Feel free to change any and all of this as you wish. Text in red contains instructions and text in green points to consider as you draft what you want to say. 

You will notice that the letter begins by ensuring the person taking your phone call or reading your letter understands that you know about the governor. 

Next, I thank the governor for taking action on a specific issue that protected Michigan’s citizens. 

I then ask them to take action to help BCBSM choose a different strategy with their PPO mental health providers to support their constituents in Michigan. 

Feel free to edit, but keep that format. It is helpful.

Good luck! Sincerely, Dr. Burns

Your name, your credentials
Your address
Your phone
Your email

X/XX/26

Dear Governor Whitmer:

Thank you so very much for protecting the citizens of Michigan as Governor. I appreciate that you have worked tirelessly to raise the minimum wage to $15 per hour by January 2027, establish the Earned Sick Time Act requiring paid leave for workers, advocate for capping medical debt interest rates at 3%, and prevent wage garnishment for unpaid medical bills. 

As your constituent, a Licensed Professional Counselor (LPC), and a Counselor Educator responsible for preparing Michigan's future mental health workforce, I hope you will also agree to protect Michigan’s citizens by intervening to stop BCBSM’s proposed PPO changes to incident-to billing in private practice settings.
If this policy is implemented, it will severely damage the educational pipeline that prepares Michigan's future licensed mental health professionals. The consequences will extend far beyond universities—they will affect every Michigan resident seeking mental health care.
As Counselor Educators, we are responsible for training competent, ethical, and highly qualified counselors who are prepared to serve individuals, couples, families, veterans, children, and communities across our state. However, our students cannot become licensed professionals without completing supervised practicum and internship experiences during graduate school, followed by supervised postgraduate clinical experience.
Private practices currently provide many of these essential training opportunities. They have become indispensable partners in counselor education by offering students and graduates the supervised clinical experiences required by accreditation standards and Michigan licensure requirements.
BCBSM's proposed policy threatens to dismantle this system.
By refusing to reimburse services provided through incident-to billing in private practice settings, BCBSM will make it financially impossible for many private practices to continue accepting practicum students, interns, and graduates working toward independent licensure. Practices simply cannot absorb the financial loss associated with supervising clinicians whose services can no longer be reimbursed.
The result will be immediate and devastating.
Graduate students will struggle to secure practicum and internship placements required for graduation. Many may experience delayed graduation because they cannot obtain the clinical hours necessary to complete their degree programs.
Graduates working toward independent licensure will have dramatically fewer employment opportunities. Thousands of Limited Licensed Professional Counselors, Limited Licensed Master Social Workers, Limited Licensed Marriage and Family Therapists, and Limited Licensed Psychologists may find themselves unable to obtain positions that allow them to complete their supervised clinical hours.
Without supervised employment opportunities, these graduates cannot become independently licensed clinicians.
This is not simply an employment issue—it is a workforce development crisis.
Michigan already faces significant shortages of mental health professionals, particularly in rural and underserved communities. At a time when demand for behavioral health services continues to rise, BCBSM is proposing a policy that will reduce—not increase—the number of professionals entering the workforce.
Most importantly, BCBSM's stated rationale for this policy does not justify the harm it will cause. Other Blue Cross organizations have already demonstrated that there are better solutions. BCBSM has options that protect quality without dismantling Michigan's behavioral health workforce.
As a Counselor Educator, I worry deeply about what this policy means for the future of our profession. We ask students to invest years of graduate education, tens of thousands of dollars in tuition, and countless hours developing the skills needed to serve Michigan residents. They do so with the expectation that supervised training opportunities and entry-level employment will exist after graduation.
This policy jeopardizes that promise.
It discourages talented students from entering the profession, limits educational opportunities, reduces employment options for new graduates, and ultimately decreases the number of independently licensed mental health professionals available to serve Michigan families.
The individuals who will suffer most are the patients.
Longer waitlists, reduced provider availability, fewer rural mental health services, and fewer future clinicians are the predictable outcomes of this policy.
I respectfully ask you to intervene on behalf of Michigan's universities, students, future mental health professionals, and the millions of Michigan residents who depend upon timely access to behavioral health care.
Please urge BCBSM to suspend implementation of this policy and work collaboratively with counselor educators, professional associations, universities, supervisors, private practice owners, and state licensing boards to develop a solution that protects patients without destroying Michigan's mental health workforce pipeline.
Michigan cannot afford to reduce access to care or discourage the next generation of mental health professionals. I urge you to help protect both.
Suddenly, in early June of 2026, BCBSM announced that it would no longer cover services for its PPO plan when treatment is provided by counselors, social workers, marriage and family therapists, and psychologists who are working towards independent licensure through something called incident-to billing in private practice settings. 

1. BCBSM claims this change is “to strengthen their ability to identify rendering providers.”
Currently, BCBSM is choosing not to allow interns and limited-licensed mental health practitioners to be paneled directly through its PPO plan. However, all interns and limited-licensed mental health practitioners can apply for an NPI number. If BCBSM allowed these individuals to be directly paneled with them, then BCBSM would know exactly who was directly providing mental health treatment to the client. 

