Attachment 2 Individual Copies of Public Comments

STATE OF ALABAMA

DEPARTMENT OF MENTAL HEALTH
AND MENTAL RETARDATION
RS A UNI ON BU I LDING
100 N. UNION ST REET
POST OFFICE B OX 301 410
MONTGOMERY, ALABAMA 36130-1410
B
O
B
RILEY
GOVERNOR

JOHN M. HOUSTON
COMMISSIONER

May 1, 2007
I-rA'614
Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
I am writing in response to the publication of the draft guidance for submission of the Mental
Health Services Block Grant application. The Alabama Department of Mental Health and
Mental Retardation has undertaken a number of transformation activities that can be incorporated
into the narrative and goals of the application as indicated in the revised guidance. However,
reporting State as well as Block Grant expenditures for each transformation activity exceeds
the scope of the Block Grant requirements and represents an undue reporting burden on states. We
respectfully request that the language regarding expenditures be stricken from the final guidance.
Sincerely,

AJl

J
Ho ton
Commissioner
JMH/mb
c: NASMHPD

DEPARTMENT OF HUMAN SERVICES
DIVISION OF MENTAL HEALTH
Hillsview Properties Plaza, East Highway 34
c% 500 East Capitol
Pierre, South Dakota 57501-5070
Phone: (605) 773-5991
FAX: (605) 773-7076

TTY: (605) 773-5990

www.state.sd.us/dhs

May 2, 2007
Summer King
Reports Clearance Officer
SAMHSA
One Choke Cherry Road, Room 7-1044
Rockville, MD 20857
Re: E7-5796 Federal Register Notice: Community Mental Health Services Block Grant Application and
Guidance
Dear Ms. King:
This correspondence is regarding the request for comments on Federal Register Notice E75796, Agency
Information Collection Activities: Proposed Collection, Community Mental Health Services Block Grant
Application and Guidance. I have reviewed the draft CMHS Block Grant application and would like to
take this opportunity to share my concerns with the FY2008-2010 guidance and application process,
specifically regarding Table 4: Transformation Expenditure Reporting Form.
The South Dakota Division of Mental Health (DMH) believes that the integration of mental health
transformation is essential in crafting positive outcomes for the people of South Dakota. The DMH receives a
minimum amount in Block Grant funds per year (approximately $878,000). South Dakota uses our entire
Block Grant to fund direct services to children with serious emotional disturbances, adults with severe and
persistent mental illnesses, and adults with co-occurring substance abuse/mental health diagnoses. It would
be extremely difficult and burdensome for the DMH to report for each state transformation activity area
listed in Table 4. Additionally, the DMH does not feel that Table 4 is necessary or practical for a state like
South Dakota where there is no additional money to be utilized for direct funding of transformational
activities. While the DMH cannot quantify in expenditures the funding for each area listed in Table 4, our
current State Plan performance indicators do show progress in many areas related to transformational
activities (supporting individualized plans of care, improving coordination of care among multiple systems,
provision of evidence based practices, improving consumer access to employment and affordable housing,
etc.). The DMH does not feel Table 4 would provide a true representation of the efforts towards
transformation in the planning and delivery of community mental health services in South Dakota.

Page 2
May 2, 2007

The DMH works very closely with community mental health centers and the Mental Health Advisory
Council to develop recovery-oriented and consumer driven services for individuals receiving assistance
from the community mental health system. In addition, the DMH works within a Systems of Care Steering
Committee comprised of the eleven community mental health centers, the Department of Human Services,
the Department of Corrections, Unified Judicial Systems, the Department of Social Services, and the
Department of Education to address many of the items referenced in Table 4. Through these collaborative
relationships it is clear that all of the stakeholders involved find consumer driven, recovery-oriented
services a priority. South Dakota has taken many strides in the transformation of community mental health
services and the coordination of care among multiple systems, without having the benefit of flexible funding
to support specific transformation activities.
Thank you for the opportunity to comment on the proposed Block Grant application and guidance, and for
taking our concerns under consideration during the approval process with OMB.
Sincerely,

Amy ersen-Pollreisz
Director

Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
This letter is in response to the Federal Register Notice on the FY 2008-2010 Mental Health Block Grant
Guidance and Instructions of March 29, 2007. The guidance outlined four proposed changes:
Proposed revisions to the guidance include:
(1) The integration of mental health transformation as a guiding principle in the development of State
mental health plans.
(2) The introduction of the Web Block Grant Application System (WebBGAS).
(3) A requirement for States to report nine CMHS National Outcome Measures (NOMS) for mental health,
including: Increased access to services; Reduced utilization of psychiatric inpatient beds for 30 and 180
days; Number of evidenced-based practices and number of persons served in these programs; Client
perception of care; Increased/retained employment or returned to/stayed in school; Decreased criminal
justice involvement; Increased stability in housing; Increased social supports and social connectedness;
and Improved level of functioning.
(4) Revisions to tables in the Uniform Reporting System (URS), including one major proposed change of
adding a table on “Social Connectedness and Improved Functioning”.
The revisions are a result of years of work between CMHS, the States and the Congress in order to quantitatively
justify the desired results received (effective treatment of mental illness) in order to continue funding of this
federal grant program. There has been much qualitative data available but there is a need and demand to validate
results.
The 1st proposal to integrate transformation is identified in the President’s New Freedom Commission Report.
This is an activity Arizona can easily report on. Transformation is a broad definition that encompasses many
initiatives this state is currently involved in.
The 2nd proposal is to encourage States to use the WebBGas for this year’s application of the grant. Arizona is
familiar with WebBGas and it would not present an issue for submission.
The 3rd proposal is the increase in the number of National Outcome Measures (NOMS) States must report on
from four to nine, with two NOMS still under development at SAMHSA. Arizona has been able to report on the
required four NOMS as well as three optional NOMS in its past applications.
The 4th proposal identifies revisions proposed through the work of the Data Infrastructure Grant (DIG) by
CMHS, in collaboration with the States. There is only one major revision, which is to add a new table, “Social
Connectedness and Improved Functioning” as one of SAMHSA’s new NOMS. Arizona may have to include
new ways to capture this data through its Independent Case File Review, Consumer Satisfaction Survey, etc.

