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A main street in a small Michigan town on an overcast late-winter afternoon

Statewide Policy Impact Assessment July 28, 2026

2,769 Michiganders told us what this policy would cost.

73% of clients said they would go without mental health care. We are asking BCBSM to make the current framework permanent.

Prepared by

689

Limited licensed providers

1,856

Fully licensed providers & practice owners

224

Clients

2,769

Total respondents

“This could literally mean someone’s life or death. I don’t mean that dramatically. I mean that seriously.”

Client respondent

Implementation timeline

Now

Current framework still in place. Data collection remains open and responses are still being counted.

Phase 1 · September 1, 2026

Incident-to claims must carry the SA modifier. {{ daysToPhase1 }} days away.

Phase 2 · March 1, 2027

Limited licensed clinicians lose incident-to eligibility in professional practice settings, and 68% of surveyed limited licensed clinicians do not anticipate holding full licensure by then. {{ daysToPhase2 }} days away.

What we are asking

We are not requesting a delay or further study. We are asking Blue Cross Blue Shield of Michigan to keep the current framework as the permanent policy for limited licensed clinicians in professional settings.

Making the current system permanent has a neutral impact on BCBSM. Increasing the number of participating providers would help Michiganders. This policy change does the opposite. The findings below document what that would cost.

A two-lane highway receding through northern Michigan pine forest under flat overcast light

Two clinicians reviewing case notes together at a table

What the policy actually changes

A limited licensed clinician’s work is billed under their supervisor’s license.

That is what incident-to billing means. A limited licensed counselor, social worker or psychologist sees the client. A fully licensed supervisor directs and reviews the clinical work, and the claim goes out under the supervisor’s credential. It is a primary pathway through which Michigan clinicians complete the supervised hours the state requires for full licensure.

BCBSM is closing that pathway: first by requiring an SA modifier from September 1, 2026, then by ending incident-to billing for limited licensed clinicians on March 1, 2027. The supervision does not change. Only who can be paid for it.

Licensed. Supervised. Serving Michigan.

Why the alternative pathway does not work

In Why We Are Updating Our Incident-to Policy (May 31, 2026), BCBSM states that limited licensed providers “must submit claims in facility-based settings such as hospitals, outpatient psychiatric centers and community health centers,” and that “private practice owners can apply for their practice to be qualified as an outpatient psychiatric center.” Both halves of that pathway break down: the first for the client, the second for the practice.

Figure A

The clinician can move. The client cannot.

Today

Client

Private practice

Limited licensed clinician

Supervised by a fully licensed clinician

Care continues

From March 1, 2027

Client

Private practice

Reimbursement ends

The clinical relationship ends here

Clinician moves to a facility-based setting

Hospital, outpatient psychiatric center or community health center, if one has a funded supervised position

The client does not follow

Nothing in BCBSM’s pathway transfers an existing client to the new setting. The clinician’s hours can continue. The relationship cannot.

Figure B

The pathway Michigan law does not allow

What the pathway asks

Private practice owned by a licensed counselor

Apply to qualify as an outpatient psychiatric center

Bring in a physician to direct clinical care

Required of an OPC facility by BCBSM’s own standards. See note below.

Reimbursement continues

What Michigan law permits

Private practice owned by a licensed counselor

A physician cannot provide medical services through the practice as an ordinary employee

Every shareholder must hold the same license as the service the entity provides

“Each shareholder of the professional corporation must be licensed or legally authorized in this state to provide the same professional service.” MCL 450.1284(1).

The counselor would have to give up ownership of the practice they built

Not reduce it. A professional corporation providing medical services has no room for a shareholder who is not licensed to provide that service.

No qualification. No reimbursement.

