In this week’s issue of Pull Up Your Chair, providers are navigating continued uncertainty around Michigan’s behavioral health redesign, new non-binding guidance affecting self-directed services, and national signals that workforce stability and funding remain unresolved pressures. Since this will be our last edition of 2025, Pull Up Your Chair & Let’s Start the Conversation. Thank you for making our newsletter a part of your weekly reading. We will publish again January 5, 2026. Wish you a meaningful and memorable holiday!

Redesign Update

We are all watching the Court of Claims website for when the Court will post its opinion. The Court to Decide Whether MDHHS Can Overhaul Mental Health Care Structure, Michigan News Source.

PIHP Overreach

A recent action by Oakland Community Health Network should be a warning sign for providers across Michigan and beyond. In a December provider bulletin, OCHN unilaterally revised its benefit plans to impose a hard cap of four hours per day on Community Living Supports (H2015), with any additional hours subject to utilization management review, effective immediately. The change was issued as a benefit plan adjustment rather than through a collaborative policy or contract process, placing providers in the position of implementing service reductions while continuing to meet individualized medical-necessity requirements and person-centered planning obligations

For providers, this move reflects a broader and troubling pattern of PIHP overreach. By redefining benefit limits outside of rate-setting, contract negotiation, or transparent systemwide guidance, PIHPs effectively shift financial and clinical risk downstream to providers while maintaining centralized control over authorization decisions. What makes this especially concerning is not just the policy itself, but the precedent it sets. If benefit caps can be imposed through provider bulletins with minimal notice or engagement, other regions may follow suit under the banner of utilization management or cost containment.

Waksul Update

MDHHS Issues Non-Binding Guidance to Support Implementation of Self-Directed Service Policies

The Michigan Department of Health and Human Services has released the Waskul Non-Binding Guidance to support implementation of Medicaid policy bulletins MMP 25-31 and MMP 25-41, which took effect October 1, 2025. The guidance was developed in response to the court order in Derek Waskul, et al. v. Washtenaw County Community Mental Health, et al., and is intended to provide practical examples to clarify how self-directed service requirements may be applied in day-to-day operations. According to MDHHS, the document reflects questions and requests for clarification raised during the public comment process and is designed to accompany, not replace, the underlying policy bulletins published in the Medicaid Provider Manual.

For community mental health providers and partners supporting self-directed arrangements, the guidance outlines examples related to budget development, the role of Financial Management Services, collaborative problem solving, documentation of requests not approved, and requirements when budgets are reduced. The examples emphasize that determinations of service need must remain individualized and that budget authority rests with the appropriate planning and authorization processes, while also detailing expectations for documentation, communication, and compliance. MDHHS has indicated that the guidance will be incorporated into an updated Self-Direction Technical Requirement Implementation Guide and that additional technical assistance opportunities will be offered

Flinn Foundation Announces the 2025 Leonard W. Smith Mental Health Heroes

Congratulations to James Ebaugh, Executive Director, MiSide Health, Lenora Hardy-Foster, President & CEO, Judson Center, and other honorees, on being named a 2025 Leonard W. Smith Mental Health Hero by the The Ethel and James Flinn Foundation. The Leonard W. Smith Mental Health Hero Award honors leaders whose work is shaping a stronger, more connected mental health system for southeast Michigan.

Model Medicaid Reentry Section 1115 Demonstration Waiver Act

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 (Source: National Behavioral Health Association of Providers). The NASHP’s toolkit provides a national overview of the health care consolidation landscape and includes tools, such as model legislation, to help inform decision-making. (Source: National Academy for State Health Policy)

SUD

The U.S. Economy Has a $93 Billion Substance Abuse Black Hole
Newsweek reports on a new CDC-led study showing that substance use disorders (SUDs) drained nearly $93 billion from the U.S. economy in 2023 through lost work, reduced productivity and diminished household output.

Integrating Substance Use Disorder Services Into Primary Care: Spotlight on Kentucky
This blog post from the National Academy for State Health Policy describes how Kentucky is integrating SUD services into primary care by embedding peer support specialists, expanding provider training and using flexible funding to build a practical, stigma-reducing model for delivering evidence-based addiction care.

President Trump Signs SUPPORT Act
On Monday, Dec. 1, President Trump signed into law H.R.2483, the SUPPORT for Patients and Communities Reauthorization Act of 2025, reauthorizing funding through the next five years for many crucial programs, including the SUD Treatment and Recovery (STAR) Loan Repayment Program. It also supports critical recovery efforts achieved through the Building Communities of Recovery program and comprehensive opioid recovery centers. Read our section-by-section summary for a more detailed explanation of each of the SUPPORT Act’s provisions.

Rural Health

The Rural Health Transformation Program and Maternal Mental Health

Women in rural communities are 21% more likely to experience depression during and around pregnancy than women in other areas. The National Governors Association explores how states can use Rural Health Transformation Program funds to improve maternal mental health.

Privatization of CCBHCS- Oklahoma

The Oklahoma Department of Mental Health and Substance Abuse Services has issued a request for proposals exploring whether private providers could assume operation of four state-run Certified Community Behavioral Health Clinics in Lawton, McAlester, Norman, and Fort Supply, while also reopening Logan and Oklahoma counties to address rising demand. (Oklahoma mental health department explores privatizing some behavioral care centers, Oklahoma Voice) According to the department, the RFP is a fact-finding step to assess whether a private operator could improve technology, modernize facilities, and support long-term workforce needs, with no final decisions made. The solicitation requires bidders to interview all willing incumbent staff and continue operating out of existing state facilities. (Oklahoma may privatize some of its behavioral health hospitals, The Oklahoman) Provider leaders note that the CCBHC model already faces funding challenges, including unpaid services, and have raised questions about workforce stability and the feasibility of expanding the model before existing obligations are fully funded. From a provider perspective, the process signals a potential shift in how Oklahoma delivers public behavioral health services, with operational, financial, and workforce implications that will merit close attention as the RFP moves forward. (The Real Fraud, Waste, And Abuse: Medicare And Medicaid Privatization, Health Affairs).

Reports

The Michigan Department of Labor and Economic Opportunity has released a new Workplace Mental Health and Well-Being report examining how chronic stress at work affects both mental and physical health, with implications for workers, employers, and the broader economy. The report outlines how workplace culture, policies, and conditions function as social determinants of health and highlights that these factors are modifiable through intentional investments in safe, healthy, and supportive work environments. State officials note that improving employment conditions requires collaboration across employers, workers, policymakers, and partners to strengthen workforce stability, productivity, and long-term well-being across Michigan.

Other stories