MHA Shares Talking Points on Mental Health Framework

The MHA recently finalized talking points on Michigan’s Mental Health Framework to support hospital engagement with policymakers and legislators.

The release follows the association’s formal comment letter outlining hospital concerns with the proposed framework, particularly related to access to care, administrative burden and implementation challenges.

The talking points provide clear and consistent messaging to guide member advocacy efforts. The materials outline potential risks, including that the framework may:

  • Put behavioral health access at risk for Medicaid patients.
  • Create delays in crisis care due to redundant assessment requirements.
  • Add significant administrative and documentation burden during a period of workforce shortages.
  • Require extensive training and certification processes that remove clinicians from direct patient care.
  • Lack sufficient implementation time and infrastructure to support a successful rollout.
  • Expand requirements broadly across provider types without clear prioritization.
  • Move forward without transparent data demonstrating improved outcomes.

Members are encouraged to use the talking points in meetings, calls and written communication with legislators and state officials. Direct engagement will be critical to ensure that any changes to the Mental Health Framework strengthen access to care and avoid unintended disruptions to care delivery.

Members with questions may contact the MHA policy team.

DEA Extends Telemedicine Rule for Controlled Substances Through 2025

The Drug Enforcement Administration (DEA) and the Department of Health and Human Services (HHS) recently issued a rule extending telemedicine prescribing flexibilities for controlled substances through Dec. 31, 2025. This extension continues pandemic-era provisions, allowing controlled substances to be prescribed via telemedicine without requiring a prior in-person visit, which is crucial for Michigan hospitals, particularly in rural and underserved communities.

The rule will:

  • Extend the ability to prescribe Schedule II-V controlled substances, including medications like buprenorphine for opioid use disorder, via telemedicine.
  • Allow flexibilities to apply to all practitioner-patient relationships, not just those established during the COVID-19 public health emergency.
  • Serve as an effort to ensure continued access to essential healthcare, reduce requirement of in-person evaluations and provide critical medications, especially for opioid use disorder.

While the rule extends telemedicine prescribing flexibilities, certain conditions remain in place:

  • The prescription must be issued for a legitimate medical purpose and within the usual course of professional practice.
  • The prescription must be issued through an interactive telecommunications system, ensuring that the patient and practitioner are engaged in a real-time communication.
  • The practitioner must be authorized to prescribe the controlled substance under their DEA registration or be exempt from the need for a registration.
  • The prescription must comply with all relevant legal and regulatory requirements for controlled substances.

This extension provides the DEA and HHS more time to continue reviewing and evaluating telemedicine and controlled substance policies. The MHA submitted a comment letter advocating for expanded access to telehealth and will remain actively involved in these efforts throughout 2025.

Members with questions may contact Kelsey Ostergren at the MHA.

MHA Provides Comment on Proposed Medicaid Reimbursement for Group Prenatal Care

The MHA submitted a comment letter to the Michigan Department of Health and Human Services regarding the proposed Medicaid coverage of group prenatal care, set to begin in October 2024. The MHA expressed support for the policy, highlighting its potential to significantly improve maternal and infant health outcomes in Michigan. However, in its comment letter, while supporting the policy, the MHA requested clarification on the reimbursement rate and suggested a higher rate for sessions with larger attendance due to the increased resources required.

Members with questions may contact Lauren LaPine at the MHA.