My Preliminary Position on CMH Transition.

Based on the information currently available, I do not support proceeding with the conversion of Ottawa County Community Mental Health from a county department to an independent authority at this time. This position is based on the following:

• The risk driving this proposal is theoretical, not demonstrated.
  Neither Ottawa County, nor any other Michigan County, have ever been required to use general fund dollars to cover CMH deficits. Likewise, no statute, appellate court decision (including Muskegon), or Attorney General opinion clearly establishes that counties are legally required to backstop CMH deficits with general fund dollars. The asserted financial risk is therefore speculative rather than evidenced.

• The promised ‘liability separation’ is likely illusory regardless.
  The authority model meaningfully insulates the county only if the county is willing to allow the authority to fail. Given the essential nature of CMH services, political and moral reality makes non-intervention implausible. Statutory mandastes likewise prevent us from allowing that to occur. If the county intervenes in a crisis, —as it almost certainly would—the practical separation collapses, undermining the central rationale for conversion.

• Actual known risks have been entirely downplayed. The Authority model severs multiple critical accountability mechanisms: elected commissioners lose budget approval authority, direct reporting lines are cut, public oversight becomes more attenuated, and citizens lose the ability to hold decision-makers accountable at the ballot box. We will have traded day-to-day visibility and the ability to course-correct before small problems become crises—all for theoretical protection from a risk that has never materialized. For an essential safety-net service serving our most vulnerable residents, this distance is not a neutral organizational choice—it is a verifiable governance risk.

• Conversion does not resolve the underlying financial challenges. Structural conversion does not address state underfunding, utilization growth, CCBHC/fee-for-service deficits, or PIHP funding dynamics. An authority creates no new revenue and does not compel the state to provide additional funding. The same financial pressures exist under both models—conversion merely relocates and attentuates accountability for managing them.

• There is no demonstrated evidence of improved outcomes. Authority-model CMHSPs have not been shown to deliver better access, outcomes, or financial stability for residents. Conversion may actually increase risks to staff retention, benefits stability, and workforce security—without corresponding service improvements. Our own 2016 study documented these concerns, warning specifically of lost efficiencies, increased costs, and added complexity.

• Conversion increases costs without clear benefits. Conversion requires significant transition costs, eliminates shared-service efficiencies, and creates operational disruption—while offering only theoretical legal protection from risks that have never materialized.

Given that the asserted risk to Ottawa County is speculative and and the promised protections are likely illusory -while the costs and governance risks of conversion are real and demonstrable—conversion to an authority is not currently justified. The burden of proof rests with those advocating for change, and that burden has not been met. A more prudent course is to strengthen financial oversight, internal reserves, and risk management within our existing department model; pursue legislative or Attorney General clarification on liability questions; and evaluate structural change only if future conditions materially change. Incurring real, potentially irreversible costs and risks to address a theoretical problem that has never occurred is not sound policy.