Thank you for your consideration.
Sincerely,

Christina Dye
Chief

May 10, 2007J
Florida
Additional comments from Senyoni

1.
Integration of mental health transformation as a
guiding principle in
the development of the plan
States that did not get the SAMHSA transformation
grant award should
not be held accountable and therefore not penalized in
any way (such
as a delay in approving the block grant application or
a return of the
application as incomplete) for failure to show
substantial progress in
its transformation efforts. SAMHSA should be pleased
with states that
are making the substantial leap forward without
benefit of federal
funding support or federal technical assistance - such
as the states
that were fortunate enough to obtain a transformation
grant award.
Unfunded states should not be held to the same
standard as those
states who received an infusion of funding and
technical assistance
for this effort. There is no indication in the
instructions that
there are varying standards or expectations.
2.
Introduction of the Web Block Grant Application
System (WebBGAS)
States are required to submit the grant applications
electronically
using the WebBGAS input screens. However, the
instructions do not
specify how pages requiring signatures (e.g.,
Certifications,
Assurances, etc.) will be submitted. Should these
pages be scanned and
submitted separately? If so, will SAMHSA accept
scanned signatures

rather than the original signatures? For example, the
PATH grant
encourages electronic submission but will not accept
scanned
signatures. Therefore, if this is not the case, what
is the savings
in paper and time? The instructions or the federal
notice should
reference the issue of accepting scanned signatures.
3.

Requirement for states to report nine NOMS.
At least two of the nine NOMS are still under
development and,
therefore, it is difficult for States to collect and
report data on
these ill-defined measures. It is recommended that the
States be held
accountable only for measures that are well defined
and developed.
=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=Sen-Yoni Musingo, Ph.D.
Voice: 850-413-7171
email: [email protected]
CONFIDENTIALITY NOTICE: This message and any attachments
are for the sole use of the intended recipient(s) and may
contain confidential and privileged information that is
exempt from public disclosure. Any unauthorized review,
use, disclosure, or distribution is prohibited. If you
have received this message in error please contact the
sender (by phone or reply electronic mail) and then destroy
all copies of the original message.

Georgia’s Comments on MHBG Guidance and Instructions for FY 2008-2010
The MHBG Guidance and Instructions for FY 2008-2010 is clearer and easier to follow
than that of previous years. However, some of the new expectations that are included for
this cycle may present significant challenges to states. The most significant additions are:
¾ The requirement for state transformation efforts to be described and integrated
throughout the plans for adults and children and for there to be at least one
specific mental health transformation outcome measure and performance indicator
related to the measure – true transformation efforts should include ways in which
the multiple state agencies with mental health related services and funding are
collaborating and coordinating activities and this is not always possible in states
that do not have the infrastructure development grants and the staffing that is
designated to facilitate these activities
¾ The reporting of state and Block Grant expenditures for transformation activities
– this table may be challenging to states to report as funding and expenditures are
not likely to be captured in state accounting systems in a way that will readily
conform to the table
¾ The requirement to describe community-based services provided to older adults in
Criterion 4 – this will be especially challenging for states that have not developed
specialized programs for older adults and serve them only through the standard
adult service arrays
¾ The requirement to report on all 9 NOMS, even though NOMS 8 and 9 are still in
development – it will be difficult to establish indicators and targets when the
measures are yet to be determined

Summer King
Survey Statistician/
OMB Clearance Officer
SAMHSA/OAS
Room 7-1045
1 Choke Cherry Road
Rockville, MD 20850
Phone: 240-276-1243
Fax: 240-276-1260
-----Original Message----From: Shelly Ogata [mailto:[email protected]]
Sent: Wednesday, April 04, 2007 5:16 PM
To: King, Summer (SAMHSA/OAS)
Cc: Baldwin, Deborah (SAMHSA/CMHS)
Subject: RE: FW: Federal Register Notice for the MHBG
Guidance and Instructions FY 2008-2
Aloha Summer and Deborah,
For Hawaii, which has separate adults' and children's
systems, the total burden hours is doubled.
For the plan (Parts B and C) and for the implementation
report (Part D), both AMHD and CAMHD spend time gathering
the information from different places/people and writing up
the plan, and our administration has to read both plans &
reports. For the Data Tables (Part E), AMHD and CAMHD
spend time to run separate analyses of their own
populations.
Second comment would be that submitting applications/plans
and implementation reports electronically through WebBGAS
does NOT reduce the burden of paperwork since we still have
to prepare the same on paper in order for it to be approved
and signed off by our Director and Governor. In fact,
WebBGAS increases the time spent on submission since one
has to learn to use the system, then has to enter the data
in the tables (from what I was told, it's not just a Word
document upload; you have to go into the tables and reenter the data).
Please feel free to contact me if you need further
clarification or if you have any questions.

Thank you for the opportunity to provide comment, Shelly
Ogata State Council Chairperson
----Original Message Follows---From: "Baldwin, Deborah (SAMHSA/CMHS)"

To:
[email protected],[email protected],sharonra@ppbhg
.org,[email protected],[email protected],jack.wood@cata
wba.dmhmrsas.virginia.gov,[email protected],[email protected],
[email protected],[email protected],ahschmook@
aol.com,[email protected],[email protected],[email protected],jef
[email protected],[email protected],[email protected]
et,[email protected],[email protected],davesanders@wvmhca.
org,[email protected],[email protected],timothy.loft
[email protected],[email protected],[email protected],p
[email protected],[email protected],[email protected],jrma
[email protected],[email protected],[email protected],petraclemens@yahoo
.com,[email protected],[email protected],ripleyne@
hotmail.com,[email protected],[email protected],mike_halligan@t
mhc.org,[email protected],[email protected],mrwat
[email protected],[email protected],[email protected],pm
[email protected],[email protected],[email protected],cat
[email protected],[email protected],[email protected],JJay
@mhasc.org,[email protected],[email protected]
,[email protected],[email protected],[email protected]
rg,[email protected],[email protected],kholsopple@vf
fcmh.org,[email protected],[email protected],be
[email protected],[email protected],[email protected],bwellard
@thechildcenter.org
CC: "Cheek, Mattie C. (SAMHSA/CMHS)"
,"DiGeronimo, Richard
(SAMHSA/CMHS)"
,"Morrow, Jim
(SAMHSA/CMHS)"
,"Morrow, John (SAMHSA/CMHS)"
,"Armstrong, Karen
(SAMHSA/CMHS)"
,"Miller, Jeanette
(SAMHSA/CMHS)"
,"Stevenson, Rasheda
(SAMHSA/CMHS)"
,"Smith, Antoine S.
(SAMHSA/CMHS/DSCSD/SPSDB)","J
oseph, Herbert M.

