Community Mental Health Authority Information
No final decision has been made, and any next steps would be considered by the Ottawa County Board of Commissioners as part of a transparent public process.
Questions & Answers
The following presents paraphrased comments and questions, plus responses and answers regarding the potential transition of Community Mental Health services to an Authority model, addressing financial, operational, and governance concerns. This list will continue to be updated as more questions are received.
Services
Where do consumer services fit into the current framework (is the County is simply presenting a decision to the State and sending the bill)?
Under an Authority model, consumers will receive services from current CMH professionals using the same eligibility and service criteria to provide the behavioral health services in the same locations, using the same amount of dollars. The continuation of quality mental health services to consumers is one of the Board of Commissioners’ primary objectives as they consider this transition. Changing to an Authority model will in no way diminish current service levels for consumers, nor will it change the flow of “regular” funding—State CMH/County on General Fund; United States/Michigan to PIHP to the CMHSP on Medicaid; United States/Michigan to CMHSP on CCBHC; and County to CMHSP on millage. The difference is in Medicaid, where there is a deficit. In that instance, the “bill” is returned to the PIHP which either pays or forwards it to the State. To the extent that the bill is due to greater Medicaid need, not mismanagement, the bill will be paid by the PIHP and if necessary, the State.
How would moving to an Authority model help expand or improve critical services? Will any new mental health services be available?
The Authority will be obligated to provide the same level of Medicaid service entitlements and GF CMH services. The Mental Health Board will make the decision on whether additional services can be added if there is an Authority. This will likely depend on the result of the millage, which is independent of the authority/department issue.
As an Authority, would CMH still be able to use existing county buildings to provide services? Where will services be located for clients and employees if the transition occurs?
Yes, they can use the buildings. Currently, CMH occupies almost 25,000 square feet in 4 buildings and paid $450,000 in Fiscal Year 2025. Three of the four buildings are shared with other departments. No change is included during the transition agreement. Beyond that, under an Authority model CMH can continue to occupy this space and enter into a long-term lease agreement with the County.
Medicaid recipients are already being shifted among providers and systems. Will becoming an authority impact this?
No. Becoming an Authority is not related to how Medicaid structures the system or what is in the Medicaid benefit package.
Is becoming an "authority" going to take away who is in control of the consumer's treatment, how they are treated and what services they are receiving? Will it be taken away from our local county?
The short answer is no, becoming a CMH Authority will in no way change or “take away” who is in control of consumer treatment, how they are treated, or what services they receive. Under an Authority model, the same professionals will use the same eligibility and service criteria to provide the same behavioral health services in the same locations, using the same amount of dollars.
The continuation of quality mental health services to our community is one of the Board of Commissioners’ primary objectives as they consider approving this transition. Changing to an Authority model will in no way diminish current service levels.
Is there any evidence or case study showing that Counties operating as Authorities are more effective or better received than departments?
We are not aware of any evidence one way or the other. Effectiveness or “being received well” are not concepts affected by Authority status, one way or another. The analogy might be this: Are partnerships more efficient or better received than corporations?
Governance & Accountability
How would accountability of the CMH work under an Authority structure (e.g. how would leadership be removed if problems arise)?
Currently, program accountability is exclusively with the Mental Health Board. That would not change. The only accountability the Board of Commissioners has over CMH is regarding millage funds. That would not change. The Board of Commissioners would continue to appoint the Mental Health Board and could remove such Board members if necessary. That would not change.
Could the County’s financial contribution be used as leverage accountability and control over the Authority?
Currently, the only “leverage” the County has over the Mental Health Board and Director is in the millage-funded programs. This would not change. The mental health code dictates the County’s contribution to CMH Authorities. It can never be used as leverage.
Where does moving to an Authority structure leave the County and CMH in five years, after current County Commissioners have moved on?
The County Board of Commissioners will have the same limited control that they have now. They appoint Mental Health Board Members and control the millage.
Can a CMH Authority later change their board’s makeup without oversight or approval from the County Board of Commissioners?
No. The County Board of Commissioners would have to change the Enabling Resolution.
Has the State of Michigan indicated whether it would approve the transition?
The State of Michigan has no choice but to approve the authority. It has up to a year to approve the termination of the County department.
