Michigan Medicaid began reimbursing community health worker (CHW) services on January 1, 2024. Michigan CHWs had been doing this work for decades before that date. What changed is that an organization can now be paid for it, provided four things line up: a registry listing, a CHAMPS enrollment, a licensed provider’s recommendation, and a correctly built claim.
A session can be clinically sound and still deny because the CHW was not yet enrolled in CHAMPS on the date of service. This guide follows the order in which those approvals happen, then covers claim construction, limits, documentation, and the denials that show up most often.
What Michigan Medicaid covers for CHW services
The policy is MDHHS bulletin MMP 23-74, effective January 1, 2024. It classifies CHW services as preventive services under 42 CFR 440.130(c), and the bulletin applies directly to fee-for-service Medicaid. Medicaid health plans must cover at least what the bulletin describes and may add to it.
Three service categories are covered:
- Health system navigation and resource coordination, such as helping a beneficiary keep an appointment, find a covered provider, or arrange interpretation.
- Health promotion and education, including coaching and goal-setting for conditions like diabetes, hypertension, and asthma.
- Screening and assessment using standardized, validated tools that do not require a license.
A beneficiary’s need must be assessed with a health risk or social determinants of health screening tools. Qualifying needs include a chronic condition (behavioral health conditions count), an unmet health-related social need, or pregnancy through 12 months postpartum.
The bulletin also lists what does not qualify. Clinical case management that requires a license, transportation, discharge planning, delivery of medications or supplies, companion services, personal care, and respite care are all excluded. A CHW who drives a patient to an appointment has done something useful that Medicaid will not pay for under this policy.
Who can bill: the registry, CHAMPS, and the billing provider
A CHW cannot bill Medicaid alone. The bulletin separates the CHW (the rendering provider) from the entity that submits the claim (the billing provider), and both need active enrollment.
Step 1: NPI and the MI Medicaid CHW registry
The first gate is the MI Medicaid CHW Registry, not CHAMPS. An individual must be registered with MDHHS’s designated contractor before enrolling as a Medicaid provider. That contractor is the Michigan Community Health Worker Alliance (MiCHWA), working with the Michigan Primary Care Association.
The registry criteria in the bulletin:
- Age 18 or older, with a high school diploma or equivalency.
- Completion of an MDHHS-approved CHW training program aligned with the C3 Project core competencies, or the work experience pathway.
- Good standing on the registry, which requires at least six hours of continuing education each year.
The work experience pathway needs a note of caution. The bulletin allowed temporary eligibility for workers with 1,000 hours of experiential learning in the prior three years and a plan to finish training, and it set December 31, 2025 as the deadline for completing an approved program. That date has passed. A CHW who came in through that route should confirm current standing with MiCHWA before billing.
A CHW also needs an individual (Type 1) NPI before moving to the next step.
Step 2: CHAMPS provider enrollment for community health workers
Once the registry verifies a CHW, enrollment in CHAMPS, the state’s Medicaid enrollment and claims system, follows. The CHW completes an online application and enrolls under an individual Type 1 NPI as a rendering/servicing-only provider.
During enrollment the CHW must associate with at least one Medicaid-enrolled billing provider. That billing provider needs a Type 2 group or organizational NPI, or be a sole proprietor with a Type 1 NPI. Employers and contracting organizations can serve as the billing provider.
Most CHAMPS application problems for CHWs trace back to sequence and association:
- Applying before the registry approval is in place.
- Selecting the wrong enrollment type instead of rendering/servicing-only.
- Leaving out the billing provider association, or linking to a billing provider that is not itself enrolled.
- Starting to deliver billable services before the CHAMPS effective date.
The last one cannot be fixed with a rebill. The rendering CHW must be enrolled in CHAMPS on the date of service shown on the claim. If a CHW saw patients for three weeks before enrollment took effect, those dates of service are exposed, and the only route is asking Provider Support whether an earlier effective date is possible.
Step 3: contracting with Michigan Medicaid health plans
Most Michigan Medicaid beneficiaries are enrolled in a managed care plan, so fee-for-service CHAMPS billing covers only part of the population. For members of a Medicaid health plan or integrated care organization, claims go to the plan, and the provider should confirm prior authorization requirements with that plan, since plans may set criteria that differ from the state’s. Priority Health, Meridian, and HAP each run their own provider portals and contracting processes.
Two plans have published CHW guidance that surfaced during research for this article.
- Meridian: Meridian covers CHW services for dates of service on or after January 1, 2024, follows the same 98960, 98961, and 98962 coding, and lets providers trigger a CHW contact by completing a Social Determinants of Health assessment in its provider portal. Its published limits match the state’s: 2 hours per day, 16 visits per month, and 32 hours per month, with prior authorization needed to exceed them. Meridian CHW guidance
- UnitedHealthcare Community Plan: In a 2026 provider notice, the plan reminded FQHCs that CHW claims denied for incorrect data and provider non-enrollment were rising.