(SAMHSA/CMHS)" ,"Wehelie,
Abdi (SAMHSA/OA)"
,"Baldwin, Deborah
(SAMHSA/CMHS)"

Subject: FW: Federal Register Notice for the MHBG Guidance
and Instructions FY 2008-2010
Date: Wed, 4 Apr 2007 10:17:25 -0400

Please see the attached draft copy of the MHBG Guidance for
your review.
Please send comments by COB Friday, May 4, 2007, to
[email protected] and carbon copy me at
[email protected]. You may send a signed
letter by regular
mail to the address noted in the Federal Register Notice.

-----Original Message----From: Baldwin, Deborah (SAMHSA/CMHS)
Sent: Wednesday, April 04, 2007 9:55 AM
To: 'Hudgens, John'; '[email protected]';
'[email protected]'; '[email protected]'
Cc: King, Summer (SAMHSA/OAS)
Subject: RE: Federal Register Notice for the MHBG Guidance
and
Instructions FY 2008-2010

----Original Message Follows---From: "Hudgens, John"
To: "King, Summer (SAMHSA/OAS)"

CC: "Baldwin, Deborah (SAMHSA/CMHS)"

Subject: RE: Federal Register Notice for the MHBG Guidance
and Instructions
FY 2008-2010
Date: Tue, 3 Apr 2007 23:25:47 -0400

Please provide a copy of the guidance related to the
proposed revisions to
the Mental Health Block Grant program. Thank you for
forwarding the
requested item to [email protected].
________________________________
From: Baldwin, Deborah (SAMHSA/CMHS)
[mailto:[email protected]]
Sent: Tue 4/3/2007 4:07 PM
To: [email protected]; [email protected];
[email protected];
[email protected]; [email protected];
[email protected];
[email protected]; [email protected];
[email protected];
[email protected]; [email protected];
[email protected]; [email protected];
[email protected];
[email protected]; [email protected];
[email protected];
[email protected]; [email protected];
[email protected]; [email protected];
[email protected]; Hudgens, John;
[email protected];
[email protected]; [email protected];
[email protected];
[email protected];
[email protected];
[email protected]; [email protected]; [email protected];
[email protected]; [email protected];
[email protected];
[email protected];
[email protected]; [email protected]
Subject: Federal Register Notice for the MHBG Guidance and
Instructions FY
2008-2010

The MHBG Program requests your review of the attached FRN
for the FY
2008-2010 Guidance and Instructions. As in the past, the
Program notifies
MHBG stakeholders of the publication notice and encourages
comments on the

draft guidance.
Your request for a copy of the guidance
and written
comments should be forwarded as soon as possible to Summer
King, SAMHSA
Reports Clearance Officer, Room 7-1044, One Choke Cherry
Road, Rockville, MD
20857.

Please feel free to contact me with your questions.

Deborah Baldwin, MPA
Public Health Analyst
Center for Mental Health Services
Division of State & Community Systems Development
One Choke Cherry Road
Rockville, Maryland 20857
Office: (240) 276-1752
Fax: (240) 276-1770
[email protected]

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Rod R. Blagojevich, Governor

160 North LaSalle • Chicago, Illinois 60601

Carol L. Adams, Ph.D., Secretary

May 25, 2007

Ms. Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, Maryland 20857

Dear Ms. King,
I am writing this letter on behalf of the Illinois Department of Human Services Division of
Mental Health to comment on the Community Mental Health Block Grant Application Guidance
and Instructions for FY 2008 - FY 2010. My comments will focus on two specific areas: (1)
reporting of expenditures related to transformation activities and (2) the proposed state client
level initiative project.
Reporting of Transformation Related Expenditures
The FY 2008 to FY 2010 Block Grant Guidance incorporates requirements to report on
transformation activities within the specific block grant criterion to which they relate. This in
itself is not problematic as the Illinois Division of Mental Health is engaged in many
transformative activities, and as such welcomes the opportunity to highlight these activities. The
aspect of reporting that is problematic is the additional requirement to complete Table 4 which is
entitled: FY2008 – FY 2010 MHBG Transformation Expenditure Reporting Form. Table 4
would require that Illinois track expenditures for up to twenty (20) specific activity categories.
The Illinois DMH does not currently track the allocation of block grant dollars at this level of
specificity, and to do so would place an undue burden on state fiscal staff. We therefore request
that Table 4 be eliminated from the reporting requirements for the Mental Health Block Grant.
State Client Level Initiative Project
The FY 2008 – FY 2010 Block Grant Guidance and Instructions describes the intent of
SAMHSA to implement a State Client Level Initiative Project to test the feasibility of
implementing client level reporting in the states. While states have a need for detailed data with
regard to the consumers on whose behalf services are purchased, we question the need for such
detailed information to flow to the Federal level. Illinois currently generates more than one
million records related to service provision and consumer information on an annual basis. How

would this information be used at the Federal level? The states have been working with the
Mental Health Statistics Improvement Program (MHSIP), the National Association of State
Mental Health Directors Research Institute (NRI) and others over many years to develop data
standards, however there is still great variability in the ways in which the states define the data
elements that they collect. One has only to review the work initiated under the Data
Infrastructure Grants (DIG) funded by SAMHSA CMHS over the past six years and the variety
of footnotes related to reporting under the DIGs to appreciate the extent to which such variability
exists. Although great progress has been made on standardizing the DIG data elements,
operational definitions and reporting for the Uniform Reporting System (URS) tables, it has
taken a great deal of time for this to occur. Now imagine this process for additional data
elements across all fifty states and the United States Territories. How will the millions of
records generated via the state client level project be aggregated and utilized in a meaningful
way? Of what value will this be to the states and the consumers and families on whose behalf
mental health services are purchased? We suggest that the focus remain on key performance
measures and indicators that relate to recovery, quality and the effectiveness of mental health
services.
Thank you for the opportunity to comment on the proposed changes to the Community Mental
Health Block Grant Application. Should you require additional information or clarification,
please do not hesitate to contact me. I can be reached via e-mail at [email protected] or
via telephone at (312) 814-4948.
Sincerely,

Mary E. Smith, Ph.D.
Chief, Strategic Planning, Evaluation and
System Analysis
Acting Chief, Decision Support
Division of Mental Health

Cc:

Lorrie Rickman-Jones, Ph.D.
Director, Division of Mental Health
Robert Glover, Ph.D.
Executive Director
National Association of State Mental
Health Program Directors

