Category: Administrative Rules

MHA Submits Comments on Proposed Medicaid Mental Health Assessment Policy

Administrative Rules, Member News

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 and be an increase dbarrier to timely behavioral health treatment.

Members with questions may contact Lenise Freeman at the MHA.

MHA Releases Executive Summary of Final LARA Rules for Osteopathic Medicine and Surgery

Member News, Administrative Rules

The MHA recently released an executive summary regarding administrative rules finalized by the Michigan Department of Licensing and Regulatory Affairs (LARA), updating licensing and practice standards for osteopathic medicine and surgery in Michigan. The rules, issued through the Bureau of Professional Licensing, took effect May 8, 2025.

These updates align licensing requirements with evolving accreditation standards and aim to modernize healthcare regulation, reduce barriers to practice and uphold patient safety.

Key changes addressed in the summary include:

  • Delegation of Certain Procedures: Removes the prohibition on delegating medications or devices intended to cause miscarriage or fetal death in a pregnant patient.
  • COMLEX-USA Exam Attempt Limits: Reduces the maximum number of exam attempts per level from six to four.
  • Removal of Seven-Year Completion Rule: Eliminates the requirement to complete all levels of the licensing exam within seven years of passing the first.
  • Continuing Education Waiver Clarification: Provides new guidance on when and how licensees may request continuing education waivers.
  • Implicit Bias Training Eligibility: Allows implicit bias training under Rule 338.7004 to count toward continuing education requirements.
  • Expanded CE Provider Options: Permits non-Accreditation Council for Continuing Medical Education (ACCME)-accredited programs to qualify if offered in partnership with an ACCME-accredited organization.

Members are encouraged to review the summary and share it with relevant clinical and credentialing staff. For questions, please contact Lenise Freeman at the MHA.

MHA Releases Executive Summary of Recent MDHHS Blood Lead Testing Mandate Rules

Administrative Rules, Member News

The MHA recently released an executive summary regarding the Michigan Department of Health and Human Services’ (MDHHS) adoption of new administrative rules establishing universal blood lead testing requirements for minors across the state.

The goal of these rules is to improve early detection and prevent lead poisoning in children. The rules establish standardized testing requirements for physicians treating minors and mandate integration of test results into the Michigan Care Improvement Registry.

The executive summary provides members with more details of the following:

  • Testing requirements.
  • Identification of high-risk jurisdictions.
  • Reporting and immunization records integrations.
  • Parental objections.
  • Recommended actions for hospitals.

Members are encouraged to review the executive summary and share it with other hospital leaders. Members with questions may contact Lenise Freeman at the MHA.

LARA Finalizes Osteopathic Licensing and Practice Rules

Member News, Administrative Rules

The Department of Licensing and Regulatory Affairs (LARA) recently finalized administrative rules that update licensing and practice standards for osteopathic medicine and surgery in Michigan, effective May 8, 2025.

The revised rules, issued through the Bureau of Professional Licensing, reflect changes to licensing exams, continuing education and scope of practice, aligning with evolving accreditation standards. Physicians and license applicants are encouraged to review the updates to ensure compliance.

Key changes include:

  • Delegation of Certain Procedures: The updated rules remove the ban on delegating medications or devices intended to cause miscarriage or fetal death in a pregnant patient.
  • COMLEX-USA Exam Attempt Limits: The maximum number of attempts per level on the licensing exam is now four, reduced from six.
  • Removal of Seven-Year Completion Rule: Applicants are no longer required to complete all exam levels within seven years of passing the first.
  • Continuing Education Waiver Clarification: New guidance is provided on when and how licensees may request waivers.
  • Implicit Bias Training Eligibility: Implicit bias training under Rule 338.7004 may now count toward continuing education requirements.
  • Expanded CE Provider Options: Non-ACCME-accredited education programs may qualify if partnered with an ACCME-accredited organization.

These revisions are part of Michigan’s efforts to modernize healthcare regulation, reduce barriers to practice and uphold public safety.

The MHA is preparing an executive summary of the rule changes to share with members in the coming weeks.

Members with questions may contact Lenise Freeman at the MHA.

MHA Submits Comments on Proposed MDHHS Medicaid Behavioral Health Policies

Member News, Administrative Rules

The MHA submitted comments to the Michigan Department of Health and Human Services (MDHHS) regarding two Medicaid proposed policies Aug. 20 pertaining to the establishment of Intensive Care Coordination with Wraparound (ICCW) and the implementation of the MichiCANS tool for Medicaid-Funded Specialty Behavioral Health Services.

The MHA outlined general support of the efforts in the two proposed policies. However, in the comment letter on ICCW establishment, the MHA requested clarification on the timeline for approval of requests, criteria used for re-evaluation or extension of services and more details on transition plans after cessation of ICCW services.

On the implementation of the MichiCANS tool, the MHA also requested clarification on the timeline for approval of ICCW requests and more details related to transition plans after the cessation of ICCW services. In addition, the MHA requested further detail on the transition process when a beneficiary ages out of relevant programs.

Members with questions may contact Lauren LaPine at the MHA.