Legal position · verbally confirmed, written confirmation pending

The ownership bar is sourced to Michigan’s Business Corporation Act, MCL 450.1284(1). Michigan health care counsel has reviewed this reading and confirmed it verbally; written confirmation has been requested and will be cited here when it arrives. The requirement for a physician, shown dashed above, comes from a different document and is now sourced. BCBSM’s Clinical program requirements for behavioral health outpatient psychiatric care facility, revised March 13, 2026, requires a participating OPC to maintain “a multidisciplinary staff … which must include: a board-certified or board-eligible psychiatrist,” a fully licensed or limited licensed psychologist, and a licensed master’s social worker, with “regularly scheduled hours in the facility, and availability for emergency consultation within two hours.” The incident-to policy itself does not tell anyone to hire a psychiatrist; it points to facility-based settings, and the staffing requirement lives in the OPC standards. Those standards also require accreditation, a comprehensive service range, 24-hour emergency cover and separate facility approval, so adding a psychiatrist alone does not make a practice an OPC. The same rule appears in both statutes: MCL 450.1284(1) for professional corporations and MCL 450.4904(2) for professional limited liability companies, so the position does not turn on which form the practice takes. Michigan does allow some mixed-license professional entities, but the exception at MCL 450.4904(3) and (4) reaches only chiropractic, medicine, osteopathic medicine, podiatric medicine and physician’s assistants. Counseling is not among them.

Map of Michigan's 83 counties. 24 are shaded to show they reported zero psychiatrist full-time equivalents: Oscoda, Osceola, Ogemaw, Montmorency, Baraga, Kalkaska, Lake, Schoolcraft, Missaukee, Mackinac, Ontonagon, Iron, Luce, Montcalm, Oceana, Newaygo, Hillsdale, Presque Isle, Menominee, Alger, Antrim, Keweenaw, Mason and Barry.

70.1%

of Upper Peninsula primary care physicians reported there was no psychiatrist to whom they could readily refer patients.

Bernson J, Hedderich P, Wendling AL. Examining access to psychiatric care in Michigan’s Upper Peninsula. PRiMER, 2021;5:44.

“The path to compliance in Montmorency County is: hire a psychiatrist. The county has zero.”
MMHCA policy brief
Montmorency County reported 0 psychiatrist FTE. Michigan Department of Health and Human Services, Michigan 2020 Primary Care Needs Assessment, Montmorency County data profile. Provider data: Michigan Shortage Designation Management System, February 2020.

For clinicians and practice owners

BCBSM will weigh caseload numbers, not sentiment.

Every letter below has a line for yours. Fill it in before you send.

A clinician at a desk in a private-practice office, reading paperwork

Friday, August 21 · noon to 2:00pm

Rally at BCBSM headquarters in Detroit

600 East Lafayette Boulevard, in front of the building. The report gave BCBSM the numbers. The rally gives them the faces. Press covered the Lansing rally because a visible number of counselors physically turned up, and that is the whole mechanism here.

The rally

Friday, August 21, noon to 2:00pm.
BCBSM headquarters, 600 East Lafayette Boulevard, Detroit.

The bus, leaving Lansing

Park at the Trailways Training Center, 4600 Aurelius Road, Lansing, MI 48910.
Loading begins 9:30am. The bus departs at 10:00am.

Coming home

The bus leaves Detroit at 2:15pm and returns to the Lansing lot.

What a seat costs

MMHCA is subsidizing part of the cost. Members ride for $10 through 6:00pm on Friday, August 7. From that point the fare is $20 and the bus opens to everyone.

A subsidized seat is one of the things membership pays for. Membership starts at $65 a year.

Join MMHCA

Members, the link to reserve a seat is in the MMHCA email that went out this week. Booking opens to everyone on Friday evening.

Driving yourself is fine, and the bus is only for people who would rather not make the trip alone. Questions about either go to mmhcaboard@mmhcanow.org.

What you can do

Each one takes about two minutes and puts a specific number in front of the people deciding this.

If you are a clinician

Send BCBSM your caseload number

A letter carrying your own weekly client count. Fill in one line, copy it, send it.

If you own a practice

Write your state representative

The report asks for legislative review. Look up your legislators and write to them.

If you are a client

Add your story

Data collection is still open. Client responses carry particular weight with policymakers.

Five headline findings

Thousands of clients face immediate disruption

Respondents represent more than 5,700 BCBSM clients seen weekly by limited licensed providers. Over 1,000 of those clients are in active crisis stabilization or safety planning. Responding practice owners report fully licensed staff could absorb about 1,900 of an estimated 10,400 weekly LL-served BCBSM clients. The gap is thousands of clients with no identified provider.

