Blue Cross Blue Shield of Michigan (BCBSM) recently announced that beginning March 1, 2027, services provided by behavioral health students and certain licensed behavioral health professionals completing required post-graduate supervision hours will no longer be eligible for reimbursement through incident-to billing in professional office settings.
Behavioral health providers, educators, students, and consumers have raised concerns that this policy may reduce access to care, disrupt established treatment relationships, and weaken Michigan's behavioral health workforce pipeline at a time when provider shortages remain a significant challenge.
Your Next Steps After Completing This Action Alert
1. Attend the upcoming protest!
- Friday, August 21st
- 12:00pmEST
- BCBSM Headquarters (600 E Lafayette Blvd., Detroit, MI)
3. Join the movement via slack and participate in workgroups:
- Advocacy and Outreach – sign up for advocacy shifts to call and emails, and attend legislator coffee hours with the one-pager
- Legal and Regulatory – help review legal intervention strategies and craft policy documents
- Activism and Events – plan protests, public forums, and other direct action
- Education and Communication – craft messaging and public-facing materials
4. Take and share the surveys:
- SURVEY 1 – Fully Licensed Providers (LPCs, LMFTs, LMSWs, LLPs and LPs) and Private Practice Owners/Administrators
- SURVEY 2 – Limited Licensed Providers (LLCs/LLPCs, LLMSWs, LLMFTs, TLLPs, and DLLPs)
- SURVEY 3 – Clients [PDF/QR Code Version]
5. Notify and engage clients by directing them to make phone calls using this Client Notice/Call Script
6. Review and use these additional resources for faculty, students, providers, clients, and more!
Limited-License Professionals Are Already Part of Michigan's Behavioral Health Workforce
Limited Licensed Social Workers (LLMSWs), Limited Licensed Professional Counselors (LLPCs), Limited Licensed Marriage and Family Therapists (LLMFTs), Temporary Limited Licensed Psychologist (TLLP), and other limited-license behavioral health professionals have:
- Earned graduate degrees
- Obtained professional licensure from the State of Michigan
- Begun practicing within their profession
- Accepted responsibility for client care
- Become subject to professional regulation and disciplinary oversight
They are licensed professionals completing required post-graduate supervision hours in order to obtain independent licensure.
Stakeholders support strong supervision standards and professional accountability. The question is not whether supervision should exist, but whether licensed behavioral health professionals completing required supervision hours should remain accessible to clients through existing care delivery models.
Why This Matters
Michigan's behavioral health workforce is built through a continuum of student training, supervised practice, and independent licensure. Private practices play a critical role in this workforce pipeline by serving as both student placement sites and clinical supervision sites for licensed professionals.
Impact
Outcomes of this policy include:
- Longer wait times for behavioral health services
- Reduced provider availability
- Disruptions in continuity of care
- Fewer student placement opportunities
- Reduced employment opportunities for clinicians seeking to complete supervision requirements for independent licensure
- Greater barriers to obtaining supervision hours required for independent licensure
- Reduced access in rural and underserved communities
Michigan has invested significant resources in expanding behavioral health access and addressing workforce shortages. Policies that reduce opportunities for students and licensed behavioral health professionals to complete supervision requirements for independent licensure should be carefully evaluated for their impact on access to care and workforce development.
What We're Asking For
We urge BCBSM to:
- Conduct and publish an impact assessment examining the policy's effects on access to care, continuity of treatment, provider availability, workforce development, and rural and underserved communities
- Publicly share the data, evidence, and analyses used to justify this policy change, including any evaluations of quality, safety, outcomes, supervision practices, network adequacy, or member impact
- Engage providers, consumers, educational institutions, workforce leaders, and professional associations before implementation
- Consider enhanced supervision documentation, reporting, or auditing mechanisms in lieu of this change
- Develop a reimbursement pathway that recognizes licensed professionals completing required supervision hours for independent licensure
- Establish continuity-of-care protections for members currently receiving treatment