Responses

Attachment C - Responses.pdf

Uniform Application for the Community MH Services BG and SAPT BG Application Guidance and Instructions FY 2014-2015

Responses

OMB: 0930-0168

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 0930-0168 can be found here:

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Block Grant Comment Log (Continuous)
GENERAL COMMENTS
#

Date
Received

Section

Commenter/

Comment/Question

Disposition of Comment/ Rationale

Organization
1.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

We liked the direction of the four purposes for
block grant funding and find the framework useful.
It is recommended all of the terms be clearly
defined.

Thank you for your comment.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

SAMHSA outlines what is "generally" required in last
paragraph on page one of the document. The
language after that states "should, could,
encouraged etc." and seems more like general
guidance and not requirements.

Correct

Authorizing legislation (42 USC s/s 300x-32)
and implementing regulation (45 CFR
96.122) identifies what is required for the
SABG Plan. SAMHSA encourages States to
address the requested items in order that
SAMHSA has a more comprehensive view
of the States’ priorities and state system
services.

Block Grant Comment Log (Continuous)
3.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

Data collection system changes take time and
money. With reporting timelines two years past,
"new" data will not be seen for three years or so.
We recommend better coordination with the
SAMHSA sponsored State Profiles workgroup to
provide more timely information.

SAMHSA will consider ways to promote
better coordination with this workgroup.

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

Expanding the areas of focus may potentially detract
from the flexibility of states to focus on their
perceived areas· of highest needs.

States have the responsibility to focus on
their areas of highest need as they
determine. By expanding the areas of
focus in the plan, SAMHSA is supporting
that states use the planning process to look
at multiple populations and needs to
inform their priorities.

Any proposed change in data collection,
analysis and reporting presents numerous
challenges at the Federal, State, and
community level. Changes in States' SABGrelated data systems are difficult to
coordinate, especially when dealing with
States' legacy data systems that are not
Web-based; therefore, deleting and/or
adding data elements is costly and
generally takes timeto implement.

The authorizing legislation and
implementing regulation governing
SAMHSA’s Communty Mental Health
Services Block Grant (MHBG) and
Substance Abuse Prevention andTreatment
Block Grant (SABG) identify targeted or
priority populations to be served with
MHBG and SABG funds. Section 1912 of
Title XIX, Part B, Subpart I of the PHS Act
(42 USC §300x-2) identifies adults with a
serious mental illness and children with a

Block Grant Comment Log (Continuous)
serious emotional disturbance. Section
1923(b) of Title XIX, Part B, Subpart II of the
PHS Act (42 USC § 300x-22(b)) identifies
pregnant women and women with
dependent children and section 1923 of
Title XI, Part B, Subpart II of the PHS Act (42
USC § 300x-22 identifies intravenous drug
users.
5.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

Washington State is an advocate of gathering and
using data and we recommend replacing the
National Outcomes Measures (NOMS) with 25
relevant data elements, with defined measures,
that could be tracked over time. The NOMS data
measures are general in nature and we may not be
able to use this data for presentations or research.

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health

The new required demographic data includes
languages spoken, transgender and sexual
orientation. The sexual orientation questions are
not appropriate for all age groups especially children
and we already see significant hesitance of providers
in asking these questions for adults. Given the
variations of transgender status, the answers appear
to be too open ended.

SAMHSA will continue to request
information to support the NOMs. During
the next year, SAMHSA will engage
stakeholders in a comprehensive review of
measures to support both discretionary
and Block Grant data reporting.
The BehavioralHhealth Barometer will be
published within the next fiscal year.

While HHS has developed recommended
data points for race and ethnicity, their
language for sexual orientation is currently
under development and will soon be be
released . In the meantime, we
recommend that states use existing LGBTQ
data elements used within their state.
Further, we recognize the sensitivity
around asking LGBTQ related questions to
children and adults and view this as a
workforce development issue that may be

Block Grant Comment Log (Continuous)
Services

addressed through multicultural and
cultural competence training.
The estimate of burden was based on
historical information and analysis of
requested vs. required information and will
be updated as changes are required.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

The estimate of 282 hours in table 1for a year-one
plan does not meet the actual number of hours we
have found to complete these tables. Our experience
has been 10 times the estimate. For example,
completion of this table for both prevention and
treatment has taken in excess of 350 hours when the
estimate has been 35 hours.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

The burden estimate provided would only allow us
to complete 30% of the information requested in
the instructions.

The estimate of burden was based on
historical information and analysis of
requested vs. required information and will
be updated as changes are required.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of

In addition to the hours of staff time needed to
gather the collection of information, we also would
need to make changes to our data systems to add
new elements. These additional elements add

The estimate of burden was based on
historical information and analysis of
requested vs. required information and will
be updated as changes are required.

Block Grant Comment Log (Continuous)
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

considerably to our financial burden at a time when
our state revenues continue to be flat or declining.

10.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

Health care reform is still very much a work in
progress with key guidance yet to be written. It is
extremely difficult to estimate the burden of
reporting until these programs are defined and
implemented.

The estimate of burden was based on
historical information and analysis of
requested vs. required information and will
be updated as changes are required.

11.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,

The burden could be considerably reduced by going
to 3-year, rather than 2-year plans.

SAMHSA will take this under consideration
for future application and plan documents.
Section Section 1932 of Title XIX, Part B,
Subpart II of the PHS Act requires States to
prepare and submit an annual plan that
“…contains detailed provisions for
complying with each funding agreement for
a grant under section 1921 that is

Block Grant Comment Log (Continuous)
Department of
Social and Health
Services

applicable to the State, including a
description of the manner in which the
State intends to expend the grant.”

12.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

On the "Barometer", we believe that "Heavy Adult
Use" should be "Heavy Young Adult use".

This would represent two different
population but SAMHSA will consider
adding the latter.

13.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

We request that SAMHSA provide specific
operational definitions for each measure so that the
information is clear.

This is the plan for the future

14.

8/16/12

Chris Imhoff,

The requests for narrative information take
considerable hours of work and do not seem

SAMHSA has considerably reduced the
amount of narrative information from past

Block Grant Comment Log (Continuous)
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

quantifiable. Reducing requests for narrative would
cut the burden of hours of work.

application and plans and has given
guidance through the development of
questions to streamline the narrative
responses. SAMHSA will continue to
streamline the requests in collaboration
with states.

15.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

The application and reporting processes continues to
include new measures without reducing historic
measures. We recommend the utility of old
measures be reviewed and some of the historic
burden that has become less relevant be removed.

SAMHSA plans to do this as part of the
process for determining measures to be
included in the National Behavioral Health
Quality Framework.

16.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability

What technical assistance to states is being proposed
to assist with completing applications?

SAMHSA will continue to provide targeted
technical assistance (TA) to support States
and Jurisdictions completing the 2014/2015
Behavioral Health Assessment and Plan.
Such assistance may be provided in a
variety of formats including, but not limited
to, consultation with their respective

Block Grant Comment Log (Continuous)
Services
Administration,
Department of
Social and Health
Services

17.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

We suggest the application be limited to "required
items only" and additional requested materials be
included as addendums or quarterly, pre-scheduled
surveys on critical topics such as Health Care
Transitions, Special Populations etc. Quarterly
reports or surveys would also allow for more useful,
timely and "do-able" responses to time sensitive
issues·.

18.

8/16/12

Chris Imhoff,

We suggest automated data collection systems and

federal project officer, workshops,
instructional videos and webinars. In
addition, SAMHSA will develop an
enhanced instruction manual and post
answers to frequently asked questions on
SAMHSA’s website and the Web Block
Grant Application System (BGAS). Program
staff and managers responsible for the
preparation and submission of the States’
and Jurisdictions’ plans will also be able to
have ongoing communication and dialogue
with their assigned federal project officers
who can provide specific guidance, answer
questions, or refer the State or Jurisdiction
to the necessary information needed to
complete the plan. Technical assistance is
also available through the Web BGAS Help
Desk.
SAMHSA has considered this option and
has chosen to include requested items in
the application to allow for one bi-annual
submission of requested information
instead of multiple survey requests.

SAMHSA is moving toward a more

Block Grant Comment Log (Continuous)
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

other forms of information technology used to
gather data are compatible with SAMHSA's systems.

integrated data collection system, and will
do what is within the agency’s control to
promote these goals.

19.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

We recommend SAMHSA address as many of their
data needs as possible by utilizing data from other
federal agencies such as the Center for Medicaid and
Medicare Services (CMMS). The state profile
workgroup could be a resource to leverage
administrative data bases which federal agencies can
access.

The development of a core set of
recommended measures within the
National Behavioral Health Quality
Framework will represent an important
effort to promote the use of key measures
across various payers and providers.

20.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability

A model response for the block grant application
and reporting would be helpful.

SAMHSA is working on developing some
model responses and reports to share with
states.

Block Grant Comment Log (Continuous)
Services
Administration,
Department of
Social and Health
Services
21.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

We recommend military veterans be included in the
list of populations subject to health care disparities.

The populations identified in the Block
Grant application were selected based on
Section 4302 of the Affordable Care Act
and the Secretary’s Action Plan for
Eliminating Racial and Ethnic Disparities. In
addition to the populations identified in the
Block Grant application and these HHS
documents, states may report on additional
populations serviced that may be
vulnerable to disparities. Military are
included in the listing of populations

22.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health

States have been reducing staff positions in order to
deal with budget deficits and we recommend
SAHMSA limit the scope of information proposed
that states are asked to provide.

SAMHSA has streamlined the Uniform
application as much as allowed under our
statutory requirements.

Block Grant Comment Log (Continuous)
Services
23.

24.

8/16/12

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

There may be some overlapping of responsibilities
between the single state authority and the other
state entities, including the State Medicaid
Authority. These include:

Chris Imhoff,

SAMHSA is requesting states implement policies and
procedures that are designed to ensure Block Grant

SAMHSA recognizes that there may be
overlap, but is seeking to understand how
the state authorities are involved in that
discussion.

(a) Ensuring that Qualified
Health Plans (QHPs) and
Medicaid programs are
including Essential Health
Benefits (EHBs) as per the
state bench mark;
(b) Ensuring individuals· are
aware of the cov red mental
health and substance abuse
benefits;·
(c) Ensuring people will utilize the
benefits despite concerns that
employers will learn of mental
health and substance abuse
diagnosis of their employees;
and (d) Monitoring utilization of
behavioral health benefits in light
of utilization review, medical
necessity, etc.