Michigan
Comments on the DRAFT Community Mental Health Services Block Grant Application
Guidance and Instructions FY 2008-2010
Thank you very much for the opportunity to provide feedback on the draft guidance.
We appreciate the increased emphasis on mental health system transformation. In
Michigan, the movement of the entire system has been greatly assisted by the ability to
use mental health block grant funds to support the implementation of evidence-based
practices and other promising practices.
The only major problem we note with the draft is Table 4. We don’t and would not be
able to meaningfully account for costs by many of these 19 (plus “other”) activities. The
transformation activities listed are largely underlying expectations of many services we
provide. Many of them overlap within services and just cannot be broken out as
proposed the draft table.
For example, we may have a Co-occurring Disorder: Integrated Dual Disorder Treatment
(activity 5 and activity 9) program within and Assertive Community Treatment Program
(activity 9) that works to improve coordination of care among multiple systems (activity
1), provides culturally competent services (activity 2), involves consumers and families
fully in orienting the MH system toward recovery (activity 3), improves consumer access
to employment and affordable housing (activity 8), supports individualized plans of care
for consumers (activity 11), has a peer specialist on the team (activity 12), and links with
primary care (activity 13). This same program could also support reduction of stigma
(activity 17), have electronic health records (activity 7), and so on.
There are a myriad of such combinations and neither a math formula to attribute shares
for each activity makes sense, nor, reporting all costs for eleven (as this case) different
activities make sense.
In Michigan, most of our mental health block grants funds is being used on
transformation activities. Some of it is awarded based on proposals submitted by
regional agencies in response to the state’s annual Request for Proposals. What is
submitted is based on locally and regionally determined need. Consumer participation in
this process is required. The state could not say in advance exactly which categories of
services will be requested or awarded (based on the recommendations of review panels
which includes consumers). We are able to report for each year what kinds of services
the block grant was used to support.
Our department also manages state general and restricted funds, other grant program
funds, and Medicaid funding. Medicaid funds are distributed on a capitated basis to
regional health plans. Service encounters are reported into a statewide data system and
numbers of services (as defined by the state) can be reported. Cost reports, which are
completed after the end of each fiscal year, show totals amounts of Medicaid spent on
Medicaid service categories. This information doesn’t lead to the requested numbers in

draft Table 4. Limited subsets of some of the information could be provided (after, not
before) each year, such as the amount spent on Assertive Community Treatment.
In summary, expenditures are not planned or tracked by most of these categories and the
state would not be able to provide meaningful dollar amounts for Table 4, although we
are supporting the activities throughout the system.

DEPARTMENT OF MENTAL HEALTH
State of Mississippi
1101 Robert E. Lee Building
239 North Lamar Street
Jackson, Mississippi 39201

(601) 359-1288
FAX (601) 359-6295
TDD (601) 359-6230

Edwin C. LeGrand III - Executive Director

May 16, 2007
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, MD 20857
RE: Comments and request for clarifications to Department of Health and Human Services,
SAMHSA Agency Information Collection Activities: Proposed Collection and
related Community Mental Health Services Block Grant Guidance and Instructions, FY
2008-2010
Dear Ms. King:
Thank you for the opportunity to submit these comments about the Draft Community
Services Block Grant Application Guidance and Instructions, FY 2008-2010 that are
referenced in the Federal Register Notice of March 29, 2007, vol. 72, no. 60. (Specific notice
referenced dated March 23, 2007). Comments/requests for clarification are referenced to
the page number of the Draft Application Guidance as currently proposed. The majority of
the comments pertain to the related parts of the Draft Guidance, as follows:
.p. 14: "In FY 2008, States will be asked to report Block Grant and State funding for
transformation activities in Table 4," and,
p. 34: "States are required to identify at least one state-specific mental health
transformation outcome measure and to report a performance indicator related to the
measure. State specific transformation performance indicator(s) shall be constructed
according to the guidance provided in this document and should be labeled as
transformation outcome measures."
Additionally, the wording of the text on p. 24 seems to indicate that states can select the
"specific mental health transformation outcome measure"; however, the Draft Guidance

goes on to add on p. 32 as a requirement 19 specific activities by funding source (federal block
grant or state funding) to be addressed under Criterion 5: "Identifies transformation
expenditures by Mental Health Block Grant funding and other State funding sources.
(Table 4)."
On p. 33, Table 4 lists 19 "State Transformation Activities" and a space for "other
activity," and as noted previously (on p. 14), the Draft Guidance indicates that states
"will be asked to report Block Grant and State funding for transformation activities in
Table 4" in several places.
Several points are unclear and of concern:
Data is not currently available to report on all of the 19 transformation activities as they are
listed in Table 4 on p. 33. Mississippi can continue to report how CMHS Block Grant funds
are expended, as in previous years and as called for in Criterion 5 in federal state plan
requirements; however, we would have significant difficulty reporting expenditures for all of
the activities as presented in the Table 4 format. Although a few of the activities listed reflect
the same topics addressed in the URS/NOMs measures, most would involve additional data
definitions and information management system changes to report. Even for a topic
currently addressed in the URS/NOMs, reporting in the proposed Table 4 format changes
the reporting parameters/requirements and therefore, would require further adapting data
systems, which will take time and resources.
Although Table 4 does include an "other activity" category, its otherwise prescriptive format
appears inconsistent with the intent of the block grant, that is, to provide states with flexibility
in use of block grant funds. As noted in Mississippi's State Plan, the goals of the Mississippi
Department of Mental Health are consistent with those reflected in the New Freedom
Commission on Mental Health, and our agency is committed to system transformation.
Regarding the mental health transformation outcome measures, it is unclear the extent to
which states will continue to have the flexibility to select and focus on transformation
activities that are most appropriate to local and state needs and to the stage of-their individual
system development. How this issue is approached will also impact the role of the state
Planning Council in working with the state agency to identify and set priorities. In many
cases, transformation initiatives, such as the provision of culturally competent services and
incorporation of a person-centered planning approach (which supports individualized plans of
care), are intentionally designed to be integrated across services, including some services
that are also listed in Table 4 as transformation activities (e.g., services for co-occurring
mental and substance abuse disorders). This integration of transformation activities is
necessary to achieve systems change, both within organizational cultures and in direct service
practices, but would also make it difficult to track the exact costs by funding source of those
specific activities as currently listed in Table 4. Having continued flexibility in use of CMHS
Block Grant funds facilitates the state's efforts to support transformation activities as they
evolve and to better use funds as appropriate to its status and needs within a broader systems
change context.

