SUD Rule Changes Toolkit

The state of Michigan is considering changes to regulations that could have serious implications for substance use disorder providers around the state.

These changes are likely to reduce access to care and increase the cost of care. This would be of great concern at any time but is of extra concern when we are in the middle of an opioid and overdose crisis.

The changes that raise the most serious concerns are:

• Staff certification requirements that would eliminate limited licensed social workers from the workforce and the opportunity for non-licensed staff to enter the profession, effectively decimating the treatment workforce.
• Staff licensing requirements that Requiring medical staff around the clock which would create a significant and unnecessary cost burden forcing many providers to choose between closing their doors or significantly raising costs.

These changes are a threat to the treatment provider community, the clients they serve, and the social workers who provide the services.

Please take action by the October 17, 5pm deadline by clicking here 

More information:

Draft of the rule changes: http://dmbinternet.state.mi.us/DMB/ORRDocs/ORR/1809_2018-028LR_orr-draft.pdf

Other documents about the rule changes: http://dmbinternet.state.mi.us/DMB/DTMBORR/Rules.aspx?type=dept&id=LR

Legislative and Social Policy Committee member, Jason Schwartz created a helpful website where you can get a sense of how this will impact individual agencies: https://protectspera.dawnfarm.org/background

TIMELINE FOR FINALIZING PROPOSED SUD SERVICES RULES

All written public comment must be received by LARA by 5:00 pm on Wed., October 17.

Please email your comments to: Tammy Bagby at Bagbyt@michigan.gov

If you are available to attend, a public hearing has been scheduled (in this case written comments are more important):  

Wednesday, October 17, 2018

9:00 am -10:00 am  

G. Mennen Williams Building Auditorium

525 W. Ottawa Street

Lansing, Michigan

After public comments close, LARA can decide to make revisions based on public comments OR NOT make revisions. If they do make revisions (we hope they do) and they are major substantive changes, the process starts over – public comments will follow, etc. Once they are ready for submission, they are presented to the Joint Committee on Administrative Rules (JCAR). This is the legislatures “touch” on the process. Typically this committee does not meet to approve rule changes like a legislative committee would meet to approve legislation. As long as 15 legislative session days remain prior to the end of a legislative session, the rules are approved automatically unless JCAR meets to stop them by passing legislation to that effect. However, we have a special case here! There are only 14 session days remaining. Meaning, JCAR MUST meet to “waive” the 15 day rule. This is yet another opportunity for us to lobby. If we make enough noise, we can either a) convince LARA to rewrite the rule effectively starting the process over or b) convince JCAR to NOT waive the 15 day rule – which doesn’t start the process over but it pushes the rule process into the new year and starts the 15 day clock over again buying us more time.

In other words, we should be writing LARA, JCAR, DHHS, legislators in our home districts, legislators in leadership, and the governor’s office to voice our concerns.

Governor Rick Snyder: governorsoffice@michigan.gov

LARA: Tammy Bagby at Bagbyt@michigan.gov

DHHS: Jeff Wieferich at wieferichj@michigan.gov

Your Elected Official: http://cqrcengage.com/socialworkersmi/home

Health and Human Services Budget Committee Chairs:

House: Ed Canfield EdwardCanfield@house.mi.gov

Senate: Pete MacGregor SenPMacGregor@senate.michigan.gov

Members, Joint Committee on Administrative Rules (JCAR):

State Senators

The Hon. Jim Stamas, State Senator 
(Chair) senjstamas@senate.michigan.gov

The Hon. Tory Rocca, State Senator

sentrocca@senate.michigan.gov

The Hon. Mike Kowall, State Senator

senmkowall@senate.michigan.gov

The Hon. Morris W. Hood III, State Senator

senmhood@senate.michigan.gov

The Hon. Curtis Hertel, Jr., State Senator

senchertel@senate.michigan.gov

State Representatives

The Hon.  Steven Johnson, State Representative
(Alternate Chair) stevenjohnson@house.mi.gov

The Hon.  John Reilly, State Representative

johnreilly@house.mi.gov

The Hon.  Shane Hernandez, State Representative

shanehernandez@house.mi.gov

The Hon.  Jeremy Moss, State Representative

Jeremymoss@house.mi.gov

The Hon.  Tim Sneller, State Representative

timsneller@house.mi.gov