SAMHSA agrees that the implementation of
program integrity activities and expansion

Block Grant Comment Log (Continuous)

25.

8/16/12

LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health
Services

funds are used in accordance with the identified
four priority categories. States may have.to reevaluate their current management and oversight
strategies to accommodate the new priorities. They
may also be required to become more proactive in
ensuring state-funded providers are enrolled in the
Medicaid program and have the ability to
determine if clients are enrolled or eligible to enroll
in Medicaid. The compliance review and audit
protocols may need to be revised to provide for
increased tests of client eligibility and enrollment.

Chris Imhoff,
LICSW, Director,
Division of
Behavioral Health
and Recovery,
Aging and Disability
Services
Administration,
Department of
Social and Health

The priorities listed under the Program Integrity
Section do not correspond with the four purposes
that SAMHSA proposes grant funds be directed
towards.

of Medicaid will require states to reevaluate their procedures and protocols.
The implementing regulations governing
the SABG at 45 CFR 96.137 require States
and their SABG sub-recipients to collect
reimbursement for the costs of providing
services described in 45 CFR 9.124(c) and
(e), 45 CFR 96.127 and 45 CFR 96.128 to
persons who are entitled to insurance
benefits under the Social Secutiry Act,
including programs under Title XVIII
(Medicare), and title XIX (Medicaid, any
State compensation program, any other
public assistance program for medical
expenses, any grant program, any private
health insurance program or any other
benefit program; therefore, states and
their SABG sub-recipients have some
familiarity with Medicaid enrollment.
SAMHSA understands that the priorities for
Program integrity activities and the
purpose of the use of block grant dollars
are not identical, but are complementary.

Block Grant Comment Log (Continuous)
Services
26.

8/24/2012

Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental
disabilities
Administration

We support the direction and guidance for prevention
proposed by the BG Application; specifically the focus
on funding universal, selective and targeted
prevention activities and services, and collecting
performance and outcome data to determine the
ongoing effectiveness of behavioral health prevention

Thank you for your comment

27.

8/24/2012

Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental
disabilities
Administration

It would be helpful to receive additional guidance on
Screening, Brief Intervention and Referral to
Treatment as a prevention activity consistent with
indicated/targeted prevention activities, as well as
guidance or suggestions on developing traumainformed prevention systems and related activities for
high risk populations

28.

8/24/2012

Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental

SAMHSA has encouraged states to implement
recovery-support services, and indicated they will
provide content expertise to assist states with the
process. Recovery supports include a wide variety of
services, one of which is housing. SA BG recipients
have the option of establishing a revolving fund to
support the establishment of group homes.

For purposes of the SABG, as specified in 45
C.F.R. 96.125(b), primary prevention is
defined as programs directed at individuals
who have not been determined to require
treatment for substance abuse. Thus, any
SBIRT activity in the SABG would not be
considered a substance abuse primary
prevention activity. However, since one of
the six substance abuse primary prevention
strategies is “Problem Identification and
Referral,”, a State may refer an individual
to a program or practitioner using SBIRT for
identification and referral
SAMHSA encourages states to consider
evidence based practices and best practices
to implement recovery support services.
A State or Jurisdictions may obligate and
expend SABG funds for recovery support
services including transitional housing.

Block Grant Comment Log (Continuous)
disabilities
Administration

The requirement criteria for homes are found in CFR
45 Part 96 Section 129. These requirements,
specifically subsections 5i and 5ii, are not consistent
with the recognition that substance use disorders are
chronic illnesses and that relapse is a part of that
illness. These subsections require that individuals who
use substances in the housing provided through these
funds must be “expelled from the housing.” This is an
antiquated approach to care for individuals in
recovery. This limits the practical utility of the use of
information reported on the impact of this BG service.
Safe and stable housing is an important component of
an individuals’ recovery capital and is a key part of
establishing a recovery-oriented system of care. In
order to fully support the needs of those in recovery,
especially early recovery when people are more
vulnerable, the requirements for how these funds can
be used to support housing need to be changed so
they are consistent with what we now know about
substance use disorders. Changing the requirements
for group home funding will allow states to take the
proactive approach to implement the recovery
support services that SAMHSA is encouraging.

29.

8/24/2012

Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental

Children/Youth with Serious Emotional Disturbance
and Their Families: Additional emphasis should be
apparent in the application guidance to ensure that
this populations is comprehensively incorporated into
the block grant plan. This is especially indicated in
areas such as co-occurring issues, trauma, expansion
of the behavioral health council and support for
14

SAMHSA will carefully review state plans to
ensure that services for children/youth
with serious emotional disturbance are
integrated into the comprehensive system
of care and that co-ocurring services are
available.

Block Grant Comment Log (Continuous)

30.

8/24/2012

31.

8/24/2012

32.

8/24/2012

disabilities
Administration
Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental
disabilities
Administration
Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental
disabilities
Administration

Michigan Dept of
Community
Health/Lynda
Zeller,Deputy
Director Behavioral
Health &
Developmental
disabilities

evidence-based, evidence-informed and promising
practices that are beneficial to this population.
Thank you for your comment
Quality of Data Collected: We agree with the
proposed methodology to enhance the quality, utility
and clarity of the information to be collected. We
support the focus on the identification and targeting
of at-risk populations experiencing health disparities
specified in the Block Grant application and the
Guidance and instructions.
Mental Health Primary Prevention Activities: Whereas
the definition and scope of primary prevention
activities has been well defined in the realm of
substance use disorders, it remains an under-defined
element in the realm of mental health disorders within
the adult and child populations. It would be helpful to
have specific guidance to clarify what may constitute
primary prevention activities to address mental health
disorders such that collected information will have
clearly understood outcomes for the services provided
and the metric to gauge the results. (Mental health
promotion? Early intervention that prevents
progression to SMI status? Other?)

Thank you for your comment

Burden of Data Collection: We agree with and support
the methods suggested to minimize the burden of the
collection of information through the use of
automated collection techniques.

Block Grant Comment Log (Continuous)

33.

34.

8/30/2012

Administration
Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

Multiple Goals and Purposes of the Proposed SAPT BG
Application: Multiple divergent purposes for the
revised application place a heavy burden on State
sbustacen abuse agencies. The introduction in the
application states that the proposed revisions are to
“expand the areas of focus.” Furthermoe, the stated
purpose is to meet SAMHSA’s need to “assess the
extent to which states plan for and implement the
ACA.” Finally the scope of the revision is to determine
whether SAPT BG funds are being directed toward the
four year recommended purposes of the grant, which
are different from the statutorily required goals of the
program. Significant year-to-year changes by SAMHSA
to the application can undermine the enthusiasm and
dilute progress on any one area of focus or goal.
Everh change, especially additional requirements
without corresponding eliminations, spreads resources
too thin and risks reducing effectivenementt and
impact.
Recommendation: If absolutely necessary, one new
area of attention might be highlighted eery two years.
States require dufficient time to shape plans,
implement programs and strategies and to monitor
change.
Compliance Requirements: Given the numerous
changes to the SAPT BG application, we recommend
more thorough and clear guidance for completing
each section. We also recommend the inclusion of
criterion for distinguishing required timeframes and
sections where flexibility may be afforded to States as
they complete the application. As indicated in our
16

SAMHSA believes that since State
authorities are the policy leaders in the
provision of serives for mental and
substance use disorders, it is reasonable to
ask that the 2 year planning process include
the inclusion of expanded population focus
– particularly when examining the gaps in
service and insurance coverage- and the
application of the four recommended
purposes of the grant.

SAMHSA is revising the instructions for the
FY 2014-2015 Behavioral Health
Assessment and Plan and the MHBG and
SABG reports.
The FY 2014-2015 Behavioral Health
Assessment and Plan Table of Contents

Block Grant Comment Log (Continuous)
comments last year, the lack of common and clear
criteria for all to follow increases the potential for
delays in the final approval process. State substance
abuse directors note thaty they submitted “requested
information” as opposed to “required information”)
and were told to provide yet more information before
the application was ultimately approved. This process
has caused confusion and an unnecessary gurdent to
State Substance Abuse agencies,
Recommendation: A clear set of consistent criterion
must be include in the final document for both State
sutance abuse agencies and SAMHSA project officers
to use when submitting and evaluating the application
and more information for completing each section.

35.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse

includes required and requested (optional)
sections. States are required to provide a
detailed description of planned activivites
and services authorized by Titel XIX, Part B,
Subpart I (MHBG), Subpart II (SABG). and
Subpart III (MHBG and SABG) of the Public
Health Service Act and 45 CFR § 96.120-137
SAMHSA is also requesting States’ to
provide a description of other planned
activities and services which are not
explicity required by legislation or
regulation; therefore, States have the
option of providing such information to
SAMHSA.

States are required to provide a detailed
description of planned activites and
services authorized by Tital XIX, Part B,
Subpart I (MHBG), Subpart II (SABG). and
Subpart III (MHBG and SABG) of the Public
Health Service Act and 45 CFR § 96.120-137
SAMHSA is also requesting States’ to
provide a description of other planned
activities and services which are not
explicity required by legislation or
regulation; therefore, States have the
option of providing such information to
SAMHSA.
Terminology: The document refers to the generic term SAMHSA is committed to support the
“States,” and changes the term for the SAPT Block
strong leadership role of State Authorities.
Grant to Substance Abuse Block Grant (SABG).
The statutory name of the Substance Abuse
Recommendation: We recommend specific references Prevention and Treatment Block Grant (or
to the term State substance abuse agency. We also
the Community Mental Health Services
17

Block Grant Comment Log (Continuous)
Directors, inc
(NASADAD)

36.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

seek assistance from SAMHSA to ensure that SSAs
have a strong leadership role in federal ACA dollars
from sources other than SAMHSA [e.g. Health
Resources and Services Administration (HRSA)] and not
currently going through SSA.
We also recommend using the term for the SAPT block
grant identified in statute, which is the Substance
Abuse Prevention and Treatment Block Grant.
Corrective Action Plan: On page 54, the proposed
application notes that States should be held
accountable for meeting the goals and performance
indicators established in their plan. In addition, the
proposed application includes that States shall
develop a corrective action plan if that State has failed
to take reasonable steps to achieve its goals as stated
in the application and approved by SAMHSA. Finally,
the proposed application notes that SAMHSA may
direct the State authority responsible for the program
to change the State plan to ensure goals are met.
NASADAD supports enhanced accountability in return
for more flexibility in how SAPT Block Grant funds are
spent. We support a close working relationship
between State substance abuse agencies and SAMHSA
staff to discuss progress, identify barriers and develop
solutions. We also believe, however, that the State
and SAMHSA may have different interpretations of
what constitutes “reasonable steps” the State has
taken to address deficiencies.
Recommendation: We believe criteria should be
developed to help assess whether a not a State has
taken “reasonable” actions with regard to its
corrective action plan. We also recommend the
development of a formalized consultation process that
18

Block Grant)has not changed, SAMHSA has
shortened the acronyms to SABG and
MHBG.