Who approves a CMH millage request to voters — the CMH Authority or the County Board?
The County Board ultimately approves any millage request for placement on the ballot as a question to voters. The County Board would then decide each year how much of the authorized millage to levy. The County Board would then be obligated to appropriate the millage revenue to the Authority.
Will the Ottawa County Insurance Authority be insuring the potential new CMH Authority?
The Ottawa County, Michigan Insurance Authority will continue to insure the CMH buildings and any liability associated therein. The CMH Authority will pursue additional liability insurance as it deems appropriate.
Has any other County in Michigan has ever back transitioned back from an Authority model to a department model?
Out of the 79 counties (out of Michigan’s 83 counties) that have created CMH authorities, only one has returned to a department—Washtenaw. It returned to a department after the multi-county authority that it was in dissolved. It did not otherwise decide to return to a department, but the decision was forced upon it.
What would happen if the County wanted to reverse the decision in the future? If the County decides in the future to reverse this decision, does the CMH authority have any say or veto power? Could this create conflicts if the Board of Commissioners attempts to reclaim authority later?
No. The Board of Commissioners controls this issue.
How much authority will the CMH Authority board have to make changes independently?
The State has to approve the General Fund plan 90/10 state/county split. Medicaid funding is determined by the PIHP. The Authority can apply for CCBHC funds from the United States/State of Michigan directly.
Which specific Michigan Compiled Laws (MCLs) justify or relate to the CMH authority transition?
MCL 330.1205 covers the process. Federal law covers the State’s liability.
Legal counsel referenced a one-year period between the passage of a Board resolution and the actual creation of the Authority. Is that timeline established in statute?
The authority is created upon adoption of the resolution. MCL 330.1220 provides one year to the DHS to approve the termination of the CMH department, unless it approves the change earlier.
What is the correct length of the transition period if CMH becomes an Authority—three years or four years?
Three years from the date that the State approves the termination of the department, which it must do within the next year. So somewhere between three and four years.
Could the speed of this process lead to misunderstandings or unintended consequences for CMH employees or residents?
79 counties have completed this process without unintended consequences to employees or residents. Ottawa is actually choosing a slower process in transitioning than many of those counties used.
Financial Considerations
The Board previously considered creating an Authority ten years ago, in 2016. Costs seem to be the reason that the Board did not pursue this at that time. What changed?
2016 examined the loss of revenue to the County and the potential for higher costs to the proposed Authority. Fiscal risk was not anticipated in 2016 because it had never happened in Ottawa. That changed in 2019 when Ottawa had a $2 million deficit and the LRE ran out of money. Moreover, by extending the County cost allocation services for at least three years at the same charges, there is no significant financial impact during the transition. In short, risk circumstances and a better transition plan are what have changed.
What proof or evidence is there that the County would be liable for CMH deficits if CMH remains a department?
In 2019, Ottawa County was obligated to cover the $2 million shortfall in CMH Medicaid funding.
Is there clear, accessible legal analysis showing that converting to an authority will mitigate the stated risk?
As noted above, in 2019, PIHPS across the State ran out of money. Not a single county that had an authority had to step up to cover the risk because MCL 330.1205(6) covered them from the risk. Muskegon and Washtenaw had to use $10 million each in general funds. Ottawa used other County funds to cover its $2 million deficit. Things cannot be clearer than that.
Shouldn’t the County wait until its CMH department is in a stable financial situation?
Actually, the move is being considered because at present the CMH department is in a stable financial situation since its deficit is due to Medicaid entitlements and those will be covered by the LRE. Since it takes a year to fully establish the Authority, the decision must be made during a period like the present, where there is no uncovered deficit.
How does switching to an Authority model reduce the financial instability and risk to the County?
Deficits in Medicaid and CCBHC entitlements are presently at the risk of the County with its $127 million general budget, while an Authority’s same risk is covered by the State of Michigan’s $82 billion budget.
What proof or evidence is there that the State would cover deficits if CMH becomes an Authority?
Unless the State shifts the risk to the County, it is obligated to fund the shortfall under the Michigan Medicaid Plan and 42 USC 1398a. MCL 330.1205(6) blocks the State from risk shifting to Ottawa County. So, the LRE or its successor PIHP would have to initially cover non–mismanagement Medicaid deficits. If that is insufficient, as it was in 2019, the State is obligated by federal law to pick up the entitlements.