We also request clarification of some additional details within the Draft Guidance
document, as follows:
In Table 6 on page 36 of the Draft Guidance, NOMs 2, 3, and 4 are marked with an asterisk (*),
followed by a footnote regarding how states respond if they do not have data available to
construct a particular NOMS indicator at the time of the report, that is, they are to indicate
current capacity for reporting, as well as efforts and a target date projected for reporting of
measures on which work continues. We request clarification regarding whether or not this
provision will continue to apply to all NOMs (not just the three noted by an asterisk in the
current Draft Guidance), which is necessary to be consistent with ongoing data infrastructure
development and quality activities that are projected within a realistic and feasible timeframe.
On page 37, in the last paragraph and as indicated in the Performance Indicator Table for the
State Plan that follows on page 38, the Draft Guidance states that "For each indicator,
States must show the data for the past two years (to the extent that it is available), and project a
specific target for the next year...". We request clarification regarding what information to
include in column (3) for FY 2007 in the FY 2008 State Plan (and subsequent years), if data
for the entire fiscal year is not available at the time the Plan must be submitted (by September
1 annually).
In summary, the Mississippi Department of Mental Health remains committed to transforming
the mental health system in our state and will continue to work diligently to continue system
improvements. We are grateful for the CMHS Block Grant, including its characteristic
flexibility that facilitates our efforts to move the system forward, but have concern regarding
the feasibility of new data reporting requirements in Table 4; we also respectfully request
clarification of other points in the Draft Guidance noted previously. We have historically
enjoyed a partnership with SAMHSA in support of system changes, and we look forward to
continuing that partnership to implement the CMHS block grant program. If I can provide
additional information or clarification of these comments, please do not hesitate to contact
me. Thank you again for requesting and considering our comments.
Sincerely,

Theresa A. (Tessie) Smith
Director
Division of Policy and Planning
cc:

Mr. Edwin C. LeGrand III, Executive Director
Mr. Roger McMurtry, Director, Bureau of Mental Health
Ms. Myrna Douglas, Chairperson, Mississippi State Mental Health Planning and
Advisory Council
vMs. Deborah Baldwin, CMHS Block Grant Program Ms.
Jeanette Miller, CMHS Block Grant Project Officer

NASMHPD

Board of Directors
Renata Henry, M.Ed.
President
Delaware
Carlos Brandenburg, Ph.D.
Vice President
Nevada
James S. Reinhard, M.D.
Treasurer
Virginia
Eddy Broadway
Secretary
Arizona
Michael Moseley
At-Large Member
North Carolina
Brian Hepburn, M.D.
North-Eastern Regional
Representative
Maryland
Eddy Broadway
Western Regional
Representative
Arizona
Cathy Boggs
Mid-Western Regional
Representative
Indiana
Virginia Trotter Betts, M.S.N., J.D.
Southern Regional
Representative
Tennessee
Robert W. Glover, Ph.D.
Executive Director
NASMHPD

National Association of State Mental Health Program Directors
66 Canal Center Plaza, Suite 302, Alexandria, VA 22314 (703) 739-9333 Fax (703) 548-9517

May 15, 2007

Ms. Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, MD. 20857
Dear Ms. King:
The National Association of State Mental Health Program Directors (NASMHPD)
is pleased to have the opportunity to comment on the Substance Abuse and
Mental Health Services Administration’s (SAMHSA) Center for Mental Health
Services (CMHS) Federal Register Notice of the proposed FY 2008-2010
Guidance and Instructions for the Mental Health Block Grant Application.
NASMHPD represents state and territorial mental health commissioners/directors
and their agencies that provide public mental health services to over 6 million
people. Our members manage community-based systems of care as well as
inpatient care in state psychiatric hospitals for individuals with serious mental
illness. CMHS Block Grants provide a vital source of flexible funding for state
mental health services and programs.
NASMHPD’s comments will focus on concerns expressed by a number of state
mental health agency officials who have extensive experience in administering
block grants in their states and who work cooperatively with other state personnel
to complete the data collection, planning and analysis for the block grant
application and implementation reports. The integration of National Outcomes
Measures (NOMS) in the block grant planning process to track improvements in
the public mental health system is fully supported by NASMHPD and the states.
NASMHPD and its state mental health agency commissioner members are deeply
committed to achieving the transformation of the mental health system as
recommended in the President’s New Freedom Commission Report and other
seminal reports. We believe strongly that states and localities must be accountable
for achieving improved care for the individuals they serve. Most states are
already detailing transformation activities in their mental health block grant
applications and could work with CMHS to provide enhanced narrative
descriptions of the progress they are making to transform their mental health
systems. However, the overwhelming consensus among state agency mental

OPERATING UNDER A COOPERATIVE AGREEMENT WITH THE NATIONAL GOVERNORS’ ASSOCIATION

May 15, 2007
Page 2
health planners is that the proposed requirement for reporting of expenditures from the block grant and other
state funding sources on transformation activities is untenable, impractical and unnecessary. We strongly
recommend dropping Table 4 on page 33 of the Application Guidance and Instructions. This
recommendation in no way represents a lack of support for the principles of mental health transformation.
Our opposition to providing transformation expenditure data as requested in Table 4 is based on the fact that
states do not budget expenditures in a manner that would allow for this data to be extracted in an accurate
and meaningful way. The categories of transformation activities simply do not track with state budgeting
practices. Without expensive time studies that are beyond the scope of states’ accountability requirements,
states would be forced to make educated guesses about expenditures which could be harmful and misleading.
NASMHPD is also requesting that CMHS examine the reporting timelines in light of the proposed
requirement for reporting on additional National Outcome Measures (NOMS). On September 1, 2007, state
plans for FY 08 (which include 2007 actuals and 2008 targets) are due as well as the annual consumer
surveys as part of the NOMS. Three months later on December 1, the Implementation Reports are due.
Because states have extensive public review processes of the block grant submissions and approval
requirements by state planning councils and their Governors, the deadlines require the states to develop
“actuals” before the end of the service year. Therefore, these “actuals” are really estimates or projections
based on partial year data for many states. The workload involved with developing these ‘temporary data’ is
quite costly to the states and has nominal utility. In fact, the introduction of inaccurate data produces results
which may be misleading. It would be more advantageous for the states if the due dates for the Plans were
pushed back so that accurate data is available for planning purposes. In addition to a review of the timelines,
the definitions for the NOMS need further delineation. It is important to provide service definitions that are
clear and detailed but not so precise as to limit flexibility in achieving shared goals.
NASMHPD commends SAMHSA for its collaborative approach in working with the states to derive the
greatest benefit from limited funding for mental health services for children and adults. We are committed to
working with you to maximize the effectiveness of the Mental Health Block Grant program.
Sincerely yours,