State Project Officers have already
developed or are making every effort to
develop a close working relationship with
each State they monitor. They are flexible
while working with States to provide the
necessary technical assistance needed to
help develop a corrective action plan if the
State has not met its targets. However,
SAMHSA’s Centers will work together to
develop criteria to help assess whether or
not a State has taken “reasonable”
actions with regards to a request from
SAMHSA for a State to submit a corrective
action plan.

Block Grant Comment Log (Continuous)

37.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

38.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

would convene SAMHSA and the impacted State
should any disagreements develop with regard to
goals, corrective action plans, and success in taking
“reasonable” steps to improve services.
FY 2012 and FY 2013 Budget Proposal: For the second
year in a row, the draft SAPT Block Grant application
seems to reference initiatives that are included in
SAMHSA’s proposed budget for FY 2013. This
approach sends mixed messages to State substance
abuse agencies since SAMHSA’s budget proposal
requires Congressional action. Given the number of
changes State substance abuse agencies are
managing, direction should be given by Congress to
SAMHSA before changes are included in the
application, particularly since Congress opposed the
proposal last year.
Recommendation: We recommend that SAMHSA
remove information that references the FY 2013
Budget proposal in the application.
Behavioral Health Barometers and Data Collection:
The proposed SAPT Block Grant application does not
identify all measures that will be included in the
behavioral health barometer. State substance abuse
agencies are concerned some of the data elements
identified in the document for collection, are current
data points not currently collected. States vary
considerably in their data capabilities and any change
to their data system could be challenging.
In addition, we are concerned by the use of the term
“behavioral health.” We believe precise language is
critical given the large impact federal statutes and
regulations have on State systems. We also
understand the stigma and discrimination that can be
19

In the Background section, SAMHSA has
described our vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

The Behavioral Health Barometer is
currently in draft form. SAMHSA has and
will continue to engage stakeholders in the
development of the Barometer and identify
how the information can help states and
communities to improve BH services. As
envisioned, the Barometer will include and
report on data collected through SAMHSA
and other federal survey efforts, and thus
should not represent any additional data
collection burden to states.

Block Grant Comment Log (Continuous)

39.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

attached to certain terms.
The use of precise terminology is particularly
important as we consider, develop, and implement
measures and data elements.
Recommendation: SAMHSA should provide more
clarity on how the agency intends to incorporate
“behavioral health barometers,” and how they will
work with the National Outcome Measures (NOMs)
and States’ current data collection efforts. We also
urge SAMHSA to provide State substance abuse
agencies flexibility based on a State substance abuse
agency’s data infrastructure and capabilities. We
recommend SAMHSA work directly with NASADAD on
data collection issues.
In addition, we recommend using language that
recognizes and reinforces the fact that addiction is
indeed a unique, distinct, and primary disease. We
recommend unique measures that are appropriate for
the prevention, treatment, and recovery of substance
use disorders; prevention, treatment, and recovery of
mental illness; and elements appropriate for both
substance use disorders and mental illness. We believe
this will help better position State to use the data to
improve service delivery.
Multiple Goals and Purposes of the Proposed SAPT
Block Grant Application: Multiple, divergent purposes
for the revised application place a heavy burden on
State substance abuse agencies. The introduction in
the application states that the proposed revisions are
to “expand the areas of focus.” Furthermore, the
stated purpose is to meet SAMHSA’s need to “assess
the extent to which states plan for and implement the
ACA.” Finally, the scope of the revision is to determine
20

Block Grant Comment Log (Continuous)

40.

8/30/12

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

41.

8/30/12

Robert Morisson,

whether SAPT Block Grant funds are being directed
toward the four recommended purposes of the grant,
which are different from the statutorily required goals
of the program. Significant year-to-year changes by
SAMHSA to the application can undermine enthusiasm
and dilute progress on any one area of focus or goal.
Every change, especially additional requirements
without corresponding eliminations, spreads resources
too thin and risks reducing effectiveness and impact.
Recommendation: If absolutely necessary, one new
area of attention might be highlighted every two
years. States require sufficient time to shape plans,
implement programs and strategies, and to monitor
change.
Planning Steps: The direction of the proposed
application appears to be increasingly prescriptive in
what SAPT Block Grant funds may purchase instead of
being more flexible. NASADAD has had a long-standing
concern with any efforts to increase the
prescriptiveness of the SAPT Block Grant.
Further, these priority areas that are proposed to be
requested in a State plan are not included in statute or
regulations. It also changes the intent of the SAPT
Block Grant, which is to allow States flexibility to
identify their own needs using State data.
Recommendation: We recognize the request for
information on how States are addressing these new
populations and areas is optional. We urge that this
request be clearly labeled in the application as
optional. We also urge SAMHSA to indicate that the
State’s award will not be impacted in any way should
the section not be completed..
Overall Comments on Joint Planning: We support the
21

purposes of the grant.

SAMHSA has indicated in the application
that the information requested is not
required. SAMHSA has added language
which clarifies that the state award will not
be impacted if a state does not provide
requested information.
During the last planning cycle, all states
submitted some requested information and
many states submitted all requested
information. This allowed SAMHSA to
provide targeted technical assistance as
well as better understand the state’s issues
in these areas.

For purposes of the SABG, primary

Block Grant Comment Log (Continuous)
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

concepts and ideas behind coordinated planning with
many sister State agencies, including mental health
departments. Our support is based on the premise
that SAMHSA will maintain and endorse clinical,
financial and programmatic integrity of substance use
disorders prevention and treatment services.
Joint planning on prevention: We understand and
support SAMHSA’s work to elevate issues pertaining to
prevention. We also note that much work remains to
better define and establish common terminology
regarding substance abuse prevention and mental
health promotion. To protect prevention funding, we
caution SAMHSA not to broaden prevention
requirements and expectations far beyond the
statutory requirements guiding their allowable use.
Recommendation: We recommend that work first
move forward to establish common definitions
pertaining to substance abuse prevention, mental
health promotion, and other relevant and related
terms. We recommend working through NASADAD on
this topic.
Joint planning on recovery services: We understand
the interest in gathering additional information
regarding “recovery services.”
Recommendation: We recommend SAMHSA work with
stakeholders to define “recovery services.” In
particular, we recommend that SAMHSA work with
NASADAD to draft a definition. Recovery services for
populations with substance use disorders and recovery
services for those with mental illness will be identical in
some cases but in others may be quite different. For
instance, it is essential that individuals recovering from
22

substance abuse prevention is defined in
the authorizing legisitaion (42 USC § 300x22(a)) and implementing regulation (45 CFR
96.125) in the BG application. SAMHSA
will work collaboratively with its
stakeholders to define prevention and
other related terms as they relate to each
discipline (primary substance abuse
prevention, substance abuse treatment,
mental health promotion).

Recovery is addressed in the Children and
Adolescents
Behavioral Health Services section, as well
as, the Recovery sections. SAMHSA has a
definition of Recovery and is working with
stakeholders to identify and acknowledge
the differences between the services for .

Block Grant Comment Log (Continuous)
addiction have access to alcohol and drug free
housing. In addition, a revised SAPT Block Grant
application could ask SSAs to identify recovery services
funded by SAPT Block Grant as a starting point using
common definitions/categories.
42.

43.

8/30/2012

Robert Morisson,
Executive Director,
National Association
of State alcohol and
Drug Abuse
Directors, inc
(NASADAD)

Deadline for Submission: States are increasingly
concerned about the April 1 deadline for the
application. This coincides with States’ legislative
session. State substance abuse agencies must be
attentive to legislative requests, which include
preparing budget requests, testifying before legislative
committees, and tracking State legislation. It will be a
challenge to complete the application with competing
demands, particularly for the small States and State
substance abuse agencies that have suffered
reductions in staff as a result of economic hardships.
Recommendation: Work with NASADAD to address
the concerns of State substance abuse agencies as a
result of the April 1 deadline.
Optional and Required Information: As mentioned
previously, given the number of new topic sections
and requests, it is very important for SAMHSA to
identify the information that is requested and the
information that is required. NASADAD appreciates
that SAMHSA has 4
identified on page 16 the information that is
requested. However, a more detailed explanation
about the expectation for each section would provide
better clarity, particularly for sections of the SAPT
Block Grant and Community Mental Health Services
23

SAMHSA will work with states and
NASADAD to address the concerns of state
agencies related to the April 1 submission
date.

SAMHSA is developing additional
instructions and guidance for states on the
block grant submissions to clarify the
expectations.

Block Grant Comment Log (Continuous)

44.

9/5/12

45.

9/5/12

46.

9/5/12

Jennifer Parker,
Human Services
Program Specialist,
Department of
Public Welfare,
Office of Mental
Health and
Substance Abuse
Services
Jennifer Parker,
Human Services
Program Specialist,
Department of
Public Welfare,
Office of Mental
Health and
Substance Abuse
Services
Jennifer Parker,
Human Services
Program Specialist,
Department of
Public Welfare,
Office of Mental

(CMHS) Block Grant that have different statutory
requirements.
Recommendation: Clearly identify in each section or in
a table in the final SAPT Block Grant Application what
new sections are required and what sections are
optional and what information is required for the
CMHS Block Grant and separately the SAPT Block
Grant.
Page 41432:
Column Three, Fourth Paragraph- Please provide
clarification regarding the status of Tables 1-6b- which
are required, which are requested for MHBG only.

Page 41432:
Column Three, Fourth Paragraph- Please advise
whether the statutory five criteria are to be addressed
in the plan.

Page 41433:
Column One, First Paragraph- OMHSAS supports the
proposal that, for the FY 2014-2015 application, states
will continue to receive their annual grant funding
even if they choose to only submit the required
section of their plan. This approach allows states the

Table 1 Required
Tabel 2 Required
Tabel 3 Requested
Table 4 NA
Table 5a NA
Table 5b NA
Table 5c NA
Table 6a NA
Table 6b Required
As was done for the FFY 2012 – 2013 plan,
states will be asked to include information
relating to the five criteria in the Statute,
including a description of children’s
services, within the structure of the 2014
2015 plan.

