In March 2023, the MDHHS Conflict-Free Access and Planning (CFAP) Workgroup met to review a number of CFAP options proposed by MDHHS to ensure compliance with the federal CFAP requirements. These options raised a number of concerns for the members of the Community Mental Health Association of Michigan (CMHA) – specifically involving the threat these options hold for persons served and to the integrity of Michigan’s public mental health system.

These concerns and recommendations for action, developed by CMHA and its members, are outlined in a document sent to and reviewed with the MDHHS staff leading this effort.

As a result of the CMHA discussions with MDHHS, MDHHS held several listening sessions designed to obtain the views of persons served by Michigan’s public mental health system. Many of the participants in these listening sessions voiced deep concerns over the fragmentation of the system and the increased complexity and access barriers that would result from the MDHHS-proposed approach to meeting CFAP compliance.

Advocacy by CMHA and its members, including legislative advocacy, has been increased over the last few weeks, fueled by the latest announcement by MDHHS relative to its plans to implement the Department’s approach to CFAP.

We fully support the intent to limit conflicts, however we believe the proposed “solution” outlined by MDHHS causes unnecessary disruption and complexity and creates a greater threat than the conflicts they are attempting to prevent.

REQUEST FOR ACTION: We are asking you to reach out to your legislators (House & Senate) and the Governor and URGE them to push MDHHS to halt the implementation of its approach to meeting the federal Conflict-Free Access and Planning (CFA&P) requirements related to Medicaid mental health services. Additionally, we would like them to encourage MDHHS to seek an alternative approach with CMS (Centers for Medicare & Medicaid Services) to comply with federal regulations before making a final decision and push to include the boilerplate language in the FY25 (as well as FY24 supplemental budget) MDHHS budget.