~a monthly public policy newsletter from the Mental Health Association in Michigan (MHAM)~
Vol. 1, No. 4 April 2018
New & Dangerous Concept Proposed for Section 298 Situation
On April 17, the Senate DHHS Appropriations Subcommittee reported a budget bill for Fiscal Year-19. The bill had new section 298 language that is very troubling.
Contrary to what Michigan DHHS has been saying for months, the new language would allow Medicaid Health Plans (MHPs) in pilot communities (see our last issue) to contract with any providers they wish, and to control all utilization management functions for MHP enrollees – including those deemed to need specialty behavioral health service.
Michigan DHHS has said numerous times publicly that Medicaid specialty behavioral health service must run through CMHSPs to be legal, and that MHPs in pilot communities must contract with CMHSPs for that service. In November 2017, the department wrote, “Absent changes to the (Michigan) Mental Health Code, the CMHSP is the specialty provider and must be involved in the provision and management of services…”
In addition to the questionable legality of the new language, there are several other problems with it:
*The coming pilot programs are supposed to be MHP-CMH partnerships. In fact, the department required local proposals of interest to be submitted officially by CMHSPs. The language in the Senate Subcommittee’s section 298(2)(e) is not the language of a partnership, but instead lays out total domination by MHPs.
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