Thank you for your comment

Block Grant Comment Log (Continuous)
Health and
Substance Abuse
Services
47.

9/5/12

48.

9/5/12

49.

9/5/12

50.

9/5/12

additional time and technical assistance from SAMHSA
needed to be able to complete those sections where
additional information is requested (but not yet
required).
Page 41433:
Column Three, Second Paragraph, Second BulletOMHSAS favors the concept of an annual Behavioral
Health Barometer, which SAMHSA will prepare and
use with states for informing the planning process.
Using the report to highlight the impact of block grantfunded services will help move states toward ensuring
that grant funds are used to increase access, quality
and outcomes of care.
Page 41435:
Table 1, Column Three- OMHSAS finds the estimated
burden to the states of 35 hours to prepare and
submit the Uniform Reporting System to be
significantly understated. This is one of the more
complex and time-consuming responsibilities
associated with block grant data reporting.

Thank you for your comment

The estimate of burden was based on
historical information and analysis of
requested vs. required information

Page 41435
Table 2, Column 3- OMHSAS finds the estimated
burden to the states of 35 hours to prepare and
submit the Uniform Reporting System to be
significantly understated. This is one of the more
complex and time-consuming responsibilities
associated with block grant data reporting.

The estimate of burden was based on
historical information and analysis of
requested vs. required information

As a small sole practitioner, I find the burden of data

Through development of SAMHSA’s

Block Grant Comment Log (Continuous)
EdD., LPC, Arcadian
Resources

51.

9/5/12

Dr. Amy Stevens,
EdD., LPC, Arcadian
Resources

52.

9/5/12

Dr. Amy Stevens,
EdD., LPC, Arcadian
Resources

collection and reporting often is excessive. The level of
effort is beyond the level of effort I can expend and
still make a reasonable profit so I tend to avoid state
and federal programs that require too much data. I
believe a standardized protocol, similar to those used
by many Employee Assistance Programs (ie. One page
with easy check-offs) should be sufficient in most
cases. Service delivery should be primary and
administrative effort secondary. Otherwise access to
care is limited to the few organizations who can
handle the paperwork requirements.
Since I am a disabled veteran and military advocate, I
would suggest that funding for programming and
treatment of veterans and their families be made a
priority when possible. While there is much discussion
of PTSD and trauma, the reality is that mood disorders
and substance abuse are more prevalent than most
people would believe. Also, that families are much
more impacted by their service members’ duty than
often recognized. Caregiver services and child oriented
services are perhaps more important than focusing on
trauma services for military families. I have found that
many facilities do not identify individuals who are
impacted by their service or that of their significant
others. It may be reasonable to ask that at least one
question be asked regarding military service during
initial data collection.
I would also like to include encouragement to hire
veterans and veteran spouses as service providers and
state employees to be included in the block grant
language. Governmental agencies tend to have long
term employees. Service members (like myself) often
have significant challenges being hired by state
26

National Behavioral Health Quality
Framework, the agency is attempting to
reduce the data collection and reporting
burden on states and providers while
assuring we are able to indicate the uses
and outcomes of taxpayer dollars.

SAMHSA believes that this
recommendation is outside of the purview
of this FRN, however, SAMHSA is doing
significant work to meet the needs of
military families through itds Strategic
Initiative on Military Families.

Block Grant Comment Log (Continuous)

53.

9/6/12

Alixe McNeill, Chair,
National Coalition
on Mental Health
and Aging

agencies because geographic relocations are common
in our line of work. By the time we retire or discharge,
we are behind on establishing ourselves in
communities because we haven’t been there very
long. In thinking about successful mental health
interventions for veterans, it is well known that
military culture is unique and providers are more
accepted if they are veterans themselves. It would be
helpful to the veteran community if at least one
veteran is funded as a senior clinical specialist for
behavioral health services in each state. Additionally, I
would appreciate consideration of peer support
funding for each state for veterans if possible.
Our nation is aging rapidly and it is critical that
SAMHSA and other federal agencies focus greater
attention on the behavioral health needs of the
growing number of Older Americans. However,
noticeably lacking in the Federal Register Notice,
and the related guidance and application
instructions, is the previous SAMHSA commitment
of services across the lifespan. The Coalition
recognizes that within the Framework for Planning,
SAMHSA calls for states to address “Older Adults
with SMI”. The Coalition calls on SAMHSA to
encourage states to address the needs of older
adults for mental health promotion and prevention
and treatment of substance use disorders.
Adults 18 and over and children and adolescents are
mentioned throughout the documents with almost
no reference to older adults. This is inconsistent with
the recommendations regarding the SAMHSA Block
Grants in the Institute of Medicine Report “The
27

While SAMHSA has indicated several
populations specifically in the application,
with the exception of those statutorily
defined populations, states are encouraged
to look at the needs of all of the citizens to
identify gaps in service and then to
prioritize those populations specific to that
state. Since there is a separate HHS
agency devoted specifically to the needs of
older Americans, SAMHSA works closely
with that agency to address their needs.

Block Grant Comment Log (Continuous)
Mental Health and Substance Use Workforce for
Older Adults: In Whose Hands?” issued in July of this
year. The Coalition strongly supports the IOM
recommendations and urges SAMHSA to fully adopt
those regarding the Block Grants and those related
to SAMHSA in general as well.
The IOM Report cites many studies documenting that
older adults with mental health and/or substance use
disorders are an underserved population, that the
necessary workforce to address their needs does not
exist, and that current funding policies in Medicare
and Medicaid do not support current best practices of
care including many of those listed in the SAMHSA
National Registry of Evidence-Based Practices (NREPP).
These factors make it extremely important that
SAMHSA identify older adults as a distinct population.
Without specific language regarding older adults in the
SAMHSA documents related to the Block Grants states
may ignore their needs in the planning process for the
Block Grants or in developing the state insurance
exchanges.

54.

9/7/12

Arthur T. Dean,
Major General, U.S.

The four (4) purposes proposed for the Block Grant
funding fit well with the needs of older adults. The
issue is that older adults are not included in the Block
Grant planning and application process and
subsequent reporting requirements, proportionate to
their mental health and substance abuse needs. Again,
without designation of older adults as a distinct
population this is not likely to happen.
The new Uniform Block Grant Application

States will be allowed to use some of their
current CMHS Block Grant to support

Block Grant Comment Log (Continuous)
Army, Retired,
Chairman and CEO,
Community AntiDrug Coalitions of
America (CADCA)

makes the case for and explicitly includes
mental health promotion as a "priority
area" for planning and resource allocation
purposes, despite the fact that current law
for neither the SAPTBG nor the MHBG
includes any language to authorize
expenditures for this purpose.
SAMHSA clearly delineates on page 14 ofthe
document how states will and will not be
allowed to use some of their current MHBG
funds to support prevention and
promotion services, but provides NO
guidance about limiting or prohibiting the
use of monies from the SAPTBG for this
purpose.
This lack of clarity for the use of funds from
the SAPTBG for mental health promotion,
coupled with a pervasive emphasis on mental
health promotion throughout the
document,is at best confusing and at worst
could lead states to fund unauthorized
activities with SAPTBG funds, which are
intended solely for substance abuse
prevention and treatment programs and
services under current law.

mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health.

Block Grant Comment Log (Continuous)

55.

9/7/12

Arthur T. Dean,
Major General, U.S.
Army, Retired,
Chairman and CEO,
Community AntiDrug Coalitions of
America (CADCA)

56.

9/7/12

Patricia A. Rehmer,
MSN,
Commissioner, State
of Connecticut
Department of
Mental Health and
Addiction Services, A
Healthcare Service
Agency

CADCA recommends that if in fact mental health
promotion is to be kept in the Uniform
Application as a fourth priority, there must be
clarity regarding the fact that current law does
not authorize this activity to be funded from
the SAPTBG. Verbiage must be explicitly added to
specifically clarify that scarce resources for
substance abuse prevention from the
statutorily required 20% prevention set aside in
the SAPTBG shall NOT be reallocated in this
Uniform Application to mental health
promotion activities.
As drafted, the Uniform Application includes
language concerning SAMHSA's proposed
Budget initiatives for FY 2013 which have not
been approved by Congress. CADCA
recommends that all of this language be
stricken pending definitive congressional
action on these proposed changes.
The application as proposed and detailed in the draft
guidance document contains reference to states
“directing Block Grant funds toward four purposes”
including to fund “priority treatment and support
services for individuals without insurance” and “to
fund… services not
covered by Medicaid, Medicare or private insurance
offered through the exchanges..” What is SAMHSA’s
expectation in the first year (FY 2014) of the biannual
grant application for States to redirect Block Grant
funds? With the new submittal date of April 1, 2013,
this shift in funding priorities will be difficult for

In the Background section, SAMHSA has
described our vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

SAMHSA fully expects that states will need
time to establish a plan to direct funds
towards the four purposes identified. It is
the expectation that states will describe for
SAMHSA their plan and implementation
steps.

Block Grant Comment Log (Continuous)
Connecticut given its current timeline for executing
contracts and budgetary processes. Additionally the
FFY 2014 grant period will cover only
the very start of major health care reform
initiatives timed for January 2014.
57.

9/7/12

Patricia A. Rehmer,
MSN,
Commissioner, State
of Connecticut
Department of
Mental Health and
Addiction Services, A
Healthcare Service
Agency

58.

9/7/12

59.

9/7/12

The proposed Block Grant requirement that States
develop strategies that will monitor the
implementation of health reform as to whether
individuals have better access to mental health and
addiction services is certainly of primary importance.
As we have experienced in the past, implementation
of major system changes (e.g., the transition from
State Administered General Assistance to Medicaid
Low Income Adults) requires some time to
understand the full and unrealized implications. We
ask that SAMHSA appreciate the magnitude of such a
change as health reform and provide States sufficient
time in managing that change.
The continued option to submit a
combined plan and for that plan to be
submitted for a two-year cycle is attractive
to the ODMHSAS.

SAMHSA fully recognizes the magnitude of
the change that will occur as a result of
health reform and is committed to working
with the states on tracking the implications
of that change.