Are there examples where a CMH Authority has had deficits and the State has stepped in to cover costs?
Yes. In 2019, many of the regional PIHPs, including the LRE (“Lakeshore Regional Entity”) our PIHP, were unable to the fund the deficits of CMH departments and CMH authorities. The counties that funded those authorities were not asked to fund those deficits because of MCL 330.1205(6). Instead, the Authorities presented their deficits to the State and it increased funding to cover those deficits. The county departments, including Ottawa, Muskegon, and Washtenaw, were left to cover the deficits with their own resources. Ottawa was able to recover the $2 million it had in 2019 deficits with the funding increases in 2020.
Does that number make sense with the amount currently budgeted to CMH and the millage dollars/year and running at a deficit?
The General Fund and millage-funded programs in CMH are not running deficits. The deficits are in the Medicaid side of CMH, which has entitlements determined by the federal government and State and Ottawa County CMH receives its Medicaid allocation on the revenue side from the State on behalf of the United States/State of Michigan partnership. The LRE has reported that, at present, it has the funding to cover last year’s deficit. If Ottawa CMH becomes an Authority, the State will be responsible for squaring revenues with entitlements, which will stabilize CMH.
If there is a funding shortfall, would the County still ultimately be responsible in the Authority model?
No, not in the Authority model. By MCL 330.1205(6) the County is not liable.
How can residents be assured that their tax dollars are protected if no counties have had to use their general funds to cover deficits.
This is not true. In 2019, Muskegon County and Washtenaw County spent $10 million each from their general funds to cover their CMH departments’ Medicaid shortfalls. None of the counties with authorities had that experience. That is proof of taxpayer protection.
Why would the State of Michigan support the change if it is also responsible for covering losses?
The State Legislature, not DHHS, has incentivized the counties to create CMH authorities. The State Legislature is the entity trying to protect the counties and the public CMH system through authorities and PIHPs.
How would the potential loss in CMH-funded revenue to the County (from cost allocated support services) impact other County departments and their budgets?
In the first three years of the transition, little is likely to change because the County will still be providing services. Over time, as responsibilities shift and the workload stabilizes, the need for additional positions in administrative support areas may level off. In the long run, some of these expenses could be reduced due to lower workload and operational need. For example, the County may purchase fewer software licenses for contract software or determine that a supporting department position does not need to be added as previously anticipated.
If the County receives administrative cost reimbursement from the CMH department, why would it want to transition to an authority when it will lose such revenue?
The County is not generating profit from CMH administrative reimbursement; it is recovering costs for services the County currently provides (such as HR, finance, IT, legal support, procurement, and other shared services). During the initial transition, the County would continue providing many of these administrative services, so cost reimbursement would continue for a period of time. Longer term, the County could still provide administrative support to a CMH authority through a service contract if both parties choose to do so. If the authority ultimately chose to obtain those services elsewhere, the County would no longer receive reimbursement—but the County would also no longer be performing that work. Any mismatch in timing would be managed through normal budgeting and staffing adjustments, and should balance over time as workload and costs decline.
Will the loss of the County administrative services end up taking money away from CMH services in the Authority model?
No. The County is willing to provide the services under a contract.
Can the County provide a side-by-side projection of what finances would look like between an Authority and Department?
Unfortunately, there are too many variables to show a side-by-side comparison over the years. The key is that if or when there is a Medicaid deficit, the State is financially responsible.
Will the CMH Authority Board be adequately equipped to handle fiscal oversight and financial analysis currently performed by the Board of Commissioners?
The Board of Commissioners and CMH authority board have no ability to influence Medicaid-driven cost and reimbursement trends as is evidenced by the $2 million 2019 deficit and the $5 million 2025 deficit. Both deficits were due to Medicaid deficiencies over which the County has no control.
Did the Washtenaw County service case involve greater state funding?
The Washtenaw federal case involved two particular recipients’ Medicaid entitlements for developmental disability care. It does underscore; however, that entitlements cannot be cut regardless of whether funding exists at the CMH department level.
Why did Northern Lakes, a six-county authority, lay off staff last year when it had a $9 million deficit?