73% of clients would go without care

Asked what they would do if their provider could no longer bill their insurance, 73% of client respondents said they would go without mental health care, either because they cannot afford out-of-pocket costs or because they do not expect to find another provider quickly. Only 3 of 224 said they could afford out-of-pocket care without financial difficulty.

The workforce pipeline faces structural disruption

68% of limited licensed providers do not anticipate full licensure by March 1, 2027. Among supervisors, 92% reported the policy will make it harder for LLs to earn required hours and will reduce the employment options licensure depends on. 41% of practice owners have already paused hiring limited licensed clinicians.

Private practices cannot absorb the displaced clients

89% of fully licensed providers are already at or near full caseload capacity. Responding practices could absorb roughly one-fifth of the BCBSM clients currently served by limited licensed clinicians. Only 14% of practice owners said they could adapt without downsizing. 34% anticipate significant downsizing and 8% said their practice would likely close or sell entirely.

The impact is likely understated

The surveys reached current LARA licensees only, not the incoming cohort of recent graduates now applying for limited licenses. That cohort, several thousand people (more than 2,500 new limited licensed counselors were licensed last year), will spend virtually its entire limited license period under this policy. Faculty at one Michigan graduate program report students considering leaving the state rather than begin supervised practice here.

“The only way to get fully licensed is through seeing clients. This change would effectively bottleneck and kill the mental health profession in Michigan.”

Limited licensed provider

Figure 1

The two-track impact

The findings document two simultaneous and reinforcing pathways through which this policy is likely to reduce behavioral health access in Michigan: one immediate, one structural and long-term.

Track 1 Immediate access loss

5,762

BCBSM clients seen weekly by responding limited licensed providers, 1,035 of them in crisis stabilization or safety planning

89%

of fully licensed providers are already at or near full caseload capacity

1 in 5

the share of LL-served BCBSM clients that responding practices estimate fully licensed staff could absorb

Result

Thousands of clients with no identified provider, in a system where 54% already waited more than a month to find one.

Track 2 Structural pipeline disruption

68%

of limited licensed providers do not expect full licensure by March 1, 2027

41% / 45%

of practice owners have already paused hiring LLs / plan to employ fewer if the policy takes effect

22% / 16%

of limited licensed respondents are considering leaving the field / leaving Michigan

Result

Fewer supervised hours and fewer employers, which means fewer fully licensed clinicians in later years. The incoming cohort begins under this policy on its first day of practice.

Both tracks were reported independently by three separate respondent populations. Neither depends on the other to occur.

A counseling waiting room with every seat taken and several people standing — Illustrative. Responding practices estimate they could absorb roughly one-fifth of the clients this policy would displace. Existing waits are documented in Section 1, from the client survey.

In their own words

From 4,634 open-ended responses across three surveys. Reproduced verbatim, de-identified. Three themes dominate: the irreplaceability of an established therapeutic relationship, the severity of existing access barriers, and the direct line between losing care and crisis-level risk.

4,634

open-ended responses across 13 question sets, coded to five themes. Quotations on this page are reproduced verbatim.

“My son suffers from OCD. We have been through three therapists before we found the one we have now. This woman has been life-changing for my son. We went from a child who couldn’t leave my side to one who is having playdates and riding roller coasters. He trusts this woman like family. And now because she doesn’t have the right letters after her name, my insurer won’t cover her?”

Client, parent

“My highschooler has significant depression and, prior to working with the LLPC, suicidal ideation. The counselor helped to a point where SI hasn’t been an issue in 16 months.”

Client, parent

“Our child would end up in hospital.”

Client, answering on behalf of a child

“It already took me months to find my current provider. There is only one therapy place in my town that takes my insurance. The idea that I would have to start over is devastating.”

Client

“We are a child and adolescent clinic so this will impact hundreds of children in Oakland County. Many families cannot afford self-pay services.”

Practice owner, Oakland County

Two clinicians working side by side at a desk — Limited licensed provider

“I have $160,000 in student loan debt and your policy is what greets me on the other side of eight years of school.”

Limited licensed provider

The findings in detail

Although the smallest of the three surveys, client responses carry particular weight for policymakers: they come from people with no professional or financial stake in the outcome, describing their own experience of getting care. 150 respondents were the client themselves; 38 answered on behalf of a client, such as a child. 87% are currently receiving services and 84% carry BCBSM or BCN commercial insurance.