Robert W. Glover, Ph.D.
Executive Director
NASMHPD

From: [email protected]
[mailto:[email protected]]
Sent: Thursday, May 03, 2007 11:39 AM
To: King, Summer (SAMHSA/OAS)
Cc: Baldwin, Deborah (SAMHSA/CMHS); DiGeronimo, Richard
(SAMHSA/CMHS); [email protected]; Bob Glover;
[email protected]; [email protected]
Subject: NE Comments on MHBG Guidance for FY 2008-2010
To:
Summer King
From: Jim Harvey, Nebraska Division of Behavioral Health
Services
Re:
NE Comments on MHBG Guidance for FY 2008-2010
This e-mail represents the comments from the Nebraska
Division of Behavioral Health Services on the Federal
Community Mental Health Services Block Grant Application
Guidance And Instructions FY 2008 - 2010 (Transforming
Mental Health Care In America).
These comments have been approved by Ron Sorensen,
Behavioral Health Administrator for the Nebraska Division
of Behavioral Health Services.
The primary comment involves the extraordinary increase in
burden the Federal Community Mental Health Services Block
Grant application and implementation report has become. It
is time for the Center for Mental Health Services (CMHS) to
reduce the requirements back to the minimum needed to meet
the Federal Law. For example, the draft of the Application
Guidance and Instructions for FY 2008 - 2010 was over 126
pages.
There are two areas which need to be specifically
eliminated from these requirements.
1. Eliminate Table 4 (FY 2008 – FY 2010 MHBG
Transformation Expenditure
Reporting Form) - According to the instruction package,
in FY 2008,
States are required to use this Table 4 to report
Federal Mental Health
Block Grant and State funding for transformation
activities. The
burden on this table is overwhelming. Also, one needs
to ask what is
the value of the information obtained from it. The
table requires state

and federal funding to be divided into 19 categories
plus "Other" using
categories such as "Improving coordination of care among
multiple
systems", "Eliminating disparities in access to and
quality of care",
"Support for integrated electronic health record and
personal health
information systems", "Aligning financing for mental
health services for
maximum benefit" and related areas. The Nebraska
accounting system
does not track funds in this manner. That would mean
Division staff
would be forced to guess where funds should be
classified. Such an
exercise would not produce accurate data.
2. Eliminate the requirement to describe mental health
transformation
efforts and activities in the State under each
Criterion, providing
reference to specific goals of the NFC (President’s New
Freedom
Commission on Mental Health) Report to which they
relate.
These two requirements represent an arbitrary expansion of
reporting requirements which are not necessary and do not
provide useful information for managing programs resulting
in an increased State burden. Nebraska will not report on
these two items.
According to Nebraska records, the Community Mental Health
Block Grant in Federal Fiscal Year 1982 was $919,814. In
order to receive that award, the Nebraska application was
12 pages long. That year, the Federal Mental Health Block
Grant represented 15.8% of the total community mental
health funds expended.
In FY2006, the final grant award was $2,050,210. Based on
the most recent Notice of Grant Award, Nebraska received
$2,006,208 for FY2007. This represents a cut of $44,002
from FY2006 to 2007. One may assume that the
FY2008 award will be the same or less than the FY2007
award. That means the 5% administrative funds ($100,310)
remains the same.

Using the final allocation for FY2006, the Federal
Community Mental Health Services Block Grant percentage
total of funds for non-Medicaid mental health expenditures
is:
-- 3.4% of the total community mental health expenditure as
reported on MOE
-- 1.9% of the Total mental health (state psychiatric
hospital and community mental health expenditure as
reported on MOE)
With the reduction in FY2007 funds, the overall total is
now reduced to 1.8%.
Overall, the State of Nebraska has been firmly committed to
the transformation of the mental health system. Much work
has been done over the last few years to achieve this goal.
The Nebraska Behavioral Health Reform efforts have been
documented in the last few mental health block grant
applications.
In the past, Nebraska has agreed to increased reporting
requirements.
Nebraska has successfully submitted the Uniform Reporting
System tables.
Nebraska is also agreeing to work on developing the
capacity to report the National Outcome Measures. While a
burden, these data reporting requirements do have some
added value. Also, the Center for Mental Health Services
has provided a small amount of funds [currently called
"Mental Health Data Infrastructure Grants for Quality
Improvement (Short title:
State DIG)] to support these efforts.
In summary, given the recent funding levels, the Center for
Mental Health Services needs to reduce the reporting burden
with the Federal Community Mental Health Services Block
Grant. In addition, we see no added value to Table 4 (FY
2008 – FY 2010 MHBG Transformation Expenditure Reporting
Form) nor the requirement to describes mental health
transformation efforts and activities in the State under
each Criterion. Nebraska will not report on these two
items.
==========
Jim Harvey

Nebraska Department of Health and Human Services Division
of Behavioral Health Services PO Box 98925, Lincoln, NE
68509 phone 402-471-7824 cell 402-326-2515 / Fax 402.4717859
E-mail: [email protected]

OKLAHOMA DEPARTMENT OF MENTAL HEALTH AND SUBSTANCE ABUSE SERVICES

May 1, 2007

Summer King
SAMHSA Reports Clearance Officer
Room 7-1044 One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
Please accept the following comments in response to the Federal Register Document E7-5796, filed
March 28, 2007. The referenced notice specifically addressed proposed changes in the Community
Mental Health Services Block' Grant Application Guidance and Instruction for Federal FY 2008-2010
(OMB No. 0930-168).
As Oklahoma's Mental Health Authority for Oklahoma, we generally support the revisions proposed. We
do not expect that most revisions will have a notable impact on the burden required to remain in
compliance with the Mental Health Services Block Grant stipulations. In the following paragraphs I
have highlighted our perspective on some specific proposed revisions for your consideration.
•

FY2008-2010 Revisions must integrate transformation as a guiding principle in the Mental Health Block
Grant (MHBG) Plan. Oklahoma has included transformation within the scope of planning, including the
MHBG Plan, for the past several years. As a Transformation State Incentive Grant state we certainly have
work products that exemplify this. However, it is in unclear in the proposed Guidance as to how guiding
principles or lack thereof may be a specific compliance issue in terms of approved Block Grant applications.

