The MHA recently submitted comments to the Michigan Department of Health and Human Services (MDHHS) on proposed policy 2545-BH, which sets new mental health assessment requirements for Medicaid Health Plan providers caring for Comprehensive Health Care Program enrollees.
Although the association supports MDHHS’ effort to strengthen coordination between Community Mental Health agencies and Medicaid Health Plans, providers report that the policy’s training demands, documentation requirements and unclear implementation timeline create challenges that could unintentionally restrict access to behavioral health services.
To help providers prepare, the MHA recommended that MDHHS delay the implementation date to Oct. 1, 2026. Providers shared that training for the MichiCANS and LOCUS tools requires 10–13 hours, plus a certification test and that available sessions remain limited or canceled. Hospitals anticipate substantial financial and staffing impacts, including lost clinical time and increased administrative work. The association also proposed removing the certification test requirement, expanding training availability, and resolving duplicate documentation problems between state platforms and electronic medical records.
The MHA also urged MDHHS to narrow the list of provider types that must complete the training, noting that the current scope overextends an already strained behavioral health workforce. Providers requested clearer expectations for when reassessments are required and specific guidance for rural health clinics, whose responsibilities under the policy remain undefined.
The association further encouraged MDHHS to share data on how many individuals experience coordination gaps between Community Mental Health agencies and Medicaid Health Plans. Greater transparency would help determine whether a statewide implementation approach matches the scale of the issue.
Providers warn that without adjustments; the policy could reduce Medicaid behavioral health capacity an increase barrier to timely behavioral health treatment.
Members with questions may contact Lenise Freeman at the MHA.