Pull Up Your Chair

In March 2023, the Michigan Department of Health and Human Services (MDHHS) Conflict-Free Access and Planning (CFAP) Workgroup convened to review various CFAP options proposed by MDHHS to comply with federal CFAP requirements. These proposals raised significant concerns among members of the Community Mental Health Association of Michigan (CMHA), particularly regarding potential threats to those served and the integrity of Michigan’s public mental health system.

CMHA and its members outlined these concerns and recommended actions in a document reviewed with MDHHS staff leading this effort. Following these discussions, MDHHS held several listening sessions to gather input from individuals served by Michigan’s public mental health system. Participants in these sessions expressed deep concerns about system fragmentation, increased complexity, and access barriers that result from MDHHS’s proposed approach to CFAP compliance.

In response to MDHHS’s plans, CMHA and its members have ramped up advocacy efforts, including legislative advocacy. The latest announcement by MDHHS regarding its CFAP implementation plans has intensified these efforts.

While CMHA supports the intent to limit conflicts, it believes MDHHS's proposed solution introduces unnecessary disruption and complexity, posing a greater threat than the conflicts it aims to prevent.

The CMHA urges you to contact your legislators (House & Senate) and the Governor to insist that MDHHS halt the implementation of its current approach to meeting federal CFAP requirements for Medicaid mental health services. We also ask that you encourage MDHHS to seek an alternative approach with the Centers for Medicare & Medicaid Services (CMS) to comply with federal regulations before making a final decision. Additionally, we advocate for including boilerplate language in the FY25 MDHHS budget (and FY24 supplemental budget) to address these concerns.

See action alert. (link)

Please feel free to customize your response as needed. Ask your Board of Directors, staff, and community partners to make similar contacts. Forward this email to them.

The Department of Health and Human Services (DHHS) is allocating $1.3 million from the opioid settlement to expand rooming-in programs for newborns with neonatal abstinence syndrome (NAS). This initiative, to be implemented in five hospitals, aims to keep babies exposed to addictive drugs with their mothers after birth, supporting families impacted by substance use.

The Community Mental Health Association of Michigan (CMHA) is calling on CEOs of Community Mental Health Services Programs (CMHs), Prepaid Inpatient Health Plans (PIHPs), and members of the Provider Alliance to review and provide feedback on a crucial document aimed at strengthening the foundation of Michigan’s public mental health system.

The need for a deep understanding of the laws, rules, and Medicaid waivers that underpin Michigan’s mental health system has been emphasized. It has been noted that many misguided policy, contract, and practice proposals stem from a lack of this essential knowledge.

To address this gap, the CMHA Board of Directors has tasked its staff, with guidance from CMHA members, to develop a comprehensive document capturing the key statutory, regulatory, and waiver-based foundations of Michigan’s public mental health system. The document aims to serve as a foundational resource for dialogue and advocacy on policy, contract, and practice issues with various stakeholders, including the Michigan Department of Health and Human Services (MDHHS), the State Legislature, federal agencies, CMHA members, and advocacy organizations.

The initial draft of the document has been shared with key stakeholders for review. Recognizing its length and detail, CMHA is seeking detailed feedback to refine and complete the document. It is emphasized that the document will remain a living document, subject to revisions as the policy landscape evolves.

Stakeholders are requested to review the document and provide guidance, especially focusing on the citation of laws, regulations, bid/procurement documents, and Medicaid waivers. While contract language has not been cited extensively due to its volume and variability, some key contract excerpts have been included. Stakeholders are encouraged to recommend additional contract language central to understanding the roles of the state, CMHSPs, and PIHPs.

The CMHA is looking for feedback by September 1, 2024, to be incorporated into the document for review by the CMHA Legislative and Policy Committee at its September meeting.

This newsletter does not endorse candidates or parties.

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