87%

Currently receiving mental health services

84%

Have BCBSM or BCN insurance

47%

Currently seeing a limited licensed provider

Median age of person receiving services

Where client respondents live

Well over half of responding clients are outside a mid-size or large city. Those are the communities where a lost provider is hardest to replace.

Small town or suburb91 · 44%

Mid-size city61 · 29%

Rural community30 · 14%

Large city or metro area27 · 13%

Barriers that exist before this policy takes effect

Client respondents describe a system that is already hard to navigate. The proposed policy would further restrict a workforce that is already insufficient to meet demand.

Waited more than one month to find a provider54%

Have been unable to get care because of insurance42%

Say paying out of pocket would be difficult or impossible98%

n=205. Three respondents of 224 said they could afford out-of-pocket care easily.

Figure 3. If your provider could no longer bill your insurance, what would you do?

n=208. Combined, 73% said they would go without mental health care.

Go without care, cannot afford out-of-pocket costs46%

Go without care, no other provider expected quickly27%

Could afford out-of-pocket care without financial difficulty1.4%

“I began seeing my therapist when she held a limited license. My work with her over the last decade significantly changed my life for the better — I was able to graduate from university, go to graduate school, and develop healthy relationships.”

Client

LLPC, LLMSW, LLMFT and tLLP clinicians working in private practice or school-based settings. Their billing status sits at the center of the proposed change.

Licensure timeline

A foundational question is how many limited licensed providers will have reached full licensure before March 1, 2027. Findings suggest most will not (n=677).

68%

Do not anticipate full licensure by March 2027

74%

Believe the policy will delay their path to licensure

94%

Said yes or uncertain about licensure delay

The licensure path

Michigan requires a minimum of two years of supervised practice under a limited license before full licensure. Client work is the only way to accrue those hours.

Step 1

Master’s degree & internships

Step 2 · March 1, 2027

Limited license, two years minimum of supervised practice

Step 3

Required hours, supervision & exam

Step 4

Full licensure: LPC, LMSW, LP, LMFT

On March 1, 2027 incident-to billing ends at step 2 in professional practice settings. 68% of limited licensed respondents expect to still hold a limited license on that date.

The clients they serve

5,762

BCBSM clients seen weekly (n=564)

3,177

With serious or complex diagnoses (n=556)

1,035

In crisis stabilization or safety planning (n=540)

55%

Median share of clinical income from BCBSM

For most respondents this is not a billing adjustment. It is the potential elimination of more than half their professional income. 74% carry graduate school debt; among those who shared an amount (n=74) the mean was $68,242 and the median $60,000.

Figure 7. Anticipated immediate consequences

n=581, multiple-select. High rates across nearly every category suggest respondents anticipate cascading effects rather than one isolated disruption.

Financial strain88%

Disruption to existing clients87%

Delay to licensure path76%

Employment disruption54%

Considering leaving the mental health field entirely22%

Considering leaving Michigan16%

Figure C · The affected population renews every year

689

limited licensed clinicians counted in this survey

2,500+

newly licensed last year, counted nowhere in it

Each square ≈ 100 clinicians. Michigan requires a minimum of two years under a limited license, so a cohort this size would spend virtually its entire limited licensure period under the proposed policy, and another cohort arrives behind it the following year. Prior-year licensure count, not a projection.

A population not yet counted

These 689 respondents are current LARA limited licensees only. Because Michigan requires a minimum of two years under a limited license, the active limited licensed population turns over roughly every two to three years. A new cohort is entering the process now and appears nowhere in these figures; more than 2,500 new limited licensed counselors were licensed last year. They would spend virtually their entire limited license period under this policy. The figures in this report are best read as a conservative lower boundary.

“As a limited license clinician, I have already graduated with a Master’s degree and completed two internships. Being a limited license clinician does not make someone less qualified or capable.”

Limited licensed provider

LPC, LMSW, LLP, LP and LMFT clinicians across Michigan; 291 identified as practice owners or administrators and completed an extended section on practice-level impact. The average respondent has been licensed 15 years (median 13).

