Providers face a new playbook for service takeovers. Oakland County is showing other CMHSPs how to bring services in-house, bypass long-standing partners, and justify it under MCL 330.1208, even when the law doesn’t require it; The redesign still leaves the central conflict unresolved. A PIHP cannot act independently if it funds, monitors, and shares infrastructure with the CMHSP that receives the dollars. Firewalls won’t fix that; and, Providers must protect themselves now. Document changes in referrals, push for written policies, prepare for new PIHP contracts, and engage MDHHS and legislators before more services are unilaterally taken over. Pull Up Your Chair & Let’s Start the Conversation.

A Warning to Providers, OCHN Provides Other CMHSPs a Roadmap to Service Seizure

Oakland County’s decision to bring adult crisis services in-house marks a significant change in how one of Michigan’s largest Community Mental Health Services Programs delivers care. For more than a decade, Common Ground has operated the county’s primary crisis center, responding to thousands of behavioral health emergencies each year and serving as a regional anchor during some of Michigan’s most difficult moments.

This month, Oakland Community Health Network (OCHN) announced that it will assume direct control of crisis operations beginning in January, without negotiating with Common Ground. The organization, which serves as both the county’s CMHSP and its Prepaid Inpatient Health Plan (PIHP), said the shift is intended to create a more coordinated continuum of care and fill the “gaps” within the system.

Common Ground employs more than 170 people under its OCHN contract and has operated crisis services for decades. Replacing a long-standing provider with an internal operation, without a publicly vetted transition plan, raises questions about capacity, transparency, and day-one readiness. OCHN said they passed a policy on this years ago, but many of their board members seemed unaware of that policy.

These concerns are not unique to Oakland County. Michigan’s behavioral health system is in the midst of a statewide redesign that emphasizes conflict-free oversight, network adequacy, and clear separation between funding and service delivery functions. OCHN is one of the few entities in the state that serves as both payer and provider. As the system evolves, similar decisions may emerge in other regions as CMHSPs reassess their roles and responsibilities.

This is why Oakland County’s experience matters statewide. When a funder moves to take over the services it oversees, the risks to continuity, transparency, and provider stability will have a negative impact on the system and on people’s lives. The issue is not whether CMHSPs can provide services, but how they do so, and whether the transition strengthens or destabilizes the existing network of care. It also an issue of working with your partners, not against them.

As behavioral health reforms move forward, Oakland County’s shift serves as a reminder that system changes must be deliberate, transparent, and grounded in clear planning. The stakes are too high for anything less.

The Oakland County Health Network meets again December 16, 2025, 6:00 PM - 8:00 PM, at their Main Office in Troy. You are encouraged to attend and provide public comment, in person, or virtually. You are also encouraged to contact their board members, found here and contact legislators and the MDHHS with any concerns.

Read further:

Michigan’s Behavioral Health Redesign Raises an Unresolved Question:
Can a PIHP Spin Off a CMHSP and Still be Independent?

At last week’s OCHN board meeting, leaders shared a new scenario taking shape as the state moves toward its redesigned behavioral health system. If OCHN becomes a PIHP under the new procurement process, they indicated that:

• A new PIHP board would be formed with partner counties such as Macomb.
• The current OCHN board would transition to a CMHSP board.
• The new PIHP and CMHSP would share resources but maintain “firewalls,” similar to today.

On its face, while the two entities would maintain separate governance but share administrative resources, and use firewalls to separate payer and provider functions, the conflicts that are in place today, would remain under the new system, just another board to work with.

If a PIHP is still funding a CMHSP that is structurally connected to it, how is that not a conflict of interest?

You can separate boards.
You can draft firewalls.
You can split a logo into two parts.

But if the PIHP approves the payments, and the CMHSP receives the payments, and both entities share leadership lineage, infrastructure, financial systems, or strategic incentives, the conflicts still remain. In the end, the PIHP is still evaluating, monitoring, and paying itself.

Michigan’s entire redesign was supposed to reduce fragmentation and remove the dual-role conflict that has strained trust for decades. Allowing a PIHP to split itself in half, share resources with its provider arm, and call that independence, does not eliminate the conflict. It only manages the appearance of separation.

There are only three ways to eliminate the conflict outright:

Anything short of this preserves the incentive to self-protect, self-prioritize, and self-fund, regardless of how many firewalls are drawn.

So how do we fix this? Not through a contract alone.

A real solution requires a combination of strong PIHP contract terms, targeted updates to the Mental Health Code, a few administrative rule revisions, and clearer oversight requirements. Independence must be enforceable, not symbolic.

What Providers Should Be Doing Now?

While the state works through procurement should work to protect themselves today. Here are the steps every provider should take:

Michigan is about to make the biggest structural change to its behavioral health system in decades, yet the most fundamental question remains unanswered. Can a PIHP that is structurally tied to a CMHSP ever act as an independent payer? Until that question is resolved in law, contract, and practice, the conflict will remain in some regions.

