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. 

Good luck! Sincerely, Dr. Burns

Your name, your credentials
Your address
Your phone
Your email

X/XX/26

Dear BCBSM:

As a BCBSM PPO subscriber, I hope you will stop your proposed PPO changes to incident-to billing in private practice settings.
This issue is deeply personal to me because it threatens my ability to continue receiving care from the counselor who has helped me through some of the most difficult moments of my life.
Mental health treatment is not like replacing a broken appliance or switching to a different store. The relationship between a client and counselor is built on trust, safety, vulnerability, and time. It can take months or even years to develop the therapeutic relationship necessary for meaningful healing and progress. Now, because of BCBSM’s policy change, I may be forced to stop seeing the counselor who knows my history, understands my struggles, and has been instrumental in helping me improve my mental health.
The thought of starting over with a new provider is overwhelming. I would have to retell painful experiences, rebuild trust with someone new, and risk losing the progress I have worked so hard to achieve. For many people receiving mental health treatment, this disruption could lead to worsening symptoms, setbacks in recovery, increased crises, and, in some cases, people simply giving up on treatment altogether.
When I purchased a PPO plan, I paid higher premiums and deductibles because I wanted greater access to healthcare providers and the flexibility to choose the professionals who best meet my needs. I did not expect BCBSM to suddenly reduce my access to care and eliminate coverage for services provided by thousands of qualified mental health professionals working under supervision in private practice settings.
This policy will not only affect me. It will affect thousands of Michigan residents who rely on these providers for counseling services. It will reduce access to care, increase wait times, force patients to travel farther for treatment, and disproportionately harm rural and underserved communities where mental health resources are already limited.
Additionally, this decision threatens the future of Michigan’s mental health workforce. The supervised experience obtained through incident-to billing is a critical pathway for counselors, social workers, marriage and family therapists, and psychologists working toward independent licensure. By eliminating reimbursement for these services, BCBSM is discouraging the development of future mental health professionals at a time when Michigan is already facing significant behavioral health workforce shortages.
I respectfully ask that you reverse this policy before patients lose access to the care they need and deserve. No one should be forced to abandon a trusted mental health provider because of an insurance company decision that restricts access to care.
Mental health treatment saves lives. Please stand with Michigan patients and families by protecting access to the providers who are helping us heal.
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 is making 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. 

Private practices cannot convert easily to an Outpatient Psychiatric Care Facility (OPCF) if they want 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, suggesting 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 is not feasible. 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 could solve the “problem” without reducing the number of mental health treatment providers. I’m just going to list a couple.

First, 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 you are not. 

BCBSM PPO is my health insurance plan, and I paid higher premiums and deductibles so I wouldn’t have to coordinate everything through my primary care physician or need a referral to see a specialist, while gaining access to a greater number of providers and greater overall flexibility to meet my healthcare needs. 

BCBSM PPO is now doing the same thing as their HMO with my mental health treatment providers, but the reality is I paid them for more access, not less, and that’s why I feel BCBSM is in breach of contract.

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 change your policy.
Thank you for your time and consideration.
Sincerely,
Your name, your credentials