Regarding the timeline for submission, we
look forward to more closely aligning the
block grant funding and planning cycle
with our state fiscal year, but have
some concerns. Intensive work will be
required to prepare an application and
plan during the same time frame in which

SAMHSA will work with the states to
support the new timeline for submission of
the plan.

Thank you for your comment

Block Grant Comment Log (Continuous)

60.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

61.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse

much of our resources and efforts must be
focused on the legislative session, as well
as during the time that numerous federal
discretionary grant applications are due.
That will be an addition workload challenge
for which we must prepare.
The estimated reporting burden published
in the Federal Register likely
underestimates the actual burden
Oklahoma expects in response to the
required planning and application
procedures. For example, in 2011
Oklahoma submitted a combined
application and utilized a team of six staff
members to coordinate and draft all
responses. In addition to that, an internal
review and editing process· was required
to submit a quality document. Based on
that experience, the state would expect
the number of hours required to
complete the planning and application
process to be in excess of the 282 hours
estimated in the Register Likewise, the
burden to properly compile data and
complete all reports, including the URS
tables, will greatly exceed that estimated in
the draft guidance.
As with many of our colleague states, we support
continued focus on the needs of children, youth and
their families, and encourage SAMHSA and related
block grant guidance to address the following:
1. Clarify state activities per se proposed to
32

The estimate of burden was based on
historical information and analysis of
requested vs. required information and will
be updated as changes are required.

As was done for the 2012 – 2013 plan,
states will be asked to include information
relating to the five criteria in the Statute,
including a description of children’s
services, within the structure of the 2014
2015 plan.

Block Grant Comment Log (Continuous)
Services

62.

9/7/12

63.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services
TerriL. White,
ODMHSAS
Commissioner,
Oklahoma

benefit children, youth and their f amilies.
Oklahoma found the requirements in the
former MHBG guidance helpful, as these
directed states to clearly and intentionally
address the needs of children within the
context of the required criteria.
2. Encourage systems to focus on family
health promotion and prevention in a
broad-based public health model. This
approach would more likely impact communitylevel risk factors and identifies children and
families in need earlier than often occurs in
service systems built around treatment delivery.
3. Continue to support states in identifying
the best methods to assist youth and their
families as they transition between systems of
care, and as they transition into the adult
delivery system and culture.
4. Support the delivery of evidence based
and promising practices through important
infrastructure development such as training,
protocol refinements and consultation.
Throughout the guidance document the phrase "the
state should" is frequently used.
This creates
potential confusion between what is actually required
by statute and what SAMHSA recommends the state
include in the plan and application. We would
encourage clearer language regarding what is
required and what is not.
Given the differences between statutory language for
the MHS and the SAPT block grants, there are
instances throughout the proposed guidance that

References to MH promotion and
prevention are included in the guidance,
along with the importance of evidence
based practices. SAMHSA will continue to
support states in these activities through its
ongoing Technical Assistance programs.

SAMHSA has indicated in the application
background sections what information is
requested and what is required.

SAMHSA is in the process of developing
written guidance for states in the
expectations for filling out the application

Block Grant Comment Log (Continuous)
Department of
Mental Health and
Substance Abuse
Services

64.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

65.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

66.

9/7/12

TerriL. White,
ODMHSAS

necessitates distinction between the two.
For
example, references to "substance abuse and/or
mental disorders" (emphasis added) when
referencing required populations may be inaccurate
in terms of actually required populations described in
the statutes. This infers that persons with mental
disorders are required populations to which some
services must be provided.
The focus on program integrity and accountability is
certainly important to Oklahoma. The proposed
guidance is clear that SAMHSA expects states to
operate with this as a central tenant. However, it
will be important for SAMHSA, in its administration of
the block grant programs, to acknowledge and work
with what many states, including Oklahoma, have in
place within existing frameworks.
Otherwise,
additional requirements will result, which will
duplicate or add burden to work already under way.
This seems would counter to the block grants' intent
to provide states with flexibility and umqueness
needed m their particular business, cultural and
service environments.
Oklahoma is a rich data state and the ODMHSAS has
enjoyed a long tradition of working with SAMHSA
and partners within the state to develop a robust
and dynamic reporting, accountability and data
analysis system. We look forward to the additional
information data points and measurement elements
SAMHSA will propose as referenced in the
guidance. We caution that these should not duplicate
or add avoidable burden to the state.
Absent in the proposed guidance is the option for
states to participate in a consultative peer review
34

and this issue is included in that guidance.

SAMHSA fully supports and intends to
acknowledge the existence of the states
own framework for program integrity and
accountability, and working with that
framework.

Through development of SAMHSA’s
National Behavioral Health Quality
Framework and the Behavioral Health
Barometer, the agency is attempting to
reduce the data collection and reporting
burden on states and providers.

SAMHSA will retain some elements of the
consultative peer review process and will

Block Grant Comment Log (Continuous)
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

67.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

68.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

process, which Oklahoma considered a valuable
element previously included in the Center for Mental
Health Services block grant approval process.
Oklahoma requests that some elements of that
helpful system be retained or redesigned within the
newly combined block grant administrative
framework.
References to primary prevention and a perceived
new emphasis on prevention/promotion for mental
health are welcomed. More clarity, discussion and
planned work within existing prevention frameworks
will be important to Oklahoma. Further, references
to the use of Mental Health Block Grant funds for
prevention activities directed only to persons with
serious mental illness (SMI) or serious emotional
disturbances (SED) is a challenging concept. More
flexibility and allowance seems appropriate and viable
for use of block grant funds through a population or
public health oriented approach - rather than by
disability or individual treatment delivery approach.

work with the states on utilizing that
framework.

Like SAMHSA, Oklahoma values the importance of a
useful planning process, not only in response to the
block grant requirements, but in our overall
approach to assure improved access to prevention
and treatment services. Oklahoma would encourage
the guidance to be more open to other frameworks
for planning that would better utilize planning already
under way in the states. The specific framework

SAMHSA is supporting the use of the
planning steps found in the Strategic
Prevention Framework (SPF).

Block Grant Comment Log (Continuous)
proposed in the guidance, although somewhat
broad, does create added burden due to the
possibility of duplicate or multiple plans for the state.

69.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

Oklahoma is highly supportive of SAMHSA's intention
to utilize the planning methods and infrastructure of
the Strategic Prevention Framework (SPF) for
prevention services. The SPF should be utilized in
mental health promotion and prevention service
planning and implementation. In addition, the SPF's
utilization of the public health approach to achieve
community-level outcomes should be emphasized in
the Block Grant application to require/allow states to
prioritize
community-level
strategies
and
measure/report on community-level outcomes.
Based on lessons learned during the FFY2012-2013
block grant planning process, Table 1 for Priority
Areas and Indicators may be limiting and potentially
contradictory to a broader approach to planning. The
guidance and framework for the table seem to limit
the goals and priorities possible for a state to
include in this matrix. Populations and priorities
broader than those traditionally attached to the SAPT
and MHS block grants continue to be integral to the
ODMSHAS mission and priority. To categorically
limit planning to SAMHSA or block grant populations
creates a need for multiple plans at the state level
and, hence, duplicative work.

The guidance does not limit the priorities
that the state can choose. Language that is
used is “At a minimum, the plan should
address the following populations
(required in Statute)” and “In addition to
the targeted/required populations and/or
services required in statute, states are
encouraged to consider…”
Authorizing legislation (42 USC300x-22, 23,
and 27and implementing regulation (45
CFR Part 96.124, 126, and 131)
identifies what is required for identified
targeted populations [pregnant women,
women with dependent children;
intravenous drug users].

Block Grant Comment Log (Continuous)
The application allows States to report on
other populations that they plan for and
deliver services.

70.

9/7/12

71.

9/7/12

72.

9/7/12

73.

9/7/12

SAMHSA will consider options for allowing
states to provide for broader approaches in
Table 1.
This is a requested table. States can
provide whatever level of data that are
currently available. Uniform definitions will
be available soon

Table 3 appears to require substantial work for
states to complete. Some services may currently
be bundled or included with other services making it
difficult to specify the services, unit quantity, or
expenditures listed the table. Uniform definitions
and scope of required reporting will be helpful to
minimize workload and improve utility.
To an extent, Tables 5b and 5c seem potentially
duplicative of other tables. However, the proposed
format may be easier to follow. Oklahoma suggests
avoiding duplicate reporting where possible.

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services
TerriL. White,
ODMHSAS
Commissioner,

Additional guidance in the form of definitions and
examples would be helpful for states to efficiently
prepare information for Table 6b.

The tables are not duplicative of other
tables. States may choose to input funds
for the six strategies OR the IOM
categories. States must include funds for
tobacco, section 1926 on Table 5a. If the
State chooses the IOM categories/
populations, they must use Tabe 5b. Some
States report on both tables, the six
primary prevention strategies and the IOM.
Definitions and examples will be provided
in the instructions that will be provided for
Table 6b

As referenced earlier, Oklahoma supports the
refinement of quality and accountability measures.
The workload and utility of responses requested in

SAMHSA looks forward to working with
states in the refinement of quality and
accountability measures.

Block Grant Comment Log (Continuous)
Oklahoma
Department of
Mental Health and
Substance Abuse
Services

74.

9/7/12

75.

9/7/12

76.

9/7/12

TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services
TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and
Substance Abuse
Services
TerriL. White,
ODMHSAS
Commissioner,
Oklahoma
Department of
Mental Health and

item G. Quality are difficult to assess without more
information on the type of elements SAMHSA will
develop. Again, it is important to leverage data
already collected and utilized - in particular data
utilized by other SAMHSA grant projects. Oklahoma
recommends that meetings on data not be
separated out from other systems' development
meetings. This would help planners, advocates and
data staff work in concert to minimize duplication
and arrive at useful measures of quality. Also, it is
unclear if states will be limited to selecting priority
areas from the Behavioral Health Barometer when
finalized by SAMHSA?
Responses requested for item K. Primary and
Behavioral Health Care Integration Activities are
numerous and should be reduced. Some of these
will likely duplicate information requested under item
L. Health Disparities.
Oklahoma is always eager to advocate for more
effective systems of care for children, youth and their
families. However, details requested as responses
under item 0. Children and Adolescents Behavioral
Health Services seem to duplicate reporting by
states with which SAMHSA already has a
relationship through the. Children's Mental Health
Initiative (CMHI) grants.
Given the uniqueness of working with multiple tribal
entities within a state, it is helpful, as stated in item
P. Consultation with Tribes, that SAMHSA guidance is
not requesting information that is overly detailed or
prescriptive.
Oklahoma encourages SAMHSA to
38

As envisioned, the Barometer will include
and report on data collected through
SAMHSA and other federal survey efforts,
and thus should not represent any
additional data collection burden to states.

