Attachment 3-Comments

STATE OF CALIFORNIA - HEALTH AND HUMAN SERVICES AGENCY

ARNOLD SCHWARZENEGGER, Governor

DEPARTMENT OF ALCOHOL AND DRUG PROGRAMS
1700 K STREET
SACRAMENTO, CA 95811-4037
TDD (916) 445-1942
(916) 324-4398

March 29, 2010

Ms. Summer King
SAMHSA Reports Clearance Officer
Room 7-1044, One Choke Cherry Road
Rockville, Maryland 20857
Dear Ms. King:
Below please find the Department of Alcohol and Drug Programs (ADP), Prevention
Services, response to the Federal Register dated February 19, 2010:
Comments in Response to the Proposed Project: Survey of State Underage
Drinking Prevention Policies and Practices
Federal Register/Vol. 75, No. 39/Monday, March 1, 2010 – Pg. 9221-9222
1. Page 9221, right column, Category # 4, refers to cost per capita for the
prevention of underage drinking.
Comment: The amount that each State invests, per youth capita, on the prevention
of underage drinking may be difficult to measure because prevention programs
throughout the state offer a comprehensive approach where multiple Alcohol and
Other Drug (AOD) issues or youth development may be the focus.
2. Page 9221, right column, Paragraph 7, refers to the results of the State Survey
informing Federal programmatic priorities.
Comment: Guided by Strategic Prevention Plans, many of California’s 58 counties
have identified underage drinking as a priority based on their county needs
assessment. Although the State Survey results may provide an additional
measurement tool, it may also send mixed messages to counties asking them to
realign their plans to meet state or federal mandated needs rather than staying true
to the Strategic Prevention Framework (SPF) by making data-informed decisions.

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Ms. King
March 29, 2010
Page 2

3. Page 9222, left column, Paragraph 2, refers to the State Survey assessing “best
practices” and emphasizing the importance of building collaborations with
Federally Recognized Tribal Governments.
Comment: California has not identified statewide Best Practice Standards. Also,
ADP does not directly collaborate with recognized Tribal Governments. However,
the state requires all 58 counties to use the SPF for planning and implementing
prevention. As part of the planning process, counties determine the policies,
practices, and/or programs that best suit their needs and populations.
4. Page 9222, right column, regarding estimated annual response time and use of
data that is readily available.
Comment: Under the directive of ADP, counties are required to enter data into the
California Outcomes Measurement Service for Prevention (CalOMS Pv) for all
Substance Abuse Prevention and Treatment Block Grant-funded primary prevention
services. Funding is tracked by the six primary prevention CSAP strategies and
three IOM categories. Prevention data is not broken down by cost per service or
identified by issues such as underage drinking; therefore, the data may not be
readily available to SAMHSA in the form required for the State Survey.
There is some concern whether an 8-week period would be sufficient to complete
the survey. Time may be needed to collect requested information from other state
agencies and/or county AOD offices. Some offices may not have adequate
resources to be able to respond in a timely manner.
Please direct any questions you may have regarding the Federal Register comments
to Denise Bennett at (916) 327-4076.
Respectfully,

SHARON DAIS
Assistant Deputy Director
Prevention Branch
Program Services Division

May 2010 Comments from Georgia Regarding Stop Act Questionnaire
Part II B - P10
This section could define community stakeholders (alcohol retailers, law
enforcement, business owners, local officials or any other groups that are not
directly caregivers but those that have received services from the program.
P12
This section could also include the most recent annual data on the number of
community stakeholders (alcohol retailers, law enforcement, business owners,
local officials or any other groups that are not directly caregivers but those that
have received services from the program
P 12
Re the question
Has this program been evaluated?
If the respondent says “No” then ask him/her “Why not?”
P12
Some program evaluations may not be available via URL or on the agency
website but may need a section to upload the Evaluation report.
P. 16
This section could also define community stakeholders (alcohol retailers, law
enforcement, business owners, local officials or any other groups that are not
directly caregivers but those that have received services from the program.
P 18
This may not be directly tied to a program but could also be data that is collected
and evaluated by the one program that is funded by the state.
Yes, it might be better to say:
“Does your State have programs THAT measure and/or reduce . . . “ versus a
specific program TO measure and/or reduce . . . . per the current form of the
question below:
Does your State have programs to measure and/or reduce
youth exposure to alcohol advertising and marketing?
If a respondent answers, “Yes” then ask her/him to describe how the
program accomplishes this.