We, the undersigned, urge Blue Cross Blue Shield of Michigan (BCBSM) to reconsider their announced changes to incident-to billing policies that will eliminate reimbursement for services provided by Limited Licensed Counselors (LLCs), Limited Licensed Master Social Workers (LLMSWs), Temporary Limited Licensed Psychologists TLLPs), and Limited Licensed Marriage and Family Therapists (LLMFTs) in a professional setting. 

Michigan's mental health system depends on Limited  Licensed clinicians. These professionals provide thousands of therapy appointments daily across the State of Michigan while completing the supervision requirements necessary for full licensure.

Unlike fully licensed providers, LLCs, LLMSWs, TLLPs, and LLMFTs are not eligible for direct participation with BCBSM. Historically, they have provided services under required supervision and through established reimbursement pathways.

BCBSM's announcement that providers with provisional licensure will no longer be eligible for reimbursement as of March 1st, 2027, through incident-to billing raises significant concerns for patients, providers, and behavioral health organizations throughout Michigan.

Without a clear alternative reimbursement pathway, these changes could:

• Reduce access to therapy appointments for BCBSM members
• Increase waitlists for mental health services.
• Force behavioral health practices to reduce or eliminate positions for limited licensed clinicians.
• Disruption of care for existing patients in treatment with LL's, given few alternative referral options due to an overwhelmed system
• Create barriers for new clinicians entering the profession.
• Worsens Michigan's already critical behavioral health workforce shortage.

Limited licensed clinicians are not students observing treatment. These individuals have graduated with Master's degrees, completed supervised practicum & internship hours, and received limited licensure from the State of Michigan with the obligation to complete 3000-4000 hours of supervised clinical experience under a qualified supervisor. Eliminating reimbursement for their services without establishing a viable alternative threatens access to mental health care across Michigan.

BCBSM has indicated that these changes are intended to promote quality, accountability, and appropriate oversight in behavioral health services. However, if limited licensed clinicians are considered qualified to provide reimbursable mental health treatment in facility-based settings under supervision, it raises an important question: why would the same clinicians be deemed ineligible for reimbursement when providing substantially similar services under supervision in professional practice settings?

LLPCs, LLMSWs, TLLPs, and LLMFTs do not suddenly become more or less competent based on the billing location. These clinicians are trained, supervised, and regulated by the State of Michigan regardless of whether services are delivered in a facility or a professional office. If supervised care provided by limited licensed clinicians is considered appropriate and reimbursable in one setting, eliminating reimbursement in another setting appears to be a change in billing policy rather than a change that demonstrably improves clinical quality.

When access to mental health care is restricted, there is a major trickle-down effect in our communities. People don't just magically get better. Lack of access results in overwhelmed emergency rooms, law enforcement is forced to try to manage mental health crises, our inpatient beds fill up, and suicide rates increase.  

Blue Cross Blue Shield of Michigan is the largest insurer in Michigan, covering over 5 million individuals, according to its 2025 annual report. Michigan already faces a shortage of mental health professionals. Policies that reduce access to care for one of the state's largest insured populations risk creating ripple effects throughout the behavioral health system. This is not just a BCBSM issue; it is a Michigan mental health access issue. Every patient, every provider, and every community could feel the impact.

Michigan already has 233 designated Mental Health Professional Shortage Areas. This BCBS policy will unquestionably deepen that shortage, not reduce it.

We call on Blue Cross Blue Shield of Michigan to: 

• Create an exception or alternative reimbursement pathway for limited licensed mental health professionals beyond March 1st, 2027.
• Engage with professional counseling, social work, marriage and family therapy, and behavioral health organizations before implementing changes that could reduce access to care.
• Ensure that policy changes do not worsen Michigan's mental health workforce shortage or reduce patient access to services.

BCBSM has stated that these changes are intended to improve oversight, accountability, and quality within the behavioral health system. However, quality care is not measured by billing structures alone. Quality care is measured by whether patients can access treatment when they need it, maintain relationships with trusted providers, and receive consistent, uninterrupted support throughout their mental health journey.

A policy that reduces the number of available providers, lengthens waitlists, disrupts established therapeutic relationships, or creates barriers to care does not improve quality for patients. It simply limits access. For many Michiganders, especially those in rural communities, underserved areas, and populations already struggling to find mental health services, access is quality.

Michigan's limited licensed clinicians provide competent, supervised, and essential care every day. They are a critical part of the mental health workforce and the pathway through which future fully licensed providers enter the profession. Policies that jeopardize their ability to serve patients threaten not only today's access to care, but the future of Michigan's behavioral health system.

We urge BCBSM to recognize that protecting patient access, supporting a sustainable workforce, and preserving continuity of care are not obstacles to quality; they are the foundation of quality. Michigan patients deserve solutions that strengthen mental health care, not policies that risk putting it further out of reach.