Organizations funded by the Mental Health Millage seem to be part of the approved CCBHC provider network
Government healthcare systems which serve certain medically vulnerable portions of our population are currently being transformed. Once finalized, these changes will likely be implemented into the healthcare systems for the greater population. Please pay attention as this may not be affecting you today, but it likely will in the near future.
A Certified Community Behavioral Health Clinic (CCBHC) is not a physical building, but rather a collection of private, non-profit, and government health care service centers working together and usually receiving funding through one of the various state or federally run CCBHC programs. Make no mistake about it: CCBHCs are socialized health care. According to the Substance Abuse and Mental Health Services Administration (SAMHSA), “A Certified Community Behavioral Health Clinic model is designed to ensure access to coordinated comprehensive behavioral health care. CCBHCs are required to serve anyone who requests care for mental health or substance use, regardless of their ability to pay, place of residence, or age - including developmentally appropriate care for children and youth.” In addition to providing treatment for behavior and mental health, these clinics contain provisions for covering all health care needs.
In the same way government schools are encroaching on parental rights, it seems CCBHCs are slowly replacing private health care options. When established systems of government are transformed into systems that remove power from the people and place it in the hands of bureaucrats, it seems it is commonplace to begin the transformation by initially targeting the most vulnerable people, namely, children, elderly, and those with substance use disorders (SUD), mental illness, and intellectual and developmental disabilities (IDD). Once the process by which these individuals receive services is transformed and operational, the changes are likely to be implemented on the remainder of the population.
According to the CCBHC Demonstration Handbook, a guidebook for establishing an approved CCBHC that is eligible for government funding, the organization must, “participate in state sponsored activities designed to support CCBHC’s in transforming service delivery.”
There is currently a huge push for Ottawa County to adopt a CCBHC model of care, and Michigan is a demonstration state under the Section 223 Protecting Access to Medicare Act of 2014. That essentially means that select community mental health departments or nonprofit organizations are chosen to implement the CCBHC model, and are given government funding to do so. Implementation involves meeting the requirements of CCBHC, including gathering data to show success and creating infrastructure for sharing data with partner CCBHC organizations. In other words, Michigan has been busy building the infrastructure for a CCBHC model of health care since 2015 under the guise of grants that appear to benefit vulnerable populations, and this same model is likely to be expanded to cover the general citizenry.
There is also strong evidence that suggests the Mental Health Millage money, voted in by Ottawa County taxpayers in 2017, is really being used to fund the Certified Community Behavioral Health Clinic (CCBHC) model of health care delivery in Ottawa County.
To fully understand why CCBHCs are taking away people’s rights, one must first understand the current platform of Home and Community-Based Services waivers. In the 1999 Olmstead Rights decision, the Supreme Court ruled that people with disabilities have a qualified right to receive state funded supports and services in the community rather than in institutions. Home and Community-Based Services 1915(c) waiver programs (HCBS Waivers) are the programs that empower these individuals by providing them with the tools they need to live independently.
HCBS 1915(c) waiver “programs can provide a combination of standard medical services and non-medical services. Standard services include but are not limited to: case management (i.e. supports and service coordination), homemaker, home health aide, personal care, adult day health services, habilitation (both day and residential), and respite care. States can also propose “other” types of services that may assist in diverting and/or transitioning individuals from institutional settings into their homes and community.”
These programs enable freedom of choice for individuals with special needs. They are based on conflict free access and planning. Simply put, community mental health(s) (CMHs) cannot give themselves referrals. Governments cannot choose where people live or what activities fill their life. People choose for themselves, and this includes people with IDD, SUD, and mental illness. This means choosing meaningful individualized activities, and not being forced into day programs where everyone does the same thing. This is also known as least restrictive environments.
Under the CCBHC system of care, a series of independent providers work together in a collaborative to serve the health care needs of the population. These independent providers are known as Direct Collaborating Organizations. According to the Michigan CCBHC Handbook, a direct collaborating organization (DCO) “is an entity that is not under the direct supervision of the CCBHC but is engaged in a formal relationship with the CCBHC and delivers services under the same requirements as the CCBHC.” DCO’s are also “referral centers” for the other organizations in the collaborative, and they engage in data collection, as explained in the CCBHC Certification Criteria.