Follow the state’s redesign,

Is MCL 330.1208 a License for CMHSPs to Take Services In-House? Here’s What the Law Actually Says, and What Providers Need to Prepare For

At the November 18 OCHN board meeting, a board member cited MCL 330.1208 as justification for bringing services in-house. It’s an argument we are hearing more frequently, not just in Oakland but across the state as CMHSPs and PIHPs position themselves in anticipation of Michigan’s pending system redesign.

MCL 330.1208 does not require CMHSPs to directly deliver services. It simply requires them to ensure that services are provided, either directly or by contract. The statute has always been read as giving CMHSPs flexibility, not a mandate to absorb programs or displace long-standing community providers.

For more than three decades, Michigan’s public behavioral health system has operated on a hybrid model. CMHSPs contract with a network of nonprofit and private providers who deliver the bulk of services, while CMHSPs directly operate some core functions such as screening, intake, or care coordination. The entire premise of Michigan’s public system, and its strength, is a diverse, community-based provider network.

That is why invoking MCL 330.1208 to justify taking over transportation, crisis lines, mobile crisis, or other long-established contracted services is not a neutral interpretation. It is a policy choice, and one with consequences for access, continuity, and trust.

We have watched this trend accelerate.

As PIHPs and CMHSPs prepare for the outcome of the state’s procurement, they are continuing to position themselves as both payer and provider. That creates conflicts of interest and destabilizes the very network the public system relies on. If this trend continues, providers should expect more takeovers. Potential targets include:

Any service with significant Medicaid dollars attached or where the PIHP sees financial or strategic value. It seems the only programs that are safe from a takeover are evidence-based programs or specialty services.

Each move fractures the provider network, reduces choice for beneficiaries, and puts more people into a system where the payer competes with its own contractors.

What Providers Should Do Now

A Path Forward

Michigan needs a provider network that is strong, diverse, and supported. The CMHSP’s role is to ensure access, coordinate care, and steward public dollars, not to monopolize services. The law, including MCL 330.1208, has always recognized that balance.

Providers have built the backbone of Michigan’s behavioral health system. They have earned trust, delivered results, and adapted through every change. As procurement approaches and local CMHSPs continue taking steps to consolidate power, providers must protect what they’ve built, and push for a system that values partnership over control.

FYI: Who else submitted a proposal? We heard that the Michigan Association of Counties (MAC) and Rehmann submitted proposal to become a PIHP. If MAC submitted a proposal it is interesting then how a number of county commissions passed similar proposals asking the state to not move forward with the redesign. Rehmann also represents a number of PIHPs in the state.

Read more,

Request for Quote- Prepaid Inpatient Health Plan- Readiness Assessment

Northpointe director offers information on mental health services

What HB 4407 Would Mean for Providers

HB 4407 creates the framework for MiCare, a publicly financed health coverage system intended to simplify how Michiganders access care. The bill would replace today’s patchwork of plans with a single statewide model that covers all residents, streamlines reimbursement, and reduces administrative complexity for both medical and behavioral health providers. For providers, the value is straightforward: fewer intermediaries, clearer rules, consistent payment structures, and a system that is easier for clients to navigate. While the details will continue to evolve, HB 4407 signals a shift toward a more coordinated, predictable environment, one where providers can focus more on care and less on paperwork. This bill sits in the Referred to Committee on Government Operations.

Healthy Kids Dental Contract Up

A competitive bidding process for Healthy Kids Dental, a free dental program for 955,000 Michigan children statewide, was announced last week. Under the benefit program, children with Medicaid can receive such services as X-rays, cleanings, fillings, extractions, sealants and more at no cost to families. The Healthy Kids Dental model functions similarly to commercial dental plans. In 2018, Blue Cross Blue Shield of Michigan was awarded a $659 million contract for its Healthy Kids Dental Program, which led a Florida insurance company to sue. Source MIRS

New trauma center is helping violent crime survivors heal free of charge

3 states to expand behavioral health clinics with $72M grant

Autism Care Faces Market Reckoning as Payers, Investors Push for Proof of Outcomes

Opinion: The cost of health care Is everyone’s business, Crain’s

New walk-in Behavioral Health Urgent Care now open in Monroe

National Council for Mental Wellbeing, NASMHPD Announce Major Investment in Certified Community Behavioral HealthClinics

FOCUS Forward program tackles the ‘Failure to Launch’ crisis among youth in Calhoun County – Second Wave, Second Wave

Policy paths to what Black Michigan communities need, Axios Detroit

Rep. Bierlein: Mental health evaluation plan streamlines assessments, needed care

Munson Medical Center receives $2.5M grant for street medicine expansion

Michigan earmark reform passes amid AG investigations into misused public funds

Gesher Human Services to Offer New Support Coordination Services to Children with Intellectual and Developmental Disabilities in Wayne County

Michigan districts sue state for tying school safety and mental health funding to privilege waiver, Michigan Advance
Superintendents and leaders in three dozen school districts around Michigan have filed lawsuits in both federal and state court to challenge a provision of the school funding bill passed last month that would tie funding for mental health and school safety grants to a waiver of “any privilege that may otherwise protect information from disclosure in the event of a mass casualty event.”

