Recovery Program for Licensed Healthcare Professionals in Michigan

Recovery Program for Licensed Healthcare Professionals in Michigan, with Terri Vidals

This podcast explains the recovery program process for licensed healthcare professionals in the state of Michigan. It is state number two in my series on recovery programs.

Transcript:


Hello everybody. Welcome back. We do have a sponsor today, IMI. IMI offers a complete line of products to increase pharmacy efficiency and safety. And their mission is very simple help healthcare professionals ensure the safe delivery of medications from pharmacy to patient. As you can see, today I am alone. I had mentioned in a previous podcast that I would like to do a series of the different states and their recovery programs. Today. We are going to talk about the state of Michigan. They have agreed to let me share this information with you, although they did not want to be on camera themselves. So that’s why invite me some. So the state of Michigan it is called the Michigan Health Professional Recovery Program. HPRP. I’ll be referring to them throughout this blog by their initials, HPRP Michigan Health Professional Recovery Program. In 1993, Michigan passed legislation requiring the Michigan Department of Licensing and Regulatory Affairs, bureau of Professional Licensing to contract with a third party for their recovery program. 


This recovery program is for all licensed health professionals. The recovery program is designed to encourage healthcare professionals to seek treatment for substance use, disorder and or mental health disorders before the impairment harms a patient or damages their career through disciplinary action. I spoke with the current program director, Carolyn Bachelor. She’s a licensed master has her licensed Master social work. The Third Party Contract Alliance Incorporated, along with a board that is composed of members from each professional licensing board, work together to govern the policies and procedures of the program. So it’s not just the third party contractor that controls things, but there are members from each of the professional licensing boards that work together collectively. This group, these board members that form this committee, and the third party contractor, collectively, they report to the Bureau of Professional Licensing, but the Bureau does not dictate how they handle the program. 


Also interestingly, the amount the contracted company is paid is a negotiated rate. It’s the rate that is set no matter how many people they have in their program. This, I imagine, is meant to avoid stacking of the program. It works to remove any incentives to admit people into the program that shouldn’t belong. And it also removes the likelihood that they’re going to keep people in the program who should not be there just so that they can collect fees. The HPRP has no financial relationship with the fees paid for drug screening or fees paid to the treatment providers, which are paid directly by the participants. The recovering professionals, they pay directly to the lab and to their treatment providers. The HPRP does not get in the middle of that. Also interesting, and maybe other states do this, we’ll find out. But a portion of the professional license fees that are collected in Michigan go to support the recovery program for the state. 


So every licensee pays into this. And I suspect that’s then part of what goes to the HPRP for their work that they do. The recovery program in Michigan has two avenues. It’s the non regulatory and the regulatory. Both avenues have exactly the same monitoring agreement with the HPRP. There is no difference in how the program works as far as they are concerned. There is a difference to the licensee. And I’ll talk about that. So let’s talk first about the non regulatory avenue. The non regulatory is the path that removes the licensing board from the recovery process. The licensing boards do not require the names of the licensee that’s enrolled in the recovery program to be shared with them. They only want a headcount of the people in the program, but they don’t want names. This means if a person voluntarily contacts HPRP, the licensing board never has to know who they are or that they are in monitoring, they enter the program, they can continue working unrestricted. 


There is a caveat here which I’ll discuss in just a minute. If they go through the program, fulfill all the requirements of the program, and they can graduate and the licensing board will never even know that they did it. If they apply for relicensure in the future and if prospective employers ask them if they are in a monitoring program, they’ll have to answer that honestly, of course. And when I say if they apply for relicensure, that’s of course assuming that they ever were on any kind of suspension or apply in another state. I guess they will have to be honest and say that they have been in a program. How does one get on the non regulatory track of the program? Well, as I mentioned, they can voluntarily contact the HPRP and ask for help. Or another healthcare professional could report them to the HPRP as someone needing help. 


