Advocacy Updates: Hearing for Administrative Rules for Substance Use Disorder Service Program

For several years, HFM has been working as a member of the Bleeding Disorders Substance Use and Mental Health Access Coalition, or BD SUMHAC.

One of the primary goals of this coalition is to improve access to inpatient and residential mental health and substance use disorder treatment for people with bleeding disorders. Through this work, we have had the opportunity to weigh in on proposed updates to Michigan’s substance use disorder treatment rules through the Department of Licensing and Regulatory Affairs (LARA). We’re grateful to LARA for allowing us this opportunity, and we strongly support these changes, which is why HFM submitted comments during a hearing on Thursday, February 19, 2026.

The proposed rules make clear that individuals should not be denied substance use treatment simply because they have another stable, well-managed medical condition, or because they require medication to treat that condition.

The rules appropriately allow individuals to continue non–substance use disorder medical treatment while in a treatment program and, when appropriate, to self-administer prescribed medications, including infusion or injection therapies. For members of the bleeding disorders community, this clarification is critical. In our community, people with stable, well-managed chronic conditions have been turned away from substance use treatment due to assumptions about medical complexity or required to stop their critical non-substance use disorder medication to gain admission. These changes help ensure individuals are not forced to choose between their physical health and their behavioral health.

The proposed updates also make clear that if someone cannot safely manage their own medication, the program is required to ensure they receive it—either through trained staff or an outside medical provider. It also helps ensure that specialty medications are accessible by permitting recipients to bring medications prescribed by their doctor and filled at an outside pharmacy into a program, as long as the prescription can be verified and the medication is safe and in good condition.

These updates align with national clinical standards, including the American Society of Addiction Medicine’s 4th edition of the ASAM Criteria, which emphasize that individuals should not be excluded from any level of care because of a medical condition that can be self-managed or effectively managed by an external provider.

We are grateful to LARA’s staff for their thoughtful consideration and strongly support these changes, which will meaningfully improve access to substance use treatment for people with bleeding disorders and others living with chronic medical conditions.