•

Identify transformation efforts funded by the MHBG and activities of the Council related to
transformation. The funding aspect of this may be hard to quantify from the State's perspective to meet the
intent of this change. The proposed Guidance does include a Table 4 on page 33 which provides some
categories for consideration. We would anticipate times when it may be difficult to arbitrarily assign specific
funding to the categories as proposed. The approach in proposed Guidance may present a burden that will not
be offset by the benefit of completing this work to be in compliance with the application requirements.

•

Identify at least one state-specific mental health transformation outcome measure and report a
performance indicator related to the measure. Certainly the State will be able to address this requirement and
this should not represent a notable increase in burden on completing the application. The proposed Guidance
appears to provide latitude on the part of the State to define and quantify transformation-related measures. We
would encourage CMHS to be supportive of this latitude and not overly arbitrate the extent to which a measure
is considered to adequately address transformation as a MHBG compliance issue.

•

Encourage use of the WebBGAS system for MHBG Applications and Implementation Reports. Oklahoma
has utilized the WebBGAS system for the past two fiscal years. The system provides for some efficiency.
However, the actual work product does not provide a written document which can be easily utilized by state
and local level stakeholders. Oklahoma will continue to be supportive of the web-based application but will
likely continue to prepare a parallel document more suitable for use by the Mental Health Planning and
Advisory Council and the public in general.

Mission: To Promote Healthy Communities and Provide the Highest Quality Care to Enhance the Well-Being of all Oklahomans
1200 N.E. 13th., P.O. Box 53277, Oklahoma City, Oklahoma 73152-3277 . (405) 522-3908 Voice . (405) 522-3851 TDD . (405) 522-3650 FAX

• Report all nine NOMS for mental health. Oklahoma expects to be able to provide the required
data for these measures with only moderate revisions to current data collection systems. The
State is supportive of the partnership approach utilized by the Center for Mental Health Services
through the Data Infrastructure Grant program which permits states to assist and guide in the
development of measurement systems.
Thank you for the opportunity to comment on the proposed revisions. We certainty appreciate and
diligently utilize the resources provided by the Mental Health Services Block Grant.

Rand L. Baker
Interim Commissioner

MATT BLUNT
GOVERNOR

MARK STRINGER, DIRECTOR

KEITH SCHAFER, Ed.D.

DIVISION OF ALCOHOL AND
DRUG ABUSE
(573)751-4942
(573) 751-7814 FAX

DIRECTOR

JOSEPH PARKS, M.D., DIRECTOR
DIVISION OF COMPREHENSIVE

PSYCHIATRIC SERVICES

STATE OF MISSOURI
DEPARTMENT OF MENTAL HEALTH
1706 EAST ELM STREET
P.O. BOX 687
JEFFERSON CITY, MISSOURI 65102
(573) 751-4122
(573) 526-1201 TTY
www.dmh.mo.qov

(.573)751.8017 (573) 751-7815 FAX

BERNARD SIMONS, DIRECTOR
DIVISION. OF MENTAL RETARDATION AND
DEVELOPMENTAL DISABILITIES
(573)751-4054
(573) 751-9207 FAX

May 1, 2007
Summer King

SAAASHA Reports Clearance Officer
Office of Applied Studies
Substance Abuse and Mental Health Services Administration Room 71004
1 Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:

Thank you for the opportunity to submit additional comments as requested in the March 23, 2007 FRN
regarding the Substance Abuse Prevention and Treatment (SAPT) Block Grant Uniform Application
Guidance and Instructions FY 2008-2010 (OMB No. 0930-0080)-Revision.
The language for Women's MOE Table IV is proposed to change from "Report State Fiscal Years
2004, 2005, and 2006..." to "Report expenditures for 2005, 2006, and 2007..." By removing the

specific reference to State Fiscal Year, the new draft language is unclear. Strangely, the draft
revision reflects deleting the words, "Federal Fiscal Years," however the OMB approved language
actually reads "State Fiscal Year." Is It the expectation states will continue to report on their SFY as
required in past years, or does the proposed change suggest states will begin reporting on the FFY for MOE Table IV?
Reporting on the FFY would create an additional burden for the states. Previously Missouri was
advised when there is an absence of a state or federal designation in

reference to any year, then FFY is implied, This proposed change removes the specified
designation for the FY. Further clarification is necessary.
Again, thank you for the opportunity to make additional comments regarding the SAPT Block Grant
Revision Should you have any questions regarding these comments, please call me at (573) 751.
2257 or emafl me at jodi.haupt(a)dmh.mo.aov.

ut

Hal K

blic Health Analyst

DEPARTMENT OF HUMAN SERVICES
DIVISION OF MENTAL HEALTH
Hillsview Properties Plaza, East Highway 34
c/o 500 East Capitol
Pierre, South Dakota 57501-5070
Phone: (605) 773-5991
FAX: (605) 773-7076

TTY: (605) 773-5990

www.state.sd.us/dhs

June 5, 2007
Summer King
Reports Clearance Officer
SAMHSA
One Choke Cherry Road, Room 7-1044
Rockville, MD 20857
Re: E7-5796 Federal Register Notice: Community Mental Health Services Block Grant Application
and Guidance
Dear Ms. King:
This correspondence is regarding the request for comments on Federal Register Notice E75796,
Agency Information Collection Activities: Proposed Collection, Community Mental Health
Services Block Grant Application and Guidance. I have reviewed the draft CMHS Block Grant
application and would like to take this opportunity to share my concerns with the FY2008-2010
guidance and application process, specifically regarding Table 4: Transformation Expenditure
Reporting Form.
The South Dakota Division of Mental Health (DMH) believes that the integration of mental health
transformation is essential in crafting positive outcomes for the people of South Dakota. The DMH
receives a minimum amount in Block Grant funds per year (approximately $878,000). South
Dakota uses our entire Block Grant to fund direct services to children with serious emotional
disturbances, adults with severe and persistent mental illnesses, and adults with co-occurring
substance abuse/mental health diagnoses. It would be extremely difficult and burdensome for the
DMH to report for each state transformation activity area listed in Table 4. Additionally, the DMH
does not feel that Table 4 is necessary or practical for a state like South Dakota where there is no
additional money to be utilized for direct funding of transformational activities. While the DMH
cannot quantify in expenditures the funding for each area listed in Table 4, our current State Plan
performance indicators do show progress in many areas related to transformational activities
(supporting individualized plans of care, improving coordination of care among multiple systems,
provision of evidence based practices, improving consumer access to employment and affordable
housing, etc.). The DMH does not feel Table 4 would provide a true representation of the efforts
towards transformation in the planning and delivery of community mental health services in South
Dakota.

