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.  Sign up for one or more advocacy shifts (calls and emails) to ensure daily engagement with legislators and BCBSM leadership: https://linktr.ee/ProtectPrivatePractice

2. 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]

3.  Tag your legislators on social media and request a local coffee hour this summer and then show up with the one-pager (or set visits in Lansing before they leave for break)

4.  Notify and engage clients by directing them to make phone calls using this Client Notice/Call Script

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

Stakeholders support strong supervision standards and accountability. The goal is not to reduce oversight, but to preserve access to care while recognizing the role licensed professionals play in Michigan's behavioral health workforce.