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. 

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 a Limited Licensed Professional Counselor (LLPC), 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 lose my job. I currently work at ABC Counseling Services in Somecity, Michigan. The private practice owner cannot afford to keep me employed at their practice if I cannot bill insurance.
Like thousands of other limited licensed mental health professionals across Michigan, I work under the supervision of a Licensed Professional Counselor (LPC) while completing the experience requirements necessary for independent licensure. This is not an unusual arrangement. It is the standard training pathway established by ethical codes, Michigan law, and professional licensing boards to ensure the development of competent, ethical, and highly qualified mental health providers.
Under BCBSM's new policy, services provided by professionals like me will no longer be covered through incident-to billing in private practice settings. As a result, many private practices such as mine will no longer be able to employ limited licensed clinicians because there will be no viable reimbursement mechanism for the services we provide.
This policy does not simply affect me. It affects every client on BCBSM PPO plans who currently relies on mental health services from limited licensed providers across Michigan.
I chose this profession because I care deeply about helping people who are struggling with depression, anxiety, trauma, grief, addiction, relationship challenges, and other mental health concerns. Every week I work with individuals who try to hold their lives together while facing extraordinary challenges. Many of them have already waited months to obtain an appointment. If providers like me disappear from the workforce, those wait times will only increase.
I am especially concerned about rural and underserved communities where access to mental health services is already limited. This is the very population that I work with. In many areas, limited licensed clinicians represent a significant portion of the available workforce. Eliminating reimbursement for our services will inevitably reduce access to care for thousands of Michigan residents.
BCBSM has chosen a path that threatens jobs, disrupts patient care, increases barriers to treatment, and weakens Michigan's future mental health workforce.
I have invested years of education, substantial student loan debt, and countless hours of training to enter this profession. I am doing exactly what Michigan requires me to become fully licensed. Yet this policy places my career and livelihood in jeopardy through no fault of my own.
Michigan already faces significant mental health workforce shortages. This policy will make those shortages worse. It will reduce the number of available providers, increase wait times, limit access to treatment, and discourage future professionals from entering the field.
I respectfully ask that you advocate on behalf of Michigan patients, families, and mental health professionals by urging BCBSM to suspend and reconsider this policy change. At a minimum, I ask that legislative leaders investigate the impact this policy will have on access to mental health care throughout our state.
The people who will suffer most from this decision are the Michigan residents who need mental health treatment and may no longer be able to find it.
Suddenly, in early June of 2026, BCBSM announced that they would no longer cover services for their 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 have just a couple of providers, and it’s not feasible for them 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. 

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.
Thank you for your time, consideration, and service to the State of Michigan.
Sincerely,
Your name, your credentials