Credentialing steps for CHWs as rendering providers on Priority Health and HAP should come from those plans’ provider network teams. A billing organization that serves several plans should keep a one-page matrix per plan covering the contracting entity, portal, prior authorization rules, and claim submission address.
Step 4: billing 98960 to 98962 and the recommendation requirement
The code set is short. 98960 covers one patient, 98961 covers two to four patients, and 98962 covers five to eight patients. Each is reported in 15-minute increments, one increment per unit, and must carry modifier CG to be considered for payment. A group cannot exceed eight beneficiaries.
Every claim also depends on the recommendation requirement, covered in its own section below.
How to bill 98960 in Michigan Medicaid: claim anatomy
A professional claim for CHW services carries these elements:
| Claim element | What goes in it |
|---|---|
| Procedure code | 98960, 98961, or 98962 by group size |
| Modifier | CG on every line |
| Units | One per 15-minute increment of documented service |
| Rendering provider | The CHW, by Type 1 NPI, enrolled in CHAMPS on the date of service |
| Billing provider | The Type 2 organization or Type 1 sole proprietor associated with the CHW |
| Claim note | A claim note code describing need and service type |
| Payer | The member’s Medicaid health plan, or CHAMPS fee-for-service if not enrolled in a plan |
On rates, the January 2024 MDHHS CHW fee schedule listed 98960 with the CG modifier at $10.26. Rates change, so the current fee schedule on the MDHHS provider site is the reference for revenue projections.
One rule the bulletin leaves open is rounding. It states that one 15-minute increment equals one unit but does not describe how to treat a final partial increment. Until a plan says otherwise in writing, the conservative approach is to bill only completed 15-minute increments.
Service limits and when prior authorization applies
The bulletin caps CHW services at 2 hours (8 units) per day and 16 visits per month, up to 32 hours (128 units) per month per beneficiary. Going past those limits requires prior authorization based on medical necessity, determined with the recommending licensed provider. Group services are capped at eight unique beneficiaries, and there are no place-of-service restrictions.
The daily limit catches programs that run long community events. A CHW who spends three hours with one beneficiary across a day can bill only eight units without authorization. Practices with tracking built into the scheduling system catch this before the claim; those without it find out from a remittance.
On telehealth, the 2023 consultation summary records a comment noting that the audio-only fee schedule listed these codes. MDHHS answered that CHW services must be delivered face-to-face. The bulletin points to the Medicaid Provider Manual glossary for the definition of “face-to-face,” which is the place to check before scheduling any remote contact.
Documentation that holds up in an audit
Records must show the date of service, start and end times, a description of the professional services provided, and the source of the licensed provider’s recommendation. They are subject to review and post-payment audit under general Medicaid record-keeping rules.
In practice, a note that survives review usually contains:
- The screening or assessment tool used and the result that established need.
- The recommending provider’s name, credential, and the date of the recommendation.
- Start and end times, matching the units billed.
- What the CHW actually did, written as an activity: “reviewed insulin timing handout and set a goal of logging morning readings three days a week,” not “provided education.”
- The next planned contact or the closing of the episode.
The recommending provider question: is supervision required?
Searches for “supervising provider” and CHW billing return plenty of third-party guides using that phrase. The bulletin itself uses different language and a different rule.
Under the federal regulation cited in the bulletin, a licensed healthcare provider must recommend the CHW services. Qualified recommenders include physicians, physician assistants, advanced practice registered nurses, registered nurses, licensed master social workers, dentists, psychiatrists, and psychologists, among others. The recommending provider does not have to belong to the beneficiary’s healthcare team, though collaboration is encouraged.
So the policy requires a recommendation on file, not direct clinical supervision of the CHW’s daily work. Employers may still impose supervision for their own reasons, and the bulletin separately bars CHWs from delivering services that require a license. The recommendation should be documented before the first billed session.
FQHCs, health homes, and CCBHCs
Clinics that bill on behalf of CHWs follow a different claim path.
FQHCs, RHCs, tribal health centers, and tribal FQHCs are paid for CHW services outside their PPS or all-inclusive rate, at the applicable Medicaid fee screen. CHW services do not count as a qualifying visit. The claim goes on the institutional form under the clinic’s Type 2 NPI, with an eligible Type 1 provider as attending and the CHW’s Type 1 NPI in the rendering field.
The UnitedHealthcare notice adds two practical points for clinics: CHW services should not go on a separate claim when other providers rendered services the same day, and a G04xx code can be billed only if the CHW service accompanies another qualifying visit.
UnitedHealthcare 2026 provider notice
For health homes, CHW services must be separate and distinct from the core services claimed monthly by the health home. For CCBHCs, when CHW costs are folded into the PPS rate, the clinic cannot also seek Medicaid reimbursement for the CHW’s work. A later update, MMP 24-29, clarified that specialty behavioral health providers can use CHWs, with CHW services added to the behavioral health code chart.