The layoffs occurred there due to the over-expenditure of General Fund CMH. Medicaid entitlements were covered by its PIHP. Neither Michigan nor the PIHP are obligated to pick up General Fund mismanagement of authorities or departments.
Why have examples from other authorities (Northern Lakes CMH, Central Michigan CMH) not been properly reflected in claims about state coverage?
Medicaid mismanagement or General Fund mismanagement are not covered by anyone. Medicaid entitlement deficits are covered by the PIHP or State of Michigan. In the examples given, there was mismanagement.
What prompted Washtenaw County to change from an authority to a department? What were the implications of that transition for people receiving services? How were employees and programs affected by the change between department and Authority?
Washtenaw had no choice. The multi-county authority in which it was a part went out of business. Ottawa is proposing a single county authority with the same funding as now, so whatever dislocation occurred in Washtenaw should not occur her
Employees & Staffing
Would future employees of the Authority receive the same benefits as current county employees or a different, potentially reduced, benefit structure?
In the short term, the State Legislature protects such wages and benefits. Long term, wages will be determined by the Mental Health Board.
What data supports the claim that Authority employees receive higher wages and benefits than county employees? Have confounding factors, such as geographic location, been accounted for in wage and benefit comparisons?
The claim is that over time, the experience of authorities is that their employees receive wages comparable to those of other authorities and the private medical care field, not the counties. While that is expected to mean higher wages, perhaps it is best to say the wages will be more market-driven, and therefore more equitable, than at present.
Will employees continue to be allowed to participate in the union under their recently negotiated contract after the first year as an Authority?
Yes. The union will continue.
What is the strategy to maintain good coverage for CMH Authority employees while controlling costs—beyond just “aggressive negotiation”?
The employees have a union and the statute for protection. In the long term, the revenues from this medical enterprise funded by the United States and State of Michigan and the same funding that the County has always given will provide the same resources for the Authority to operate as it does now. There is no change in funding.
Would current CMH employees have priority access to County positions if they choose not to move to the Authority?
CMH employees may apply for County openings if they are interested and qualified. All candidates, whether current County employees or external applicants, are considered through the same competitive hiring process, and positions are filled based on qualifications and fit for the role. CMH employees would not get “priority” in this process.
Will switching to an Authority model lead to increased staffing levels?
The County would provide administrative support to an authority for a fee, as it does now. No change is necessary. In the long run, an authority could seek alternative options for these administrative services or they could be provided by new authority staff. Any new staffing, if it occurs, should be minor, as the labor remains the same.
What is the hiring timeline for a Chief Financial Officer?
If the Board of Commissioners approves the transition to an Authority, that position would be promptly filled.
How will the County maintain the strong interdepartmental partnerships that currently exist between the County and CMHOC if it were to transition to an Authority model?
After the transition period, an authority would contract with County departments to maintain interdepartmental relationships.
Vendors & Service Providers
Is there any risk to vendors and service providers in terms of payment stability during or after the transition?
No.
What would the recredentialing process for service providers look like under an Authority model (i.e. would it become more burdensome)?
Should not change.
Data & Statistics
What is the ratio of the number of people/consumers/clients normally served by CMHOC to the County’s population?
Community Mental Health serves over 4,000 out of 306,000 residents.
Why are so many CMH services located in Holland? Where will services be located for clients and employees if the transition occurs?
CMH has locations throughout the County, including Holland, Grand Haven, and Hudsonville. The majority of CMH services are provided in the community throughout the County. Holland is the largest municipality in Ottawa County. As an Authority, the Mental Health Board would be responsible for locating service centers.
Is Lakeshore Regional Entity (LRE) being (or has been) eliminated?
Until a few weeks ago, the intent of the State of Michigan was to consolidate the 10 regional entities, including the LRE, into 3 new PHIPs in which Ottawa County would not participate. The State has stepped back and is considering whether to keep or make another change, but has affirmed its intent to make a change.
Will public comments be recorded so that Commissioners not present could hear them in full?
Only the first session in Georgetown was recorded on video. Questions and Comments from the community were documented and are being answered here.
Read the Report
View the Presentation
See the impacts and considerations of the department becoming an authority.
Watch the Hearing
Three public hearings were held to consider feedback from residents.