The absorption problem

≈1,900

absorbed by existing fully licensed staff

n = 227

The remainder

with no identified provider

Each square ≈ 100 weekly clients · 10,400 weekly BCBSM clients seen by limited licensed providers at responding practices

Because the two figures come from different valid Ns, the gap is best expressed as a ratio: responding practice owners estimated their fully licensed staff could absorb roughly one-fifth of the BCBSM clients currently served by limited licensed clinicians.

89%

Already at or near full caseload capacity (n=1,749)

4.6

Average additional clients a licensed provider could absorb

1,659

LLs supervised to full licensure by responding practices in five years (n=266)

The workforce pipeline

Among the 491 fully licensed providers who currently supervise LLs for BCBSM incident-to billing, the assessment was near-unanimous.

Pipeline impactRespondents (n=491)

Will make it more difficult for LLs to get required hours454 · 92%

Will reduce employment options for LLs to reach full licensure455 · 93%

Will slow the number of people becoming fully licensed408 · 83%

No impact7 · 1%

92% of fully licensed respondents stated that private practice adequately prepares limited licensed clinicians for full licensure. That judgment comes from the supervisors responsible for the training, and it challenges the premise that facility-based supervision is preferable.

Practice sustainability

41%

Have already paused hiring limited licensed clinicians

45%

Plan to employ fewer LLs if the policy takes effect

239

Non-clinical staff positions potentially at risk

1 in 3

Dollars of practice revenue that come from BCBSM incident-to billing, on average

Only 14% of responding practice owners said they could adapt without downsizing (n=286). A further 29% anticipate some downsizing, 34% anticipate significant downsizing, 15% said it was too early to tell, and 8% said they would likely close or sell entirely. Revenue exposure, hiring pauses already in place, and near-full capacity across the licensed workforce create conditions in which the policy’s effects cannot be absorbed. They will be passed on to clients.

“We already serve communities where access to mental health care is limited. Without the LLMSWs, there are certainly communities that will go without.”

Practice owner, rural Michigan

Open-ended responses across 13 question sets were coded using a five-theme framework. Themes are not mutually exclusive. The near-even distribution is itself a finding: respondents did not cluster around a single concern. The policy is experienced as simultaneously threatening clients, clinicians, practices, the pipeline, and the professional standing of limited licensed clinicians.

1 · Access & continuity of the therapeutic relationship1,822+

2 · Workforce pipeline1,637+

3 · Practice sustainability1,620+

4 · Qualifications & supervision1,582+

5 · Messages to decision-makers1,456+

The most consistent argument in provider responses: the “limited” in limited license reflects a stage of career development under supervision, not a level of competence. Many respondents note that supervision in private practice is more rigorous than what facility settings offer.

“If client access to outpatient mental health services is limited, mental health care will likely lead to reactive care instead of preventative care. I expect IOP, PHP, urgent care, ER, and hospital admission rates will likely rise — which will cost BCBS substantially more money than covering preventative outpatient care provided by limited licensed clinicians.”

Fully licensed provider

1 · Convergence across three independent populations

Three surveys completed independently by people with different roles and different stakes produced the same five themes in consistent proportions. This is not one group advocating for its own interests. It is three populations describing the same problem from three vantage points: a policy intended to improve quality of care would instead reduce access to it, at a time when the access crisis is already severe.

2 · The therapeutic relationship as a clinical asset

Clients describe the bond with a particular provider as clinically essential, consistent with the research literature on therapeutic alliance as a predictor of outcomes. Disrupting these relationships is not experienced as a billing adjustment. It is experienced as a clinical event.

3 · The rural amplification effect

In metropolitan areas a disrupted client may eventually find another provider, though waits will grow. In rural Michigan there is often no alternative at all: no facility-based option, no reliable telehealth connection, no other provider accepting their insurance within a reasonable distance.

4 · Children and adolescents

Child therapy is already scarcer than adult therapy and wait times are longer. Children’s progress is particularly sensitive to disrupted relationships. Several responses describe children and adolescents with active suicidal ideation or self-harm history whose therapeutic relationships are now at risk.

“For a child, therapy only works when there is trust — and building that trust with a therapist takes time, consistency, and safety. Abruptly removing that trusted adult from a child’s life isn’t just a disruption to treatment. It can be its own trauma.”