It has to be themselves or a healthcare professional reporting them. Only healthcare professionals can report in. It can’t be a spouse or a friend. Unless of course that spouse or a friend is also a healthcare professional. Reporting cannot be anonymous because they want to avoid reporting for malicious reasons. Another way to be referred is through the employer. Employers are required to report to the licensing and regulatory affairs. They’re mandated reporters. And if they have terminated or suspended a healthcare professional due to concerns with substance use disorder or mental health need, they are supposed to report out to the licensing and regulatory affairs. They also can be referred to the HPRP. So now I’ve just said that the hospital is supposed to report to the licensing and regulatory affairs. But I’ve also said that if the person is enrolled in the HPRP, the licensing affairs doesn’t want to know who they are. 


So how do we reconcile this? Well, let me start first with if an employer reports out and this would be if also just another healthcare professional reports out, I’m sure the HPRP will reach out to that healthcare professional whose name they have been given and they will see if this person will agree to a voluntary assessment. They will attempt multiple times to reach this person over a 45 day period. And if at first they refuse, they’ll say, you know what? Let me give you time to think about it. And they’ll continue to reach back to them in that 45 day period through multiple routes to see if they will change their mind and agree. If ultimately that person refuses, the final answer, I refuse, then HPRP will close the file as non-compliant, and the matter will be referred to the state licensing board. Okay, so if the state licensing board didn’t already know about them, they’re going to know about them. 


Now, if, however, the employer has reported to the licensing board because they’ve been suspended or terminated for suspected substance use disorder or diversion or mental health, and they also report them to the HPRP, how does the person stay on the non-regulatory path? Because a complaint has already been filed with the licensing board. Right? Well, when the licensing board evaluates the complaint, they will contact the professional and ask them if they have been in contact with the HPRP. They will ask if they have agreed to enter the recovery program. If the healthcare professional says yes, then they will ask the professional to sign a release so the licensing investigator can confer with the HPRP to confirm admission to the program. If this healthcare professional allows them to do this and the licensing agency can confirm this, that they are enrolled in the program, then they will take this information and consider it when speaking with the Attorney General and ask that this professional be allowed to go through the non-regulatory recovery program process. 


So, in other words, they had a complaint filed, but when HPRP reached out to the individual, they agreed to seek help. And so the licensing investigator asked the Attorney General, please take this into consideration, and let’s allow them to go through this process, and then let’s allow them to go through this process with no public record, and let’s keep it as a non-regulatory participant. Okay, so now let’s talk about the regulatory avenue in the example that I just went through. If the professional refuses to enter the HPRP, even after repeated attempts by the HPRP to offer services, the HPRP is required by the statute to forward the non-compliant file to the state. They’ll close out the file, and then they send it off to the state. After the state reviews the case, it’s decided if there is a reason to suspend the license, and if there is, it will be done. 


And the licensee will now show the suspension on the website public facing the public record of action remains attached to the licensee from that moment forward. Okay, so just kind of in summary, if someone with a substance use disorder reports themselves or another healthcare professional reports them, they have the opportunity to enroll in the program and essentially keep themselves anonymous from the licensing investigator. If they don’t want to enroll after there’s been a complaint filed, then the state will consider it the regulatory avenue and it will post on the website that their license has been suspended while they work through the other things. Okay, as I mentioned earlier, it does not matter how the licensee gets into the HPRP program. The program is the same. All treatment providers that work with the HPRP have been vetted and they have undergone training by the HPRP. The MD or the do providers must be board certified in addiction psychiatric medicine and the clinicians that are the LMSWs, LPCs, or Ma. 


Psychologists must have a minimum of five years work in the field postgraduate, and they can’t be working out of their home office. All potential enrollees are given the name of three treatment providers so they can find a person that they’re comfortable to work with, that they feel comfortable with, and if they interview all three and they’re still not comfortable, then they’ll be given more names. So the goal is to get them hooked up with somebody that they feel comfortable with. The program begins with an extensive evaluation as to whether they meet the criteria to enroll. This involves meeting the Diagnostic and Statistical Manual, the DSM five criteria for Substance Use Disorder or a mental health issue. The diagnosis will determine how long of a monitoring agreement program will be offered. That duration can change. They give them the initial duration and it can change. But that change requires a decision by the committee who evaluates all admissions. 