Page 2
June 5, 2007

The DMH works very closely with community mental health centers and the Mental Health
Advisory Council to develop recovery-oriented and consumer driven services for individuals
receiving assistance from the community mental health system. In addition, the DMH works within
a Systems of Care Steering Committee comprised of the eleven community mental health centers,
the Department of Human Services, the Department of Corrections, Unified Judicial Systems, the
Department of Social Services, and the Department of Education to address many of the items
referenced in Table 4. Through these collaborative relationships it is clear that all of the
stakeholders involved find consumer driven, recovery-oriented services a priority. South Dakota
has taken many strides in the transformation of community mental health services and the
coordination of care among multiple systems, without having the benefit of flexible funding to
support specific transformation activities.
Thank you for the opportunity to comment on the proposed Block Grant application and guidance,
and for taking our concerns under consideration during the approval process with OMB.

Sincerely,

Amy Iversen-Pollreisz
Director

CMHS BLOCK GRANT INSTRUCTIONS REVIEW

BG Guidance/Instructions
Page 12
Last paragraph – The third set of DIG funding is expected to continue in FY07. (should
this be FY08)
Page 14
IV. (3) – Information regarding Implementation reports. Multi-year Plan approved in FY
2009 will not have Implementation Report due December 1, 2007 for FY 2007 Plan.
Page 16
Line 1 – States that submitted (should this be submit)
Line 2 – ...status of their mental -----

(missing words)

Page 25
(4) – Line 5 – In the annual implementation report, States are also required to submit
documentation that the State Plan was shared with the Planning Council and must
include any comments from the Council on the State’s annual implementation report.
(should State Plan read Annual Report)
Page 36
Table 6
Use of asterisk – consistency? None on NOMS 4-9
NOM 7. – period instead of comma
Page 37
4. (a) (i)... References to Table 3 “above” – (should this be Table 3 on page 31)
Page 38-39
Performance Indicator Tables – State Plan
(For 2008 Plan, shouldn’t Fiscal Years be as below)
(2)
FY 2005 Actual

(3)
FY 2006 Actual

(4)
FY 2007 Projected

(5)
FY 2008 Target............

Page 41
Performance Indicator Table – Implementation Report
(For 2008 Implementation report shouldn’t Fiscal Years be as below)
(2)
(3)
FY 2006 Actual FY 2007 Actual

(4)
FY 2008 Target

(5)
FY 2008 Actual

(6)
FY 2008 Target % Attained

P VERMONT
State of Vermont
Department of Health
Division of Mental Health 108
Cherry Street, PO-Box 70
Burlington, VT 0540.2-0070
healthvermont.gov

[phone]
802-652-2000
[fax] 802-652-2005 [ttyl
800-253-0191

Agency of Human Services

May 16, 2007
Summer King
SAMHSA Reports Clearance Officer
Room 7-1044
One Choke Cherry Road
Rockville, MD 20857
Thank you for the opportunity to comment on the proposed Community Mental Health Block Grant
Application Guidance and Instructions as described in the Federal Register / Vol. 72, No 60/ Thursday, March
29, 2007 (14825).
(a)
Much of the proposed information collection is proper, supports the functioning of the state mental
health authority, and has practical utility. Some exceptions, however, should be noted:
The proposal for client-level reporting of data to the Center for Mental Health Services (CMHS) has
the potential to raise serious questions about the confidentiality of medical records and the personal privacy of
service recipients. Any inclusion of unique personal identifiers (e.g., Social Security number, name, etc.)
would be very problematic.
The ongoing expansion of the consumer survey data collection effort is also problematic. The
traditional and legitimate focus of the consumer survey is consumers' evaluations of the services they have
received. The addition of questions regarding consumers' criminal justice involvement, level of functioning,
school attendance, etc., radically changes the role of the consumer from the person evaluating services to the
person being evaluated. We believe that this change will have a substantial detrimental impact on
consumers' willingness to participate in the consumer surveys. In Vermont, we have already seen a
significant reduction in adult consumer survey response rates, from 53% in 1997 to 36% in 2006. We attribute
most of this decrease to the requirement by the Substance Abuse and Mental Health Services Administration
(SAMHSA) that consumers be surveyed on an annual basis. The addition of new questions that do not
relate to consumer satisfaction could very well further reduce response rates and reduce the utility of
consumer surveys to help guide state mental health policy at the state level.
(b) We believe that the single most important way to enhance the quality and utility of the data used to
populate Uniform Reporting System (URS) tables is to increase utilization of administrative data from other
state agencies. Vermont uses data from other state agencies to measure consumers' employment rates,
rates of criminal justice involvement, readmission to general hospitals after st1te

hospital discharge, livings. ituation and homelessness, and school participation. We believe these data to be of
very high quality and find these data to be very useful at the state level. Changing the source of these data
to the consumer survey as has been suggested by SAMHSA could have a negative impact on the validity
and reliability of these data, and diminish their utility at the state level.
(c)
The reporting burden can be reduced in two ways. First, more reliance on administrative data
from existing databases and reduced reliance on special-purpose data collection can greatly reduce the burden
on state mental health authorities. We live in an age of data abundance. The model being proposed by
SAMHSA (special-purpose data collection) is the legacy of an age of data scarcity. There is no need for
mental health agencies to collect data that have been routinely collected by other state agencies that
specialize in the specific areas of concern. Their data are of higher quality and the expense of data collection has
already been borne elsewhere.
Second, the measurement of fidelity with regard to the ten Evidence-Based Practices in the
current URS reporting system is extremely time-consuming and expensive. Making these tables
optional until reliable, consistent reporting practices can be established and supported with resources
commensurate to the task would result in great savings for the time being at the state level.
Sincerely,

A. Pandiani, Chief
earch and Statistics
I

G~e)~446)~4t-t
Melinda Murtaugh
Quality Management Coordinator
Adult Unit, Division of Mental Health
State Planner for the Mental-Health Block Grant