We have reduced the number of responses
requested for item K from 13 to 6.
Any questions that appears to the state to
be duplicative can be referenced in other
relevant sections
SAMHSA recognizes that there is some
overlap and integration with the focus on
children’s services in the BG and in the
CMHI grants, as there should be. States are
encouraged to use information they have
available through their CMHI grants to
provide information for Item O
Thank you for your comment

Block Grant Comment Log (Continuous)
Substance Abuse
Services
77.

9/7/12

78.

9/7/12

79.

9/7/12

continue to honor the flexibility around this
important matter as currently proposed in the
guidance.
Oklahoma recommends that SAMHSA minimize
information requested under U. Technical
Assistance Needs and, instead, delay discussions on
technical assistance until the review of each states'
plans and applications are complete. To do so will
allow for a more peer consultative approach to
identify needs and request related assistance.
Regarding the listing of Council members, Oklahoma
encourages the guidance for the table on page 87 to
be revised to clearly reflect actual language for
required memberships as stated in the statute. Some
types of members on the table as drafted are not
required.
Oklahoma
recommends revisions to
the
terminology proposed
in
the
membership
composition table on page 89.
1. The reference to members from diverse
racial and LGBTQ populations is potentially
confusing and creates a dilemma as to
which category members should be
ascribed. These characteristics are
important for the overall richness and
diversity on the council. Perhaps a
question could be added to discuss this in
narrative form rather than arbitrarily
assigning people to these categories.
2. The term 'leading state experts' is also
confusing and somewhat arbitrary. This
39

We have reduced the number of responses
from 5 to 3

States will only be held accountable for
membership representatives included in
the Statute. Other cagegories of
membership were included to encourage
representation on the Council. The table
has been modified to provide clarity.
SAMHSA agrees with the
recommendations that request for number
of individuals and providers from diverse
racial, ethnic, and lgbtq in the table will
skew the calculation of the percentage of
consumers/state members. SAMHSA has
moved this information to the bottom of
the table and removed it from the
calculation.
“Leading state expert”will be deleted.
Federally Recognized Tribe Representatives
are individuals who are officially designated
by the Tribe to sit on the Council.

Block Grant Comment Log (Continuous)

80.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

should be deleted. Oklahoma considers
many current and future council members
as experts - especially people in recovery
and their family members. Is their
expertise less valued than other experts
who might receive that designation on this
form?
3. The membership categorization for
"Federally Recognized Tribe Representatives"
needs additional clarification. If the intent is to
identify Council members who have been
officially designated as a representative from
their tribal government, then that should be
described in the guidance. Otherwise, this
could be confused with council members who
happen to be tribal members.
Recommendation One: Full public
transparency in all block grant planning
processes States and Territories will be
required to post on a publicly accessible
website the following information:
• Composition of membership of
block grant planning committee –
Website information shall include
names of individuals, constituency
and/or agency representation
(family, youth, adult, etc).
• Announcement of Block Grant meetings
and inclusion of time for public comment Announcements of block grant meetings
40

Section X of the planning section requires
that states will provide opportunity for the
public to comment on the State BG Plan,
facilitate comment from any person during
the development of the plan and after the
submission of the plan.

Block Grant Comment Log (Continuous)
will include encouragement for the public
to attend. Block grant meetings shall
include time on the agenda for public
comment.
• Process utilized for arriving at funding
recommendations - The process used to
develop and implement Block Grant funding
decisions will be fully described.
Recommendation Two: Equity in funding
between child and adult mental health
services Block grant plans will exhibit equity
in funding for children's mental health
services that is proportional to each state's
child/youth population at a minimum but
also takes into account level of need of
children and youth with serious emotional
challenges and their families.

81.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

82.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

Recommendation Three: Comprehensive Care
Coordination
Comprehensive care coordination for
children and youth with serious emotional
challenges and their families will be
considered a funding priority.

Section O includes encouragement to the
states to use this model and asks for
information to determine the states’
activities in these areas

83.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

Recommendation Four: Wraparound Child and
Family Teams
Wraparound Child and Family Teams will be
supported as the vehicle to develop family-driven
and youth-guided plans to further coordinate a
family driven, youth guided, comprehensive

This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model

SAMHSA believes that states must have the
flexibility to design funding for mental
health services for children based upon
that states identified need.

Block Grant Comment Log (Continuous)

84.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

85.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

86.

9/8/12

87.

9/8/12

Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network
Scott BryantComstock,
President and CEO,
Children’s Mental
Health Network

community-based ongoing service planning and
implementation process.
Recommendation Five: Agency Contracts Must be
Monitored
Contracting between the state and local entities
must include language and conditions that support
the active utilization of Wraparound Child and
Family Teams, Care Review, as well as other areas
that support system of care principles. The
responsible organization must monitor all service
provider organizations to ensure adherence to
active utilization of wraparound child and family
teams and care review.
Recommendation Six: Family and Youth Partners
Specific funding strategies will be identified to
support youth and family support like Family
Partners or Youth Peer Support who provide
informal care coordination, navigation,
engagement and linkage to services for children,
youth and families.
Recommendation Seven: Care Review Process
A community based Care Review process must be
in place with active representative participation
and responsibility from all major child-serving
agencies, organizations, youth and families.
Recommendation Eight: Family-Driven and YouthGuided
Plans will embrace a family-driven and
youth-guided approach, which requires
among other things:
• Stigma reduction - A clear plan to reduce
stigma and engage in community-based

SAMHSA believes that states should have
the flexibility to determine the contract
language that is used.

This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model

SAMHSA believes that states must have the
flexibility to determine this.

This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model

Block Grant Comment Log (Continuous)

88.

9/10/12

Sharon Kramer,
M.Ed., CPP,
Executive Director,
Manatee County
Substance Abuse
Coalition

health promotion activities.
•
Family and youth involvement in
Governance - Clear evidence of parents and
youth involved in local governance around
the design and delivery of services and
supports to youth with emotional challenges
and their families.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.
MCSAC recommends that if in fact mental

Block Grant Comment Log (Continuous)
health promotion is to be kept in the Uniform
Application as a fourth priority, there must be
clarity regarding the fact that current law does
not authorize this activity to be funded from
the SAPTBG. Verbiage must be explicitly added
to specifically clarify that scarce resources for
substance abuse prevention from the
statutorily required 20% prevention set aside
in the SAPTBG shall NOT be reallocated in this
Uniform Application to mental health
promotion activities.
89.

9/10/12

90.

9/10/12

Sharon Kramer,
M.Ed., CPP,
Executive Director,
Manatee County
Substance Abuse
Coalition
Karen A. Murray,
County Coalition
Director, The Butler
County Coalition for
healthy, safe &
drug-free
communities

As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which have not been approved by Congress.
MCSAC recommends that all of this language be
stricken pending definitive congressional action on
these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of

In the background section, SAMHSA has
described our vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.
States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of

Block Grant Comment Log (Continuous)
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.

91.

9/10/12

Karen A. Murray,
County Coalition
Director, The Butler
County Coalition for
healthy, safe &
drug-free
communities

92.

9/10/12

Pat VanOflen,
Coalition
Coordinator,

The BCC recommends that if in fact mental health
promotion is to be kept in the Uniform Application as a
fourth priority, there must be clarity regarding the fact
that current law does not authorize this activity to be
funded from the SAPTBG. Verbiage must be explicitly
added to specifically clarify that scarce resources for
substance abuse prevention from the statutorily
required 20% prevention set aside in the SAPTBG shall
NOT be reallocated in this Uniform Application to
mental health promotion activities.
As drafted, the Uniform Application includes
language concerning SAMHSA's proposed
Budget initiatives for FY 2013 which have not
been approved by Congress. The BCC
recommends that all of this language be
stricken pending definitive congressional
action on these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
45

substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness

Block Grant Comment Log (Continuous)
Coalition for Safe
and Drug-Free
Fairfield

resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.
CADCA recommends that if in fact mental
health promotion is to be kept in the Uniform
Application as a fourth priority, there must be
clarity regarding the fact that current law does
not authorize this activity to be funded from
the SAPTBG. Verbiage must be explicitly added
to specifically clarify that scarce resources for
substance abuse prevention from the
statutorily required 20% prevention set aside
in the SAPTBG shall NOT be reallocated in this

prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..

Block Grant Comment Log (Continuous)
Uniform Application to mental health
promotion activities.
93.

9/10/12

Pat VanOflen,
Coalition
Coordinator,
Coalition for Safe
and Drug-Free
Fairfield

As drafted, the Uniform Application includes
language concerning SAMHSA’s proposed
Budget initiatives for FY 2013 which have not
been approved by Congress. CADCA
recommends that all of this language be
stricken pending definitive congressional
action on these proposed changes.

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

94.

9/10/12

Michael J. Kramer,
Judge, Noble
Superior Court, Div.
2

The encouragement of including mental health
promotion as a priority area when current law does
not allow expenditure of either Mental Health Grant
and Substance Abuse Block Grant funds for mental
health promotion is puzzling and can place states in a
precarious position if they plan and/or spend their
block grant funds illegally. The instructions need to be
clear about areas funds may legally be utilized and
provide proper guidance.

SAMHSA needs to ensure that all children in America
hear the substance abuse prevention message and
receive inoculation and regular booster shots to
reduce substance use among youth. On a daily basis I
see the failings of our prevention system in the people
I send to probation, treatment, or prison. The costs to
our system for treatment of addiction and the medical
costs for the ravages of addition on the body are
enormous.
Because I believe every child deserves a

Block Grant Comment Log (Continuous)
chance to a happy and productive future, I
object to any reduction or watering down of
substance abuse prevention to our youth.
95.

9/10/12

Sarah C. Dinklage,
LICSW, Executive
Director, Rhode
Island Student
Assistance Services,
a division of
Coastline EAP

The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.
CADCA recommends that if in fact mental health
promotion is to be kept in the Uniform Application as
a fourth priority, there must be clarity regarding the
fact that current law does not authorize this activity to
be funded from the SAPTBG. Verbiage must be
explicitly added to specifically clarify that scarce
48

Block Grant Comment Log (Continuous)

96.