They evaluate all program time extensions as well as program time decreases. So this is a very formal process. The diagnosis, assessment process is pretty extensive and based on their experience, they know essentially how long it will take depending on the severity and what the condition is. But they also recognize that each case is individual. And so they will work toward either decreasing that time or increasing that time if need be. If the professional meets the criteria for admission, they will be asked to sign a voluntary agreement for participation in the program. This person can remain employed if there has been no suspected diversion of controlled substances. The participant can remain in their current position. If there has been substantiated diversion of a controlled substance, that changes things. The participant will be required to work in a capacity where controlled substances are not available to them. 


So earlier I said they can continue working, but there’s a caveat. Some of these people in the program have alcohol issue and it’s not controlled substances that are available in hospitals. That, that is their temptation. And so they can continue to work, but if there is substantiated diversion, that changes the whole thing and they can continue working, but they have to not be able to have access to those controlled substances. So this could mean a new position where medications are not handled at all, or if the employer is willing to make an accommodation so they can keep their current role and have others handle the controlled substances, then that is an option as well. After six months of working without the ability to dispense controlled substances, the licensee can be assessed by their treatment team to see if they can resume their ability to practice with access to controlled substances. 


All of the employers who continue to employ the participant are vetted and they need to meet certain program requirements. This includes having a work site monitor, which is usually their supervisor, who will have eyes on the participant regularly and has the ability to remove the licensee if they are instructed to do so by the HPRP because of maybe a positive or unapproved drug screen. This worksite monitor also provides quarterly updates to the HPRP so they work very closely with the employer. The healthcare professional participant will typically not be allowed to work the night shift in the early months after starting a monitoring agreement, largely due to the lack of supervision in the hospital. And they are also discouraged from working more than a 40 hours work week unless their outpatient. HPRP treatment team clinically assesses and determines that they’re safe to work more than 40 hours. 


Because if you think about it’s often those long work weeks that contribute to some of the stressors, right? So they want to remove them from that and give them every chance of success. The program involves regular drug screening, the frequency of which may depend on the diagnosis and the work environment. If relapse occurs, time in the program will be extended so the participant has more time to get abstinent and is given every benefit for success. If at any time the participant is non compliant, to the extent that it’s clear that they’re just not engaged in the program, HPRP will close them out non compliantly, close them from the program, and report to the Bureau of Professional Licenses, which then could result in disciplinary action. On the other hand, if they successfully complete the program for the statute, all records of their participation in the program will be expunged after five years. 


And there’s nothing that was ever public facing on their record to let anyone know that they were ever on suspension or at any action on their license at any point. Medically assisted treatment is allowed in Michigan with the HPRP program, the HPRP leaves a decision of mat versus nomat up to the treatment providers. The treatment providers do a clinical assessment and determine what is best for that patient. If the treatment provider feels matt, will give the participant a higher chance of recovery success, then that’s the route that they’ll go, and the HPRP will allow that based on their clinical rationale. They also will allow a participant to remain on other controlled substance medications. If the treatment provider deems medically necessary. Now, this is interesting. This isn’t really something, actually, I had even thought about until Carolyn mentioned it when were speaking. For example, antianxiety medication. 


If this is medically necessary due to past trauma history, et cetera, the participant will be allowed to continue on that medication. Michigan has legalized recreational and medicinal marijuana. However, no HPRP participant will be allowed to have a positive THC drug screen while in monitoring. The philosophy here is that health professionals are held to a higher standard as a safety sensitive occupation. Also included in that are airline pilots, police officers, attorney, and all healthcare professionals. So while marijuana may be legal, it is not something a healthcare professional should be partaking in. While working as a healthcare professional, if they are invested in its continued use, then they can step down from healthcare work and do something else. That’s the philosophy. And that makes sense. Actually, after she said it makes perfect sense. I know that’s something that you see on the forums. How do you handle marijuana if it’s legal in your state? 


