With changes to dual eligible policy on the horizon, Michigan expert says behavioral health integration will continue to be in focus in 2023


James Sklar


Dave Schneider, Managing Principal at Health Management Associates, recently told State of Reform that Michigan lawmakers, policy makers, and beneficiaries need to start watching MI Health Link because—in accordance the recent final rule, CMS-4192-F, issued by CMS—Michigan plans to transition to an Integrated Dual Eligible Special Needs Plan beginning 2026.


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Currently, for dual eligible beneficiaries, the entire state operates with Dual Eligible special Needs Plans (D-SNPs). However, by 2026, Michigan will either transition to a fully integrated dual eligible special needs plan (FIDE SNP) or a highly integrated dual eligible special needs plan (HIDE SNP).

–   FIDE SNPs includes coverage of primary, acute, and long-term services and supports benefits. FIDE SNPs must also cover behavioral health benefits unless the state carves behavioral health out of the capitation rate.

–   HIDE SNPs includes coverage of long-term services and supports benefits or behavioral health.

Again, behavioral health integration is on the table for 2023. Schneider said the conversation will involve a lot of the same players with similar concerns to last year’s behavioral health integration legislation.

Since integrating behavioral health would require taking behavioral health funding out of the existing Prepaid Inpatient Health Plans—thus requiring changes to Michigan’s Social Welfare Act—stakeholders like the Community Mental Health Association are likely to oppose the new effort..

Leading up to the implementation of its new integrated model, Michigan plans to have stakeholder engagements, determine state legislation authority, and start program development.