Model Medicaid Reentry Section 1115 Demonstration Waiver Act
Legislative Analysis and Public Policy Association via NBHAP
The purpose of the Model Medicaid Section 1115 Demonstration Waiver Act is to: (1) Require a state department of health and human services to apply for a Medicaid reentry Section 1115 demonstration waiver to allow a state Medicaid program to cover pre-release services for a Medicaid eligible incarcerated individual for up to 90 days prior to the individual's expected release date and (2) Require a state department of health and human services to conduct comprehensive monitoring and evaluation of the Medicaid reentry demonstration, if the waiver is approved.... Read More

Attracting Top Talent in the Addiction Field: Strategies for Employers
Counselor Magazine via NBHAP
As an employer in the addiction-focused industry, you understand the critical role your organization plays in supporting individuals on their journey to recovery. To deliver exceptional care and services, it's essential to attract and retain top talent. In this blog post, we'll explore effective strategies for attracting skilled professionals who are passionate about making a difference in the addiction field. Read More

Digital Mental Health, SUD Provider Affect Therapeutics Raises $26M
Behavioral Health Business
Digital mental health and addiction treatment provider Affect Therapeutics has raised $26 million in funding. That’s according to Axios, which reported the Series B funding round was led by Allumia Ventures. Read More

How States Are Modernizing Facility Licensure to Advance Integrated Care

Windsor unveils Canada’s first COMPASS Station for drowning prevention and crisis support, CHWI TV (Canada)

ARPA-H to invest in leading-edge approaches to mental health treatment

 The Advanced Research Projects Agency for Health (ARPA-H) today announced it will invest up to $100 million in more quantitative measures of mental and behavioral health through its new Evidence-Based Validation & Innovation for Rapid Therapeutics in Behavioral Health (EVIDENT) initiative.

EVIDENT will pursue two foundational components to improve behavioral and mental health care: more robust data on individual clinical outcomes, as well as a patient’s unique response to novel treatment approaches. Establishing such objective measures of mental and behavioral health will accelerate innovative diagnostics and treatments for these disorders. “Through EVIDENT, we aim to break through longstanding barriers in mental health measurement, diagnosis, and treatment — bringing faster, more precise solutions to all Americans,” said ARPA-H Director Alicia Jackson, PhD. “With robust data and novel therapies, we are paving the way for understanding the best uses of groundbreaking treatments and demystifying the field of mental health.”

Over their lifetime, half of all Americans will experience mental and behavioral health disorders, including addiction, anxiety, depression, and post-traumatic stress disorder. The rates of addiction are higher for veterans compared to the general population. Yet, today’s treatments are rarely tailored to an individual and thus remain largely trial-and-error, based on patchwork clinical trial data and outdated tools for assessing treatment outcomes.

Novel approaches to treat mental health disorders, such as neuroplastogens (compounds that quickly promote the nervous system's ability to adapt structurally and functionally), neuromodulation, and digital therapeutics, have shown extraordinary promise to revolutionize behavioral health, especially for veterans. Despite this potential, current diagnostics and treatments rely on subjective endpoints and are not matched to individual needs, resulting in a “trial-and-error” approach that limits innovation. Beyond biomarkers, there is an opportunity to combine data to garner clearer insights into a person’s mental state — and, in turn, predict what treatments will work swiftly and optimally for any individual. With better data, patients will spend less time using therapies that aren’t working for them, and their course of treatment can be quickly adapted to reflect their individual experience.   Through a forthcoming solicitation, ARPA-H is seeking multimodal, longitudinal data (e.g., psychological, social, digital, biological) collected in registered clinical trials testing the effects of rapid-acting interventions for behavioral health (e.g., neuroplastogens, neuromodulation, digital therapeutics). These deidentified data and biological samples will then be curated and stored within a Rapid Response Data Repository managed by an ARPA-H partner, to enable research and accelerate future discoveries.

The data from this solicitation also seeks to improve providers’ ability to identify when a specific therapy will be most effective and monitor rapid treatment effects when they are occurring. This will indicate when a treatment is or is not working for an individual, rather than taking a trial-and-error approach, and ultimately, will reduce the burden of mental illness, lower healthcare costs, and improve quality of life for millions of Americans. EVIDENT awards are not grants, but actively managed contracts, where each performer’s continuation of work will be contingent upon successful performance reviews by ARPA-H, demonstrating measurable progress toward defined milestones, including data collection, quality, and delivery. For more information, visit the EVIDENT at the ARPA-H Customer Experience Hub.