2. BCBSM claims that they want to “improve oversight of quality of care.” However, BCBSM does not determine how any of those professions supervise their members working towards their independent licensure. Ethical codes for each of those professions set guidelines, as do Michigan state law rules and codes for all of those professions. For example, even if BCBSM makes this change, all supervision requirements for a Limited Licensed Professional Counselor remain exactly the same whether the supervisee works in a hospital or a private practice setting. 

3. BCBSM claims that they want to “ensure reimbursement is appropriately aligned with provider licensure and participation status with Blue Cross PPO and BCN.” BCBSM is now saying it is making its PPO plan equivalent to its HMO plan. What this comes down to is BCBSM doesn’t want to pay the supervisor, who has legal and ethical responsibilities for the patient the supervisee is treating, and who is also furthering the supervisee’s training through extensive consultation with the supervisee.

BCBSM wants to make it harder for patients on the PPO plans to get a mental health counseling appointment. This will result in far fewer places where PPO plan members can get mental health treatment, which will increase wait times for treatment, and people will have to travel farther to receive it. 

BCBSM flippantly states that a private practice can convert to an Outpatient Psychiatric Care Facility (OPCF) if it wants to bill for interns and graduates working toward independent licensure. However, BCBSM requires an OPCF to have a board-certified or board-eligible psychiatrist on staff. However, Michigan is currently 880 psychiatrists short, according to the National Center for Health Workforce Analysis (NCHWA). Most of our mental health private practices, like mine, have just a couple of providers, and it’s not feasible for them or me to hire new staff from so many different professions. Further, those facilities must have emergency services available 24 hours a day. That’s just not financially feasible for any private practice owner. 

Additionally, BCBSM flippantly states that all interns and individuals who have graduated and are working toward independent licensure can simply go to work at a hospital, an OPCF, or an MDHHS community mental health facility. In talking with MDHHS, they can’t accommodate all of these people. So again, this is also impossible.

But let’s look at how many limited licensed providers we currently have in Michigan. 
7,296 Social Workers
2,471 Counselors
   489 Psychologists
   144 Marriage and Family Therapists
10,400 Total

That’s not even talking about the folks doing practicums and internships within their graduate programs. And while some of those folks work in hospitals or in OPCF and MDHHS community mental health facilities, the majority do not. 

What’s really troubling here is that there are several ways BCBSM PPO could solve the “problem” they themselves created without reducing the number of mental health treatment providers. I’m just going to list a couple.

First, as I’ve mentioned, interns and limited licensed mental health practitioners can apply for an NPI number. And if BCBSM would allow them to be paneled directly with them, they could bill directly, and BCBSM would know exactly who is providing mental health treatment to the client. However, if BCBSM takes this route, they’ll pay the limited-licensed provider much less for seeing a client, and then they’ll force supervisors to charge supervisees for supervision directly. The supervisee is getting less money, and they’ll have to pay out of pocket for their own supervision. It’ll be a difficult hardship for the supervisee.

Second, Blue Cross Blue Shield of Illinois (BCBSI) is taking a very different track. They are recognizing the current and upcoming shortage of mental health treatment providers. They’re allowing covered services rendered by the supervisee to be billed under the supervising licensed clinician’s NPI (National Provider Identifier). BCBSI requires that the supervisor be available to the supervisee 100% of the time, enabling the supervisor to provide direction and intervene in the event of an emergency. Supervisors may supervise up to 4 trainees at a time, and the supervisee must receive the required minimum individual safe face-to-face supervision in compliance with Illinois state licensure requirements specific to the trainee’s level of licensure. So BCBSI is deferring, as they should, to Illinois state law for those professions, and they stipulate that supervisors and supervisees should work within the same organization or system. BCBSI also has a rule that the supervisee doesn’t make a direct payment to the supervisor for supervision while they’re pursuing their clinical hours for state licensure. Clearly, BCBSI recognizes the importance of the supervisory relationship and the ethical, legal, and consulting responsibilities of that supervisor to the supervisee. 

Clearly, there are many other ways BCBSM could be handling this, and it’s very telling that they are not. 

The reality is that BCBSM is now willfully cutting off access to over 10,000 limited licensed mental health practitioners in Michigan, making it harder for rural and underserved populations to receive care, resulting in longer wait times for mental health treatment for everyone who’s in their PPO plan in Michigan. Additionally, BCBSM is willfully cutting off the pipeline of licensed mental health practitioners that Michigan will have in the future. 

I respectfully ask you meet with BCBSM to get them to change this policy and provide a meaningful solution. Michigan cannot afford to reduce its behavioral health workforce at a time when the need for mental health services has never been greater.
Thank you for your leadership, your service to our communities, and your consideration of this urgent matter.
Sincerely,
Your name, your credentials