So that’s the philosophy that Michigan has. At least their HPRP program does. Because THC can stay in the system for up to 30 days. And until there’s improved refinement on drug testing, the safety sensitive occupations just have to refrain from its use. Everyone who graduates compliantly from the program has to write a relapse prevention plan. Part of that is a statement of what they have learned. And I want to end this podcast reading some of those statements for you. So here’s what some of their participants had to say. I know you hear nothing but complaints, but I really want to pass along to the team that I thank everybody. I’m a strong advocate for this program. It has saved my life, my license, and my job. In fact, because of this program, I have advanced in my job. I’m looking forward to my life, my grandkids, my retirement. 


That is what this program has allowed me to do, to look forward to these things. I thank everybody who has helped me along the way. Without it, I wouldn’t have been able to keep anything. We are very fortunate as healthcare professionals to have you. I have always advocated in my HPRP group for people to hang in there, give it time. We all have hard jobs, but your job is very hard. And I know you guys take the brunt of a lot of things, but we are very fortunate to have you. Another person shared. Some may think that relapse is a bad thing. In my case, I consider my relapse of 2020 a life-saving event. I was set to complete HPRP in May of 2020. Due to my relapse, I was required to participate two more years in HPRP. It was because of this extra time that I was motivated to dig deeper into my emotional well-being. 


With the help of my entire team, I was diagnosed with bipolar disorder. Once I accepted the diagnosis and began treatment, my life has changed dramatically for the better and with my addiction recovery, my mental health and well-being is of paramount importance. I pay close attention to how I feel. This was not easy. Initially, I was pretty well disconnected from my feelings. After years of abusing my mind, body and spirit with alcohol and cocaine, I am now able to recognize the warning signs of emotional decline. In the past, when I got down emotionally, I felt as though life was crashing all around me and there was no hope. Ultimately, making my decision to relapse that much easier. Now I understand that these emotional declines are part of my disease. They are not permanent and that time and strategies can help alleviate these feelings. The actions I take are to consider my thoughts. 


Are they rational? Are they the best interest of myself and those around me? I consult understanding members of my family and discuss these feelings with my therapist and psychiatrist. My emotional well-being is instrumental in maintaining a successful and happy life. Sobriety can’t exist without emotional well-being and emotional well-being can’t exist without sobriety. They are intertwined. They are my life now. And one more. I am completing my second three-year monitoring agreement in HPRP for depression and alcohol abuse. Essentially, I’ve spent 10% of my life in the HPRP program. In one sense, that seems a sad reflection of my life. However, I truly believe I would have continued to deteriorate without this program and would have spiraled downward to even lower depths of despair. Also, my participation in the program was self-initiated as I self-reported and reached out for help because my life had become an unimaginable nightmare. 


There is so much I regret, but I am proud to be completing the program with a 100% clean slate and remain completely sober for over three years. As the Serenity Prayer says, I can’t change the past but must have the courage to move forward and try to improve myself. Every day now, I face a new challenge to continue my recovery and maintain sobriety and positive mental health as I leave the program. So these are some great Testimonials of Michigan’s program. I do think after discussing things with Caroline, that they really do have a solid program and their goal really is to give every participant every opportunity to be successful. And so they give them that latitude and they give them those tools that they need. And I think I forgot to mention actually that the participant does need to pay for these services. Another good reason to consider keeping them employed so they can utilize that insurance so it’s not an out-of-pocket thing. 


And of course, if they maintain employment, which is encouraged, then they truly are employed and maintaining that insurance to help pay for these things. But the participant does need to pay for these things. All right, that’s it. If anybody has any comments on the program or has worked with the Michigan program and has anything that they would like to share, then please do so. And I want to thank you all for listening. Please hit the subscribe button. I also want to thank our sponsor for today IMI, the manufacturer of the industry leading prep log line of tamper evident caps, which indeed are an active deterrent to diversion, as well as a product that sort serves to safeguard the sterility and integrity of medications. Learn more at imiweb.com.

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Terri Vidals

Terri has been a pharmacist for over 30 years and is a drug diversion mitigation and monitoring subject matter expert. Her years of experience in various roles within hospital pharmacy have given her real-world insight into risk, compliance, and regulatory requirements, as well as best practices for medication and patient safety.

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