Limited licensed provider

5 · The downstream cost argument

Providers and clients independently, and without prompting, raised the argument that reducing access to outpatient preventive care increases use of more expensive services: emergency departments, inpatient psychiatric facilities, and medical care for conditions driven by untreated mental health needs. Michigan already has a documented shortage of inpatient psychiatric capacity. No survey question prompted this argument; its spontaneous appearance across hundreds of responses in all three surveys is itself a finding.

The findings document that, as written, this policy will cause serious and lasting harm to both the providers and the clients it is intended to serve. We are asking BCBSM to work with us toward a path that achieves its stated quality-of-care goals without those consequences. Specifically:

A stakeholder meeting with BCBSM provider relations leadership to review these findings and discuss alternatives that protect access to care.
A delay in implementation of the March 1, 2027 requirements pending resolution of the credentialing pathway question and review of the workforce impact documented here.
A direct credentialing pathway for limited licensed providers to participate with BCBSM commercial plans, consistent with their state licensure and supervised status.
Legislative review of the policy’s impact on Michigan’s behavioral health workforce pipeline, particularly rural access and the development of future fully licensed clinicians.

Our position

This policy, as currently written, eliminates or severely restricts the ability of thousands of licensed clinicians to serve BCBSM commercial members in private practice settings. It does so when Michigan’s behavioral health workforce is already insufficient to meet demand, when thousands of existing clients have no readily available alternative provider, and when the incoming generation of early-career clinicians is deciding whether Michigan is a viable place to build a career.

The same findings that document the harm also point to the solution: a direct credentialing pathway for limited licensed providers, combined with a delay sufficient to establish it. We are ready to engage in that conversation.

Section 6, item 4

The report asks for legislative review of this policy’s effect on Michigan’s behavioral health workforce.

That review begins with letters from constituents. Two are written below, ready to send.

Write to BCBSM and to your legislators

BCBSM and legislative offices count letters. One that carries a specific caseload number is evidence.

Template 1 · For clinicians

Letter to BCBSM provider relations

Your weekly BCBSM caseload Your name and credential

Subject: Incident-to policy change and my BCBSM clients

Dear BCBSM Provider Relations,

I am a behavioral health clinician practicing in Michigan. I am writing about the commercial incident-to billing policy changes taking effect September 1, 2026 and March 1, 2027.

I currently see {{ caseloadDisplay }} BCBSM clients each week. If limited licensed clinicians can no longer bill incident-to in professional practice settings, those clients lose continuity of care. In a statewide survey of 2,769 providers and clients, 89% of responding fully licensed providers reported they are already at or near full caseload capacity, and responding practices estimated they could absorb only about one-fifth of the BCBSM clients currently served by limited licensed clinicians. There is no available capacity to receive the clients this policy would displace.

I am asking BCBSM to keep the current framework as the permanent policy for limited licensed clinicians in professional settings, and to establish a direct credentialing pathway for those clinicians. Making the current system permanent has a neutral impact on BCBSM. This change does not.

I would welcome the opportunity to discuss this with your team, and I am willing to provide further detail about my caseload and my clients’ circumstances.

Sincerely,
{{ signatureDisplay }}

Send to your BCBSM provider relations representative and copy MMHCABoard@MMHCAnow.org so the coalition can count it.

Template 2 · For everyone

Letter to your state representative or senator

Find your state representative → Find your state senator →

Subject: BCBSM incident-to policy and behavioral health access in our district

Dear Representative / Senator,

I am a constituent writing about a change to Blue Cross Blue Shield of Michigan’s commercial incident-to billing policy that will restrict which behavioral health clinicians can serve BCBSM members. Beginning March 1, 2027, limited licensed clinicians, who hold a Michigan license and practice under supervision while completing the hours required for full licensure, will no longer be eligible for incident-to reimbursement in private practice settings.

A statewide survey of 2,769 Michigan clinicians and clients found that 73% of client respondents would go without mental health care if their provider could no longer bill their insurance, that 89% of fully licensed providers are already at or near full caseload capacity, and that 68% of limited licensed clinicians do not expect to reach full licensure before the deadline. In rural districts there is frequently no alternative provider at all.

I am asking you to request a legislative review of this policy’s impact on Michigan’s behavioral health workforce pipeline and on access to care in our district, and to urge BCBSM to keep the current framework in place while a direct credentialing pathway is established.

