Editor's Note: This article first appeared in The Detroit News on July 15, 2021.

On June 3, I testified before the House Oversight Committee and explained that Michigan has been undercounting COVID-19 deaths in long-term care facilities. This was revealed after our client, Pulitzer Prize-winning journalist Charlie LeDuff, sued the state for failing to fulfill a public record request.

Now, the state’s auditor general has announced that he will review how the Michigan Department of Health and Human Services has been tracking these deaths. It is important to get this accounting correct, and there are a number of concerns that deserve particular focus.

One concern is that the state has neglected to track COVID-19 deaths in two types of facilities, known in statute as Homes for the Aged and Adult Foster Care. Facilities of these types that serve fewer than 13 residents have never been required to report COVID-19 deaths to the state.

These facilities make up 75% of all the long-term care facilities regulated by the state and serve about a quarter of all residents, nearly 22,000 people. Resident deaths at these facilities need to be accounted for, and the auditor general should account for these facilities in his report.

Another thing the auditor general must review is the state’s process for quantifying and categorizing COVID-19 deaths that come from reviewing death certificates.

Based on MDHHS Director Elizabeth Hertel’s June 3 legislative testimony, the department tracks long-term care deaths based on either reports to the federal government or self-reporting from the facilities themselves. It does not consider the COVID-19 deaths listed on death certificates that were not reported to the federal government or self-reported by facilities as a long-term care death.

The state can do this but has simply chosen not to. For a few months last year, the state did investigate the data from death certificates and used it to add to the tally of deaths at long-term care facilities. The state stopped because MDHHS said it was too time consuming.

This change in practice could have a significant impact on the overall count, because when the department was more thoroughly reviewing these death certificate records it found that 44% of them could be traced to long-term care facilities. Now none of them are — the result of a policy decision.

The auditor general should engage in the careful analysis once performed by MDHHS to ensure that deaths recorded in death certificates that may have occurred at long-term care facilities are properly classified.

Thankfully, investigating how many COVID-19 deaths reported on death certificates occurred at long-term care facilities is not difficult. All the state needs to do is compare the addresses listed on death certificates to the addresses of all the licensed long-term care facilities in Michigan. This could be done easily with software like Microsoft Excel. That number would help establish a new minimum long-term care death count.

Why a minimum count? As Director Hertel testified, the families of long-term care residents may report the deceased’s previous private residence on their death certificate rather than the long-term care facility where they were living before they died from COVID-19. Nevertheless, the review proposed above would at least provide a more accurate minimum count than the one currently published by the state.

Why does this matter? For one, those who have lost family in one of these facilities deserve the state’s best effort at assembling the complete picture of this unfortunate situation. Important policy decisions were made throughout the pandemic that may have impacted the chance of people dying in state-licensed facilities, and policymakers cannot learn how to improve on these policies if they do not have all the details.

The auditor general now has the opportunity to objectively review those policies, identify deficiencies and help the state be better prepared in the future.

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