9/10/12

97.

9/10/12

Sarah C. Dinklage,
LICSW, Executive
Director, Rhode
Island Student
Assistance Services,
a division of
Coastline EAP
Greg Puckett,
Executive Director,
Community
Connections, Inc.

resources for substance abuse prevention from the
statutorily required 20% prevention set aside in the
SAPTBG shall NOT be reallocated in this Uniform
Application to mental health promotion activities.
As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which have not been approved by Congress.
CADCA recommends that all of this language be
stricken pending definitive congressional action on
these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
SAMHSA clearly delineates on page 14 of the
Abuse Block Grant must be used for
document how states will and will not be allowed to
substance abuse primary prevention
use some of their current MHBG funds to support
activities by the state. Many evidencedprevention and promotion services, but provides no
based substance abuse programs have a
guidance about limiting or prohibiting the use of
positive impact on the prevention of
monies from the SAPTBG for this purpose. By not
substance use and abuse as well as other
clarifying this use of funds from the SAPTBG for mental health and social outcomes such as
health promotion, coupled with a pervasive emphasis
education, juvenile justice involvement,
on mental health promotion throughout the
violence prevention and mental health..
document, it seems confusing and could lead states to
fund unauthorized activities with SAPTBG funds, which
are intended solely for substance abuse prevention
and treatment programs and services under current
law. As a community based agency that effectively
49

Block Grant Comment Log (Continuous)
leverages these funds to serve our communities to the
maximum extent possible, we are concerned that this
would mean a decrease in the prevention funding
available at the local level where it matters most.

98.

9/10/12

Greg Puckett,
Executive Director,
Community
Connections, Inc.

99.

9/10/12

Cindy Grant,
Director,
Hillsborough County
Anti Drug Alliance,
Inc.

We recommend that if in fact mental health
promotion is to be kept in the Uniform Application as
a fourth priority, there must be some clarity regarding
the fact that current law does not authorize this
activity to be funded from the SAPTBG. Verbiage must
be explicitly added to specifically clarify that scarce
resources for substance abuse prevention from the
statutorily required 20% prevention set aside in the
SAPTBG cannot be reallocated in this Uniform
Application to mental health promotion activities.
As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which have not been approved by Congress.
Community Connections recommends that all of this
language be stricken pending definitive congressional
action on these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.
States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidenced-

Block Grant Comment Log (Continuous)
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.

100.

9/10/12

Cindy Grant,
Director,
Hillsborough County
Anti Drug Alliance,
Inc.

101.

9/10/12

Jackie Griffin, MS,
LiveFree! Executive
Director

HCADA recommends that if in fact mental health
promotion is to be kept in the Uniform Application as
a fourth priority, there must be clarity regarding the
fact that current law does not authorize this activity to
be funded from the SAPTBG. Verbiage must be
explicitly added to specifically clarify that scarce
resources for substance abuse prevention from the
statutorily required 20% prevention set aside in the
SAPTBG shall NOT be reallocated in this Uniform
Application to mental health promotion activities.
As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which have not been approved by Congress.
HCADA recommends that all of this language be
stricken pending definitive congressional action on
these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and

based substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..

Block Grant Comment Log (Continuous)
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose. SAMHSA clearly delineates on page 14 of
the document how states will and will not be allowed
to use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.

102.

9/10/12

Jackie Griffin, MS,
LiveFree! Executive
Director

LiveFree! Pinellas recommends that if in fact mental
health promotion is to be kept in the Uniform
Application as a fourth priority, there must be clarity
regarding the fact that current law does not authorize
this activity to be funded from the SAPTBG. Verbiage
must be explicitly added to specifically clarify that
scarce resources for substance abuse prevention from
the statutorily required 20% prevention set aside in
the SAPTBG shall NOT be reallocated in this Uniform
Application to mental health promotion activities.
As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which have not been approved by Congress.
LiveFree! Pinellas recommends that all of this
52

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in

Block Grant Comment Log (Continuous)

103.

9/10/12

Gwendolyn W.
Brown, Chairman
and CEO, Genesis
Prevention
Coalition, Inc.,
Excellence in
Community Service

language be stricken pending definitive congressional
action on these proposed changes.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.
GPC recommends that if in fact mental health
promotion is to be kept in the Uniform Application as
a fourth priority, there must be clarity regarding the
fact that current law does not authorize this activity to
be funded from the SAPTBG. Verbiage must be
explicitly added to specifically clarify that scarce
resources for substance abuse prevention from the
statutorily required 20% prevention set aside in the
53

their planning process.
States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..

Block Grant Comment Log (Continuous)

104.

9/10/12

105.

9/10/12

Gwendolyn W.
Brown, Chairman
and CEO, Genesis
Prevention
Coalition, Inc.,
Excellence in
Community Service
Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

SAPTBG shall NOT be reallocated in this Uniform
Application to mental health promotion activities.
As drafted, the Uniform Application includes language
concerning SAMHSA’s proposed Budget initiatives for
FY 2013 which has not been approved by Congress.
GPC recommends that all of this language be stricken
pending definitive congressional action on these
proposed changes.
The manner in which the application is
written makes it unclear what items are
required by states and which items are
requested. The only item that is clearly
marked as being required are the
populations identified by existing Federal
law. ( Section 1911 of Title XIX, Part 8,
Subpart I of the Public Health Service
(PHS) Act (42 U.S.C. 300x-1) or Section
1921 of Title XIX, Part 8, Subpart II of the
PHS Act (42 U.S.C. 300x- 21) All other
sections are marked as "should" or
"encouraged" which can be subjective.
Just because someone "should" do
something, does not mean they are
"required" to do so. There are also new
forms this year that conflict, none of
which is marked as being "required" or
merely "requested." This becomes
significant in states where different
priorities may exist. If the purpose of this
permissive situation is indeed to allow a
state to "customize" its block grant, that
54

In the background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

SAMHSA has clarified what is requested
and what is required.

Block Grant Comment Log (Continuous)

106.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

107.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

aspect is not clear and emphasized.
In addition to the areas of emphasis being expanded,
how the funds from the block grant are to be used is
becoming more directed and perhaps less flexible.
This does not allow states to address what they see
and have been told are areas of concerns. DBH
believes the funds should be used for prevention and
non-treatment recovery such as housing, job
assistance, and recovery services that are not
considered "treatment". Primary prevention cannot
be directed to a population that is already diagnosed.
As such, it seems somewhat contradictory to indicate
that CMHBG funds may be used for prevention but
that prevention must be directed towards adults with
SMI and youth with SED. DBH prefers the original
concept of a highly flexible, highly state-defined,
block grant program.
There are populations, such as veterans and
specialized courts, that are to be served through the
block grant. These populations are being served by
other funds, agencies, and systems. It is unclear
what DBH's role, through the block grant, should be
in serving these populations. We recommend focus
in areas otherwise unserved. Further, it is of
particular concern the requirement for DBH to
consult with tribes to ensure that DBH's programs
meet the needs of the tribes when the law does not
require states to assist tribes. That is generally an
obligation of the federal government. Consultation
with the tribes is a new obligation placed on the
states that will require additional resources.
55

States will be allowed to use some of their
current CMHS Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..
The populations identified in the Block
Grant application were selected based on
statute, Section 4302 of the Affordable
Care Act and the Secretary’s Action Plan for
Eliminating Racial and Ethnic Disparities. In
addition to the populations identified in the
Block Grant application and these HHS
documents, states may report on additional
populations serviced that may be
vulnerable to disparities. It is the intention
that the planning process be inclusive of
the broader populations, but the BG be
focused on those who are unserved.
It is up to the state to define its populations

Block Grant Comment Log (Continuous)

108.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

109.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

Nebraska's Native American population is 1.3% of
the state's total population and they do not receive
block grant support, though receive $1.3 million in
state general fund resources. There are other
minority populations that have a larger presence in
the state whose needs also should be served. We
prefer state-defined populations of need.
In addition to the barometers and data collection
concerns outlined in the NASADAD comments, the
additional requirement to report services and cost
per specific person are not possible. Nebraska does
not have the ability to obtain this information as
Nebraska does not have a claims processing system
to track this information.

While client level data has been required for
substance abuse for several years, the transition to
reporting client level data for mental health will more
than double the preparation time of the previously
required reporting. Also the block grant grades on
performance indicators demonstrate substantial
change. The language seems subjective and it is
difficult for states to know meaningfully if they are
meeting the performance indicators. The field itself
simply has not caught up fully with the
implementation of full behavioral health integration.
Tension exists between the good and the possible in

of need in addition to the statutorily
defined populations.

Through development of SAMHSA’s
National Behavioral Health Quality
Framework and the Barometer (which will
include and report on data collected
through SAMHSA and other federal survey
efforts) the agency is attempting to reduce
the data collection and reporting burden on
states and providers. Specifically, SAMHSA
understands current limitations within
state data systems and is committed to
working with states to support efforts that
will provide necessary data whenever
possible.
SAMHSA understands these concerns and
will engage with states to develop
acceptable solutions.

Block Grant Comment Log (Continuous)

110.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

111.

9/10/12

Scot L. Adams,
Ph.D., Director,
Division of
Behavioral Health,
Nebraska
Department of
Health and Human
Services

this realm of data. Perhaps pilots with volunteer
states on measurement issues over time could help
ease in this transition.
A new emphasis is being placed on the ACA. This
presumes that as more individuals become Medicaid
eligible the states are directed to support nonsupported services. This seems premature. The
Governor of Nebraska has stated that Nebraska will
not expand Medicaid. There has not been a decision
if Nebraska will have its own health insurance
exchange. If this requirement is implemented in
Nebraska, new information technology systems
would be needed to gather the information
requested. The information requested is not DBH's
information and would need to be gathered from
other divisions in the agency such as Medicaid and
other departments such as the Department of
Insurance. The population that receives Medicaid
benefits or purchases insurance through health
insurance exchanges will always be changing. DBH
would need to be able to access other databases
daily or create a new system with daily data
exchanges to have the most updated information.
Perhaps an implementation timeframe of two to
three years hence would help ease this transition.
DBH also has concerns that due to sequestration,
fewer funds may be distributed than are anticipated.
That makes it very difficult to budget and plan
programs while also expanding the scope and breath
of the work to incorporate or place emphasis on
additional populations or administrative duties such
as tracking which individuals are being covered by

SAMHSA recognizes that the ability of
states to determine coverage will be a
longer-term effort that will develop over
time. SAMHSA will accept a discussion of
the implementation process as a sufficient
response.