Common denials and CHAMPS rendering provider errors
| Problem | Why it happens | How to prevent it |
|---|---|---|
| CHW not enrolled on date of service | Sessions delivered before CHAMPS effective date | Confirm effective date before scheduling billable visits |
| Missing modifier CG | Claim template built from generic 98960 setup | Lock CG into the CHW charge master |
| Wrong payer | Member is in a health plan but claim went to CHAMPS fee-for-service | Check eligibility for plan assignment on each date of service |
| Rendering provider mismatch | Billing entity listed in the rendering field, or an unassociated CHW | Report the enrolled CHW as rendering and verify the billing association |
| Units over limit | More than 8 units in a day, or visit and monthly caps exceeded | Track units per beneficiary per day and per month |
| Separate claim for same-day clinic services | CHW service billed apart from the medical visit | Combine same-day services on one claim where the payer requires it |
| No recommendation on file | Referral never captured, or from an unqualified source | Store the recommendation before the first session |
Claim scenarios
These are illustrative composites built from the policy rules above, not specific client cases.
A routine individual session
A CBO billing under its Type 2 NPI sends a CHW to meet a beneficiary with type 2 diabetes for 45 minutes of education on glucose logging. The claim shows 98960 with CG for three units, the CHW’s NPI as rendering, and claim note C200. The note records start and end times, the screening result, and the name of the nurse practitioner who recommended the service.
A group session
A CHW leads an asthma-in-the-home workshop for six beneficiaries for 60 minutes. Each beneficiary’s claim uses 98962 with CG for four units. The MDHHS fee schedule notes that group codes are billed for each beneficiary who received the service.
A denial that cannot be rebilled
A CHW completes registry approval in March, submits the CHAMPS application in April, and sees Medicaid patients from the first week of April. CHAMPS enrollment is effective in May. Claims for April dates are denied because the CHW was not enrolled. The organization asks Provider Support about the effective date, and in the meantime builds a rule that no Medicaid-billable visit is scheduled until the effective date is confirmed in writing.
A claim sent to the wrong payer
A CHW serves a beneficiary whose coverage shows a Medicaid health plan assignment. The biller submits through CHAMPS. The claim is rejected, and the corrected submission goes to the plan.
When outsourcing CHW billing makes sense
A small CBO with one CHW and a handful of Medicaid beneficiaries can sometimes run this in-house. The workload grows quickly once multiple CHWs, several health plans, and group sessions are involved. The work is mostly administrative sequencing: registry and CHAMPS status tracking, eligibility checks that distinguish fee-for-service from plan-assigned members, unit tracking against daily and monthly caps, claim note codes, and denial follow-up within filing windows. So it's better to outsource to a reliable remote billing partner such as A2Z Billings.
Frequently asked questions
Does Medicaid in Michigan cover services provided by community health workers?
Yes, coverage for CHWs enrolled in CHAMPS and on the MI Medicaid CHW Registry started on January 1, 2024, per MMP 23-74.
Which CPT codes are billed by CHWs in Michigan?
98960 per 15 minutes for one beneficiary, 98961 for two to four, and 98962 for five to eight, all with the CG modifier.
Is CG a necessary modifier?
Indeed. According to the notice, codes must have CG in order to be eligible for payment.
Does a CHW require both an NPI and CHAMPS enrollment?
Indeed. The CHW joins a billing provider and registers as a rendering/servicing-only provider with a Type 1 NPI.
Is it possible for a community-based organization to bill its CHWs?
A billing provider must be enrolled in CHAMPS and have either a Type 2 NPI or a Type 1 NPI for sole proprietors. The present situation should be verified with Provider Support as CBO enrollment alternatives were still developing in 2023.
What are the service limitations?
Each beneficiary may get up to 128 units per month, 16 visits per month, and eight units per day, with prior authorization.
Who is able to suggest CHW services?
Among the licensed providers are doctors, physician assistants, registered nurses, advanced practice registered nurses, dentists, psychologists, psychiatrists, and licensed master social workers.
Is it necessary to have a supervisory provider?
The bulletin calls for the suggestion of a licensed provider rather than direct oversight. Employers may add their own supervision.
Is it possible to conduct CHW sessions over the phone?
According to MDHHS, CHW services have to be provided in person. That phrase is defined in the lexicon of the Medicaid Provider Manual.
Where do Medicaid health plan members' claims end up?
to the strategy. Only beneficiaries who are not enrolled in a plan are eligible for fee-for-service CHAMPS.
What is the required amount of continuous education for a CHW?
Six hours annually through a program that is in line with the C3 core competencies and has been authorized by MDHHS.
Where can I find information on HAP CHW or Priority Health credentialing?
Since MMP 23-74 leaves plan procedures and prior authorization requirements to the plans, these can be found in each plan's provider portal or through the provider network team.