Michigan Proposed Removing an ABA Access Barrier. Every Other State Added One.

MDHHS project 2613-BCCHPS would drop the requirement that a child complete a physical examination before receiving behavioral health treatment, widen who may diagnose, and align ABA language with BACB, APBA and CASP standards — to cut waitlists. The comment period and the proposed effective date have both passed, and no final bulletin adopting it could be located.

Every state story this year has gone the same direction. South Carolina cut telehealth and tightened caseloads. Virginia capped hours. Indiana required accreditation. Ohio revived a shelved rule. North Carolina added certification and supervision floors.

Michigan proposed the opposite, and said so in a sentence:

“These updates and clarifications are intended to remove barriers causing waitlists for beneficiaries to gain access to quality and timely BHT interventions.”

What the proposal does

MDHHS project 2613-BCCHPS, “Updates to Behavioral Health Treatment (BHT) Requirements for Autism Services,” proposes four changes to the BHT/ABA section of the Michigan Medicaid Provider Manual:

  • Removes the physical examination requirement. Children no longer have to complete a physical exam by a primary care provider before receiving BHT services. This is the barrier the waitlist sentence is about.
  • Widens who can diagnose. Language is added “to increase access to qualified licensed diagnosticians as approved by MDHHS.”
  • Aligns ABA language with generally accepted standards of care. The notice names its authorities: the BACB, the Association of Professional Behavior Analysts, Autism Speaks, and the Council of Autism Service Providers.
  • Updates provider qualification language to match the licensure requirements administered by the Department of Licensing and Regulatory Affairs, under Public Act 403 of 2016 (MCL 333.18251), and updates diagnostic re-evaluation requirements under Public Act 111 of 2021.

The notice is distributed to Community Mental Health Services Programs and Prepaid Inpatient Health Plans.

Worth noticing who Michigan cites

Michigan names CASP as a standard-setter it is aligning toward, in the same year a major payer wrote CASP's criteria out of its own policy and replaced them. The same document is a floor in one state and surplus to requirements at a payer in another. If you operate in both, you are already reconciling that.

The dates, and the gap in them

  • April 23, 2026 — public comments due.
  • May 1, 2026 — proposed bulletin issued.
  • June 1, 2026 — proposed effective date.
  • July 1, 2026 — the July manual update went live under bulletin MMP 26-22.

All four have passed. And here is the part we could not close: we could not find a final bulletin adopting 2613-BCCHPS. We read MMP 26-22, the 58-page July manual update, in full. It revises the Behavioral Health chapter in several places — Youth Peer Support eligibility among them — but contains no reference to the physical examination requirement, to diagnostic re-evaluation, or to the BHT standards-of-care language. Searching the bulletin for those terms returns nothing.

The limits

This is a proposed policy. A notice of proposed policy is a consultation document, not a rule, and MDHHS can adopt it, change it or drop it after comment. The proposed effective date passing is not evidence that it took effect. It is equally possible the change was finalized in a bulletin we did not locate, or folded into the online manual without a separate bulletin, as it is that it stalled. We are reporting the proposal and the gap, not an outcome — and a Michigan provider should confirm against the manual rather than against this article.

What you must know or do

  • Michigan providers: check the manual, not the bulletin list. Open the MDHHS Medicaid Provider Manual, Behavioral Health and Intellectual and Developmental Disability Supports and Services chapter, and read the Behavioral Health Treatment Services/Applied Behavior Analysis section as it stands today. Technical updates are highlighted in yellow in the online version. That tells you what is operative; the bulletin trail does not.
  • If you have been turning families away for want of a PCP physical: that requirement is the specific thing proposed for removal. Confirm its current status before you keep applying it — this is the rare change that shortens your waitlist rather than your schedule.
  • If you intake on a diagnosis from a non-traditional diagnostician: the proposal widens the accepted list to “qualified licensed diagnosticians as approved by MDHHS.” Approved by MDHHS is the operative qualifier, and the approval list is the thing to ask for.
  • Everyone else: this is the first state this year we have found moving to reduce access conditions rather than add them, and its stated reason is waitlists. When your own state's next rule arrives framed as program integrity, Michigan is the counter-example worth having in the room.