The full impact assessment is published by the Michigan Mental Health Counselors Association, the National Association of Social Workers, Michigan Chapter, and the Michigan Psychological Association. I am glad to share it, or to talk about what this means for the people I see.

Thank you for your attention,

Data collection is open

Add your story

Data collection remains open. Clients, clinicians, and practice owners can still be counted, and new accounts keep this record current as the situation develops.

Share your story

Takes about three minutes. No account or sign-in needed. If you would rather write to us directly, the address is MMHCABoard@MMHCAnow.org.

What we ask for

Whether you are a client, a limited licensed clinician, a fully licensed clinician, or a practice owner

Your county. Rural responses carry particular weight

What this policy would mean for you or for the people you see

Whether we may quote you anonymously

An email address, only if you are willing to be contacted

Stories are held in confidence. Nothing is published with a name attached, and nothing clinical is ever reproduced without permission.

Data collection remains open

The three surveys are still accepting responses

These are the instruments behind every finding on this page. If you have not responded yet, your answers are added to the record and counted in the next update. Responses are anonymous and take about ten minutes.

Survey 1 · 689 respondents so far

Limited licensed clinicians

LLPC, LLMSW, LLMFT and tLLP clinicians

Take the survey →

Survey 2 · 1,856 respondents so far

Fully licensed clinicians & practice owners

LPC, LMSW, LLP, LP and LMFT clinicians, and practice owners

Take the survey →

Survey 3 · 224 respondents so far

Clients

People receiving behavioral health care with BCBSM coverage

Take the survey →

A joint communication · July 2026

This report went out to Michigan behavioral health professionals as a joint communication from MMHCA, NASW-Michigan, the Michigan Psychological Association and AAMFT. Almost 3,000 people have now responded to the coalition’s surveys, and data collection remains open.

Download and share

The full report is the citable version. The one-page summary is sized for a legislative office. The handout is written for clients.

PDF · 19 pages

Full impact assessment

The citable archival version, with all figures, tables, and the appendix on survey administration.

PDF · 1 page

One-page summary

The counts, the five findings and the ask, sized for a legislative office or a board meeting.

PDF · 1 page

Client-facing handout

Plain-language explanation of what changes, what it means for your care, and how to be counted. For waiting rooms and portals.

Prefer to read without downloading? The one-page summary and the client handout are also available as web pages you can share by link.

Methodology

Three surveys were developed and distributed jointly by MMHCA, NASW-MI, MPA and AAMFT from June 17 to June 30, 2026 on Google Forms. Data collection remains technically open, though response volume has slowed substantially.

Primary distribution was by email invitation to approximately 48,000 behavioral health professionals using publicly available LARA licensure information, and was endorsed by MMHCA, NASW-MI, MPA, the Michigan Association for Marriage and Family Therapy, and closed professional social media groups. The client survey was distributed primarily through behavioral health providers.

Because participation was voluntary, findings reflect the experiences and expectations of those who chose to respond and may not represent the full population. The consistency of findings across three independent surveys of three different populations strengthens confidence in the direction and magnitude of the patterns documented. All statistics are reported with valid N counts. Analysis was conducted by MMHCA and reviewed internally by NASW-MI and MPA. All responses are anonymous; aggregate data only is reported.

Survey populationRespondents

1 · Limited licensed professionals (LLPC, LLMSW, LLMFT, tLLP)689

2 · Fully licensed professionals & practice owners1,856

3 · Behavioral health clients224

Total2,769

All findings are respondent-reported experiences and expectations. Language throughout uses “respondents reported” and “findings suggest” rather than causal claims. Open-ended responses are reproduced verbatim, fully de-identified, with minor edits for clarity only where noted.

Distribution was statewide across all 83 counties, by email to approximately 48,000 licensed professionals and through four association membership lists.

Membership funded this work

2,769 responses in thirteen days.

MMHCA built and fielded the survey, coded 4,634 open-ended responses, and took the findings to BCBSM with NASW-MI and MPA. Membership is what paid for it.

Members hear first, including whatever BCBSM says next

Regular policy updates as this develops, sent to members directly

Ongoing member support on private practice and billing questions

Join MMHCA

Updates on this policy go to members. If you are already a member you are on the list. Nothing further to do.

Prepared by