Forming such a collective ensures organizations in the collective thrive, where as organizations outside the collective are not identified as entities where consumers are typically referred. Therefore, the government appears to be picking ‘winners’ through this selection processes, but according to the following response to a FOIA request, there are no formal DCO’s in Ottawa County.
Despite not having formal DCO agreements in Ottawa County, the organizations who currently receive funding through the mental health millage program seem to be the same organizations becoming partners in the CCBHC’s. In other words, the mental health millage beneficiaries, seem to be the CCBHC DCO’s. Some of these organizations include:
Benjamin’s Hope
Georgetown Harmony Homes
Harbor House Ministries
Heritage Homes, Inc
Holland Deacons Conference
MOKA
Parkview AFC
IKUS R.E.C. Connect
Momentum Center
Pioneer Resources
Arbor Circle
Beacon of Hope
Bethany Christian Services
City on a Hill
Midtown Counseling
Mosaic Counseling
Holland Drop-In Center
Lakeside Clubhouse
Lakeshore Housing Alliance
Michigan Rehabilitation Services
Hidden in the CMHOC website is the Provider Network Council meeting minutes. Providers of services to the community mental health have regular meetings. According to the Provider Network Council minutes, “This Council’s purpose is to discuss and prioritize issues related to the CMHOC Provider Network. This type of forum will assure that there is a common and consistent message going out from CMHOC to the provider network.” On the last page of the Provider Network Council (PNC) meeting minutes from April 13, 2023, there is a link to a CCBHC Activities and Newsletter.
If you click on the Events – Ottawa County, Michigan (miOttawa.org), it brings you to a CMH page that lists many CCBHC events funded by recipients under their mental health millage contracts.
This raises the question: Are CCBHC activities being funded by the Mental Health Millage? Many of the events listed are part of the social recreation programs offered by non-profits. For example, there are several events hosted by the Momentum Center such as SMART Recovery, Teen Mindfulness events, and dinner and movie nights.
Some community members are beginning to question these social recreation programs. During the July 24, 2023, Community Mental Health board meeting a local resident gave the following public comment.
(12:40)
“These CMHOC board meetings sound more like a mental health millage meeting supporting the CCBHC initiative. There is absolutely no oversight of the Managed Care Medicaid programs and general funds. The board of directors give authorization to Lynn Doyle to sign contracts between the state, and CMHOC, and Lakeshore Regional Entity, as a prepaid inpatient health plan and CMH for delivery of contracts; for delivery of services within those contracts, for the 40 million dollars that is entrusted to CMH, to provide to the most vulnerable people, to keep them out of crisis.
A good portion of these funds are protected under the home and community-based final rule, that allows the most severely disabled and elderly to choose meaningful services, that are individualized to meet their needs and desires, to live meaningful lives, fully integrated in their community. Integration is not what Momentum [Center] is doing. The millage is paying for Momentum's model to intentionally integrate IDD, SMI, and SUD in one facility, which most resembles a psychiatric hospital, that takes us back about 60 years.
The home and community-based services mandate integration of IDD with the greater community; with people who aren't Medicaid recipients. So, I feel like the millage, is actually being weaponized against people who want freedom, and I urge the board to please look into this.”
The CMHOC board is supposed to govern the Federal Medicaid programs, State Medicaid Programs, and general fund programs per the CMHOC/State, CMHOC/LRE and LRE/State contracts per the Michigan Mental Health Code 330.1226. Unfortunately, it seems like the CMHOC board and the public are being misled. CMH meetings tend to focus on mental health millage and grant spending which appear to be funding the CCBHC programs intended to “transform service delivery”, but they rarely if ever discuss Medicaid Home and Community-Based Service waiver 1915(c) (HCBS) benefit plan programs. This means that the taxpayers of Ottawa County, are possibly unknowingly funding the creation of a socialized healthcare system called CCBHC through the mental health millage.