility will be

paid to reimburse a CNA up to the current limit for training

costs, which can be reviewed through the

Reimbursement Limit

document on the website.

For

testing costs, a Medicaid certified nursing facility will be paid

based on the fees charged by the testing center. The testing

center fees can be viewed in the

Nurse Aide Testing Fee

Schedule document located on the website.

A nursing facility may reimburse a CNA for more than the

specified amounts for training and testing costs, but the facility

will not receive additional reimbursement from Medicaid.

How long does an

employer have to

reimburse a CNA?

The employer has six months from the CNA’s hire date to

reimburse the individual if the employer would like to be

reimbursed by Medicaid.

If a CNA leaves a nursing

facility before the six

month time period expires,

is the employer still

obligated to reimburse the

CNA?

No, a nursing facility is not obligated to reimburse a CNA who

leaves the nursing facility for any reason before the six month

time period expires.

If a nursing facility has not

reimbursed a CNA after

the six month time period

has expired and the CNA

is still employed with the

same facility, what can the

CNA do?

Please contact the LTC Services Division at 517-241-4079 for

additional assistance.

If a CNA is hired by a

facility after the twelve

month time period has

expired, is the CNA eligible

for reimbursement?

No, a nursing facility is not obligated to reimburse a CNA who is

hired after the twelve month time period expires.

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If a CNA leaves one

nursing facility without

receiving full

reimbursement and is

hired by another facility,

can the CNA be

reimbursed for the rest of

the training and testing

costs?

Yes, a CNA can request reimbursement from the second facility

if:

1. T

he CNA is hired by the second facility within the twelve

month time period;

2. T

he CNA has not been reimbursed for the full amount of

his or her training and testing costs by the first facility;

and

The CNA can provide documentation to the second facility

showing that the CNA has not been fully reimbursed by the first

facility.

Can a CNA submit the

form for reimbursement to

the MDHHS and receive

reimbursement directly

from the department?

No, MDHHS does not directly reimburse CNAs training and

testing costs associated with NATCEP. Facilities are

responsible for reimbursing CNAs, and participating Medicaid

facilities will be reimbursed by Medicaid through their annual

cost report settlement.

How soon after being hired

should a CNA turn in the

MSA-1326 and any

supplemental

documentation to their

employer?

While not required, it is recommended that the CNA turn in a

completed MSA-1326 and any supplemental documentation

(i.e. receipts, etc.) to their employer as soon as possible after

being hired. This will help ensure that the facility reimburses the

CNA within the required six month time frame.

Does the nursing facility

have to reimburse the CNA

for NATCEP costs?

Yes, a Medicaid certified nursing facility must reimburse a CNA

for their training and testing costs. This is required by Section

9.9.C of the Nursing Facility Cost Reporting & Reimbursement

Appendix in the Medicaid Provider Manual. A provider that does

not comply with the Medicaid Provider Manual is in direct

violation of their Provider Enrollment agreement. The only

exception to this policy is if a CNA has not secured employment

within twelve months of their testing date or they have already

been fully reimbursed for their NATCEP costs.

Does a nursing facility

reimburse CNAs for

NATCEP costs if the

facility is in a NAT lockout?

Yes, a facility under a NAT lockout is still required to reimburse

CNAs for their training and testing costs outside the facility.

These costs are still allowable and reimbursable to the facility

though their Medicaid per diem. A NAT lockout only prevents a

facility from conducting and being reimbursed for facility-based

training.

In order for a CNA to be

reimbursed by a nursing

facility do they need to be

employed full time?

No, a CNA who is employed full time, part time, or per diem

should be reimbursed for their training and testing costs.

If a CNA took out a loan to

pay for their NATCEP

costs what does the

nursing facility reimburse

the CNA for?

In this situation the nursing facility would reimburse the CNA for

the NATCEP costs charged by the training and testing centers

only. The facility is not required to reimburse the CNA for

interest expense on the loan or their monthly loan payments.

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Can a nursing facility bill

any costs to a CNA for

facility-based training

costs?

No, a facility cannot bill a CNA for facility-based NATCEP

training costs under any circumstance.

If a person hired by a

facility fails to pass the

CEP does the nursing

facility have to reimburse

them?

No, a nursing facility is only required to reimburse CNAs. If an

individual fails to pass the CEP after the maximum number of

retests the facility is under no obligation to reimburse them.

Can a nursing facility offset

a CNA’s wages in order to

reimburse their NATCEP

costs?

No, this practice is strictly prohibited by paragraph six of Section

9.9.C. of the Nursing Facility Cost Reporting & Reimbursement

Appendix of the Medicaid Provider Manual. If the facility is

offsetting the CNA’s wages they aren’t truly reimbursing their

NATCEP costs.

Is a nursing facility

obligated to reimburse a

CNA for fees associated

with the Michigan Nurse

Aide Registry?

Yes, Section 9.9.A. of the Nursing Facility Cost Reporting &

Reimbursement Appendix of the Medicaid Provider Manual

requires facilities to reimburse CNAs for their initial registration

and biennial registry fees. These fees are an allowable cost for

nursing facility Medicaid reimbursement.

Can a nursing facility

require a CNA to remain

employed with that facility

for a specific period of time

greater than six months as

a condition of

reimbursement?

No, a facility must reimburse a CNA within six months for

NATCEP related costs. Any reimbursed costs past six months

are unallowable for nursing facility reimbursement purposes,

and a facility cannot require a CNA to reimburse them if their

employment is terminated.

Are there additional

resources on NATCEP

reimbursement? Where

are they located?

CNAs can check to see if his or her employer has a published

NATCEP reimbursement policy that may show how their

employer fulfills the requirements of the program.

NAs and nursing facilities can review the entire State of

Michigan policy on NATCEP reimbursement in the

Medicaid

Provider Manual. The policy can be found in the Nurse Aide

Training and Competency Evaluation Program (NATCEP) and

Competency Evaluation Program (CEP) Section of the Nursing

Facility Cost Reporting & Reimbursement Appendix, which can

be found on the website.

If CNAs or nursing facilities have other questions about

NATCEP reimbursement after reviewing this FAQ and other

resources, they may contact the LTC Services Division at 517-

241-4079.