Pull Up Your Chair

New FY25 PIHP Contract Language over CCBHC Providers Increases Burdens

Community Behavioral Health Clinics (CCBHCs), placing oversight responsibilities on PIHPs for referrals, client assignments, and utilization management. PIHPs ensure that individuals seeking care at CCBHCs receive immediate screenings and risk assessments without needing referrals through access centers, a change intended to streamline care delivery. However, this new oversight also requires providers to navigate retrospective reviews to confirm the medical necessity of services, which may increase administrative burdens and reduce the operational autonomy of CCBHCs.

Providers must now comply with stricter protocols, such as ensuring clients are not steered based on acuity and that there is capacity to meet service demand. While prior authorizations for CCBHC services are no longer required, PIHPs are responsible for conducting audits and ensuring that services meet Medicaid standards. This places a greater emphasis on detailed documentation and adherence to compliance standards, with the potential for increased scrutiny during audits. Ultimately, these changes require providers to maintain accurate and timely service delivery while navigating PIHP oversight and administrative demands.

Providers Urged to Rally Against Medicaid Funding Gap Impacting Mental Health Services

Michigan’s public mental health system is facing a critical revenue gap due to the end of Medicaid re-enrollment freezes, resulting in over 700,000 individuals losing coverage. As Medicaid funding to Prepaid Inpatient Health Plans (PIHPs) drops, the demand for mental health services remains steady, leaving providers struggling with limited resources. This funding shortfall has forced many providers to reduce services, cut staff, and extend wait times as they operate on the diminished funds available.

The Community Mental Health Association of Michigan (CMHA), along with the Mental Health Association of Michigan, ARC, and Disability Rights Michigan (DRM), has launched a campaign to raise awareness about this crisis. These organizations have called on the Michigan Department of Health and Human Services (MDHHS) to retroactively increase Medicaid capitation rates and close the $93 million revenue gap. Providers are urged to join the campaign, raise their voices, and share the local impact of these funding cuts on their communities to help secure critical resources for mental health services.

MDHHS Slow to Respond to Concerns Around CFAP

Michigan's Conflict-Free Approach Policy (CFAP) emphasizes minimizing conflicts of interest in mental health service delivery, a position strongly supported by the Community Mental Health Association of Michigan (CMHAM). In a letter to the Centers for Medicare & Medicaid Services (CMS), CMHAM reiterated the importance of empowering individuals served through independent facilitators, full-service choice, and independent grievance processes. The policy ensures that Michigan’s Community Mental Health Centers (CMHs), which operate under a shared-risk prepaid and global budget system, are prohibited from profit-taking. Any surplus Medicaid funds must be reinvested into the system, safeguarding against financial incentives that could influence care decisions.

However, despite ongoing advocacy efforts, including outreach from CMHAM and its partners, the Michigan Department of Health and Human Services (MDHHS) has been slow to respond to concerns about CFAP compliance. CMHAM has repeatedly called for clarity and further action from MDHHS to address potential conflicts in the service delivery system, but the department has yet to provide a satisfactory response. This lack of responsiveness is creating challenges for providers and advocates who are striving to maintain the integrity of Michigan’s public mental health system while ensuring that individuals served have access to fair, conflict-free care

ICYMI

Press Release: Superintendents Talk Mental Health with Secretary of Education

LEGISLATIVE + CANDIDATE FOCUS

We profile legislators and candidates each week. This week, we encourage you to learn more about State Rep. Kathy Schmaltz (46th District, Jackson), the minority vice chair of the House Behavioral Health Subcommittee. Learn more about Rep. Schmaltz here.

If you have an event you want to share, please get in touch with Daniel Cherrin.

PHIP Contacts

Links to board meetings, notes, and key contact information on the PIHPs can be found here.

REGION 1 - NORTHCARE NETWORK

Pathways CMH (Alger, Delta, Luce, Marquette) Copper Country CMH (Baraga, Houghton, Keewanaw, Ontonagon) Hiawatha CMH (Chippewa, Mackinac, Schoolcraft) Northpointe CMH (Menominee, Dickinson, Iron) Gogebic CMH

REGION 2 - NORTHERN MI REGIONAL ENTITY

AuSable CMH (Oscoda, Ogemaw, Iosco), Manistee-Benzie CMH (Manistee, Benzie), North Country CMH (Antrim, Charlevoix, Cheboygan, Emmet, Kalkaska, Otsego), Northern Lakes CMH, (Crawford, Grand Traverse, Leelanau, Missaukee, Roscommon, Wexford) Northeast CMH (Alcona, Alpena, Montmorency, Presque Isle)

REGION 3 - LAKESHORE REGIONAL ENTITY*

Allegan CMH, Muskegon CMH, Network 180 (Kent), Ottawa CMH, West MI CMH (Lake, Mason, Oceana)

REGION 4 - SOUTHWEST MI BEHAVIORAL HEALTH

Barry CMH, Berrien CMH, Kalamazoo CMH, Pines CMH (Branch), St. Joseph CMH, Summit Pointe CMH (Calhoun), Van Buren CMH, Woodlands CMH (Cass)

REGION 5 - MID-STATE HEALTH NETWORK

(Bay, Arenac,  Clare, Gladwin, Isabella, Mecosta, Clinton, Eaton, Ingham, Gratiot, Huron, Ionia,  Lifeways, Jackson, Hillsdale, Montcalm, Newaygo Saginaw, Shiawassee, Tuscola)

REGION 6 - CMH PARTNERSHIP OF SOUTHEAST MI

Washtenaw CMH, Lenawee CMH, Livingston CMH, Monroe CMH

REGION 7 - DETROIT WAYNE INTEGRATED HEALTH NETWORK

REGION 8 - OAKLAND COMMUNITY HEALTH NETWORK

REGION 9 - MACOMB COUNTY CMH*

*No Board Notes

*_{Articles were generated with AI and reviewed by the human eye.}