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

1. Remember that phone calls matter more than emails. I would encourage you to do both
2. Remember that living in the district of the legislator will make a much bigger impact 

You will notice that the letter begins by ensuring the person taking your phone call or reading your letter understands that you know the legislator and the leadership roles they hold. 

Next, I thank the legislator 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 Michigan Senate Finance, Insurance, and Consumer Protection Committee Chair Cavanagh:

Thank you so very much for protecting the citizens of Michigan as Senate Finance, Insurance, and Consumer Protection Committee Chair. I appreciate that you have worked tirelessly to advance attainable housing, accessible & affordable healthcare, small business and community development, consumer protection, and workforce development initiatives. 

As your constituent, the owner of a Michigan mental health private practice, and a Licensed Professional Counselor (LPC), 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 takes effect, I will no longer be able to keep the three Limited Licensed Professional Counselors (LLPCs) employed in my practice and my one graduate student intern. This is not because they are unqualified or unsafe. It is because BCBSM has decided to no longer reimburse for the services they provide in my private practice while they are working toward full licensure under the supervision of an LPC.
As a private practice owner, I have invested a tremendous amount of time, resources, and financial capital in training the next generation of Michigan’s mental health workforce. Every LLPC in my practice receives extensive supervision that exceeds the minimum requirements of state law and professional ethics. Their clinical work is reviewed, cases are discussed, treatment plans are refined, and I remain legally and ethically responsible for the care they provide. 
Nothing about BCBSM’s new policy improves patient safety. Respectfully, quality of care is already governed by Michigan law, professional licensing rules, ethical codes, and mandatory clinical supervision—not by an insurance company. Whether an intern or an LLPC works in a hospital, a community mental health agency, or a private practice, the supervision requirements remain exactly the same. 
Instead, this policy removes one of the largest training environments available to future licensed mental health professionals in Michigan.
As a small business owner, I cannot simply absorb the financial loss this policy creates. Without reimbursement for services provided by my supervised clinicians, I will have no choice but to eliminate their positions. That means patients will lose trusted therapists, graduates will lose employment opportunities, and future counselors will lose one of the primary pathways to independent licensure.
The consequences extend far beyond my practice. These professionals represent the future of Michigan’s behavioral health workforce. They are serving children, veterans, families, older adults, individuals experiencing depression and anxiety, trauma survivors, and people struggling with substance use disorders.
As a private practice owner, I am not asking for special treatment. I am asking for common sense.
Every day, I witness the growing demand for mental health services. Families already wait weeks or months to find available providers. Removing thousands of supervised clinicians from private practice will only deepen this crisis.
This policy does not strengthen quality. It does not improve oversight. It does not protect patients.
It reduces access to care.
It harms small Michigan businesses.
It disrupts the education and supervision of future mental health professionals.
And ultimately, it hurts the Michigan residents who need behavioral health services the most.
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. 

Please meet with BCBSM to get them to change this policy, hold legislative hearings on it, request impact studies, and require briefings for health policy committees.
I respectfully ask you to encourage them to suspend implementation of this policy while meaningful solutions are explored. 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