October 2, 2002
Mr. Carl Beck
Office of Mental Retardation
PO Box 2675
Harrisburg, PA 17105
Dear Carl,
The Pennsylvania Community Providers Association, representing providers of both Mental Health and Mental Retardation services and supports, appreciates this opportunity to provide comments on the joint Office of Mental Health and Substance Abuse Services and Office of Mental Retardation draft Bulletin.
We were pleased that the two offices were able to issue this joint bulletin. This type of state leadership must exist in the MH/MR system in order to enable local leadership to appropriately address the needs of persons with the dual diagnoses of mental retardation and mental illness. Many PCPA members have served people with these needs for a long time and it has often been difficult to resolve resource issues at the county level. The consumers with these dual and difficult needs sometimes suffer due to a lack of expertise or funding.
There is a concern that funding is not addressed at all in the bulletin. You and other staff in OMR certainly are aware of the cost of services for people with this dual diagnosis. Development of current and new resources is encouraged in the bulletin but this must be followed with funding for the counties and providers of services and supports. We encourage OMR and OMHSAS to present the needs of these individuals within their funding request to the Governor for Fiscal Year 2003-2004. Also, we have heard that the 33 CHIPPS beds available in the current fiscal year may be considered for those with the MH and MR diagnosis. We encourage you to explore this option. These beds can be used as an opportunity for creative pilot projects that will help strengthen Pennsylvania's ability to provide these individuals with quality services and supports.
The bulletin uses the term "Serious Mental Illness," which addresses only OMHSAS' adult priority group. We believe that there must be coordination of county services regardless of the level of mental illness. Since there is no funding for the bulletin's requirements, the bulletin should address all levels of mental illness that are combined with an MR diagnosis, rather than ignore the people who have both mental illness, but not "serious" mental illness, and mental retardation.
On the second page of the bulletin, the County MH/MR Programs are required to designate "either the mental health or the mental retardation program as the lead in the coordination of services for each specific person and determining payment responsibilities." Counties have tried to do this in various ways. The bulletin should offer guidelines for how this can be done. The statement and its intent are good, but nothing is resolved if there are no recommended mechanics for getting the work done.
The development and recruitment of MH and MR providers who can successfully support persons with this dual diagnosis is definitely needed. There must also be regulations and funding streams that allow consumers to easily move between providers and systems. This will be beneficial both to the consumers who would have additional choices and to providers who could have simpler methods of expanding services into another system. Providers often see the movement into a whole new set of regulations and billing systems as a financial risk that cannot be overcome. Perhaps as H Net is enhanced, there will be more commonalities between the systems.
Some people who have both mental retardation and mental illness also have problems with substance abuse. This is not mentioned in the draft bulletin. There is only one question pertaining to a history of substance abuse in the sample questionnaire. The systems need to do more work on coordination of services for all of these diagnoses.
The regional offices, as described in this bulletin, are to provide staff assistance and monitoring to the County MH/MR Programs. The regional offices should have a more fully described role that makes it clear they are to monitor and assure county coordination of MH and MR services for individuals with these co-occurring disorders. (It should also be included in the existing approach to OMR Monitoring of Counties.) This could provide a more consistent statewide approach to coordination problems and turf battles.
We also suggest that the bulletin clearly define the need for coordination of services for people residing in the full range of living environments, from independent living arrangements to residential living. People's needs for coordination are the same no matter where they live.
The recommendation for use of a comprehensive review tool is appreciated. Some PCPA members have used a version of the tool attached to the bulletin and find it beneficial. We appreciate the flexibility you exhibit by recommending the tool, rather than requiring the use of this specific one.
We applaud the inclusion of a reference to the OMHSAS Community Support Plan and the OMR Everyday Lives document. Our community providers fully understand the value of people living and working in their communities. Some of them would be willing to share their experiences with OMR and OMHSAS and to invite Commonwealth staff to visit their agencies, to further demonstrate both the positive aspects of community services and supports and the concomitant complications and costs.
Again, we appreciate this opportunity to provide input into the development of the Mental Health and Substance Abuse Services and Mental Retardation Bulletin. Please contact Lynn Keltz if you have questions or would like further clarification of our comments.
Sincerely,
George Kimes
Executive Director