SAMHSA fully understands that the
prioritization of populations and services
will be impacted by the funds available. It
is the process of prioritization that SAMHSA
is interested in.

Block Grant Comment Log (Continuous)

112.

9/10/12

Erica Leary, MPH,
Program Manager,
North Coastal
Prevention
Coalition, Serving
the Communities of
Carlsbad, Oceanside
and Vista

insurance or Medicaid. In light of this, these
application requirements appear premature.
Although we understand SAMHSA’s goal for
improving and updating the Substance Abuse
Prevention and Treatment Block Grant
(SAPTBG) and Mental Health Block Grant
(MHBG) Applications, we have concerns with
the potential unintended consequence of
diluting a critical focus on community- level
substance abuse prevention.
We were honored to meet with staff from
Senator Diane Feinstein’s office when they
came to visit our coalition in January 2012. As
a result of their visits with many agencies
across the country, they included the following
statement in the bipartisan report, “REDUCING
THE U.S. DEMAND FOR ILLEGAL DRUGS: A
REPORT BY THE UNITED STATES SENATE
CAUCUS ON INTERNATIONAL NARCOTICS
CONTROL, JUNE 2012” “However, we also believe that drug
prevention programs cannot stray too far
from their purpose. Unfortunately, the
Substance Abuse and Mental Health Services
Administration (SAMHSA) has been
attempting to do just that. In their Fiscal Year
2012 budget request, SAMHSA proposed
merging prevention funding for both
substance abuse and mental and
behavioral health into one joint account.
The Senate Appropriations Subcommittee on Labor,
58

Block Grant Comment Log (Continuous)
Health and Human Services,
Education and Related Agencies responded
with report language stating that this structure
“would be detrimental to the specific
programmatic and policy expertise of each
center, especially as it relates to substance
abuse prevention and substance abuse
treatment.” Ultimately, Congress wisely
decided not to merge prevention
funding for substance abuse and mental and
behavioral health in the 2012 budget that
President Obama signed into law. The Caucus urges
that SAMHSA not merge substance abuse and mental
health prevention programs in future budget
proposals. Doing so would only reduce the impact of
each program.”

113.

9/10/12

Debbie Moskovitz,
Project Director ,
Council Rock
Coalition for Healthy
Youth

Substance abuse prevention coalitions play a critical
role in addressing community conditions that
contribute to alcohol, tobacco, marijuana and other
drug problems. Research has demonstrated that
substance abuse prevention coalitions make an impact
and are cost effective. It is important that their role in
universal, community level prevention efforts be
enhanced and strengthened, and not potentially lost
among competing priorities and needs.
The new Uniform Block Grant Application makes the
case for and explicitly includes mental health
promotion as a “priority area” for planning and
resource allocation purposes, despite the fact that
current law for neither the SAPTBG nor the MHBG
includes any language to authorize expenditures for

Block Grant Comment Log (Continuous)
this purpose.
SAMHSA clearly delineates on page 14 of the
document how states will and will not be allowed to
use some of their current MHBG funds to support
prevention and promotion services, but provides NO
guidance about limiting or prohibiting the use of
monies from the SAPTBG for this purpose.
This lack of clarity for the use of funds from the
SAPTBG for mental health promotion, coupled with a
pervasive emphasis on mental health promotion
throughout the document, is at best confusing and at
worst could lead states to fund unauthorized activities
with SAPTBG funds, which are intended solely for
substance abuse prevention and treatment programs
and services under current law.

114.

9/10/12

Debbie Moskovitz,
Project Director ,
Council Rock
Coalition for Healthy

families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for
substance abuse primary prevention
activities by the state. Many evidencedbased substance abuse programs have a
positive impact on the prevention of
substance use and abuse as well as other
health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health..

In the background section, SAMHSA has
described our vision for future initiatives
which can give both context and
information to states as they engage in

Block Grant Comment Log (Continuous)
Youth

115.

9/11/12

Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont
Department of
Health

116.

9/11/12

Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont

recommends that all of this language be
stricken pending definitive congressional action
on these proposed changes.
Vermont appreciates the following:
Emphasis and flexibility of the Block Grant to
strengthen systems and approaches to
improve care coordination for individuals with
substance abuse and mental issues.
Focus of the block grant fill gaps that remain
through/after health reform, i.e., 1) priority
treatment and support services for individuals
without insurance, 2) for services not covered
by insurance; 3) prevention activities; and 4)
performance and outcome data and planning.
Support of block grant for transition
challenges, including SAMHSA staff functions
and support to states, and HOPEFULLY similar
state-level transitions and supports.
Separate applications for Mental
Health and Substance Abuse
Authorities to continue to support
more effective, specialized support to
targeted populations, while
collaborating and/or coordinating to
ensure continuum of care for all
Vermonters with SA and/or MH issues.
There are too many purposes identified: The
introduction to the Block Grant states that the
proposed revisions are to “EXPAND the areas of
focus”. Furthermore, the purpose is to meet
SAMHSA’s need to “assess the extent to which states
plan for and implement the ACA”. And finally the

their planning process.

Thank you for your comment

SAMHSAs purposes are consistent in our
emphasis on the role of the state authority
to engage in a planning process which looks
at the state’s population, the availability of
various forms of reimbursement and
coverage on access to and receipt of

Block Grant Comment Log (Continuous)
Department of
Health

117.

118.

9/11/12

Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont
Department of
Health

scope of the revision is aimed to determine whether
the Block Grant funds are being directed toward the
four purposes of the grant.
RECOMMENDATION: SAMHSA should
streamline the purpose for the revisions,
namely to address the major challenges the
state will face as it transitions through health
reform, and thereby simplify the reporting
requirements.
Every change, especially additional requirements
without corresponding deletions spreads resources
too thin and risks reducing effectiveness and impact.
RECOMMENDATION: The major reporting
requirements of the block grant application
should remain consistent for at least a 4-5 year
windows, and reflect key priorities of any
current Administration, with reporting in one
year or two year increments across that 4-5
year period. States require sufficient time to
shape plans, implement programs and
strategies, and to monitor change.
The coming year and on through health reform
reflects a massive amount of systems, process and
program changes.
RECOMMENDATION: The major focus of revisions for
FY14-15 should narrowly focus on addressing
transition challenges, and specifically how the state
will address the four Block Grant purposes.
Additionally, it may be reasonable to also require
states to report/comment on the specified
62

services, and assure program integrity and
accountability.

SAMHSA has been consistent in the
continuation of the major reporting
requirements, reflecting the key priorities
of the Administration.

SAMHSA has included sections of
requested information for those states who
are able to provide it. There is no penalty
to the state if it is unable to provide that
information.

Block Grant Comment Log (Continuous)

119.

9/11/12

Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont
Department of
Health

environmental factors of health reform, namely
coverage for M/SUD Services, Insurance exchanges,
and program integrity.
An example: All “additional” optional
information under the current context of
rapid, overwhelming change is clearly
unimportant, and therefore, excessive and
unnecessary at this time and should be
eliminated from the application.
SAMHSA should avoid introducing new
themes or limit them to one or two that are
most closely associated with the health reform
transition challenges – e.g., primary and
behavioral care integration.
SAMHSA should weigh the relative
importance of any new themes
compared to CFR 45 Goals 1-17, and
either substitute these for the “new”
themes or limit any new ones to one or
two additional themes that will remain
unchanged for two or more years.
There are multiple tiers of assessment, planning and
reporting that do not easily relate to one another or
work in a streamlined way to achieve real progress
toward accomplishing one or two key goals.
RECOMMENDATION: SAMHSA needs to clarify the
connection between all the tiers of assessment,
planning and reporting, including 1) the state needs
and assessment (to which I hope goals and state
priorities emerge; 2) the four purposes of the Block
Grant; 3) the “state priorities” previously presented in

SAMHSA has indicated the relationship
between the identified elements in the
application in the background section.
SAMHSA supports the state authority as
the primary policy driver in the state and
believes that the four purposes are
consistent in our emphasis on the role of
the state authority to engage in a planning
process which looks at the state’s full
population, the availability of various forms
of reimbursement and coverage on access

Block Grant Comment Log (Continuous)
Tables 2 and 3; 4) CFR 45 statutory regulations 1-17
(currently disconnected to other planning tiers unless
states embed them as we did in Vermont); 5) other
required “fishing expedition” reporting requirements
also disconnected to the four purposes or state
priorities (e.g., Narrative sections A-N); and 6)
financial and other data reporting in their own
multiple tiers. For a small state without a fully
dedicated Block Grant staff, these numerous and
multi-tiered requirements are very burdensome.
Without clarity about the relationship
between these various elements and tiers, the
application seems more like a fishing
expedition to gathering information on
systems and program issues, and less of a road
map to establishing a well-structured road
map (or plan) to achieve data-driven goals.
It is hard to see how financial, operational and
managerial decision making relate to the
assessed state priorities previously presented
in Tables 2 and 3 or described in planning
narrative Step 1 and 2.
Intended use has been disassociated from
progress and compliance.
The requirement for financial projections for
intended use and planned expenditures for
areas of focus yet developed are very difficult
to calculate reasonably.
Technical assistance needs should
focus on transitions through health
reform and support in meeting goals in
the midst of significant and fast paced

to and receipt of services, and assure
program integrity and accountability.

Block Grant Comment Log (Continuous)

120.

121.

122.

9/11/12

Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont
Department of
Health
Barbara Cimaglio,
Deputy
Commissioner,
Alcohol & Drug
Abuse Programs,
Vermont
Department of
Health

Marcia Fowler,
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

change.
BGSA issues: the weaving of the 2012 and 2013
reporting forms together is hard on the eyes and
complicated to sort through.

SAMHSA will work on simplifying the access
to the reporting forms in WebBGAS.

RECOMMENDATION: Keep these separated by
year, but possible to access from either year.

BGSA issues: the current structure requires states to
go into each form individually to print out and /or read
the instructions. This very time consuming and
difficult to review as a whole, plan and distribute
responsibilities.

SAMHSA is developing a comprehensive
instruction document for the Uniform
application that wil be disseminated to
States, as well as being uploaded to the
WebBGAS.

RECOMMENDATION: The Dashboard needs to
include a complete set of instructions and
forms for the entire application (the same as
those included with each individual form).
Address redundancies between federal statutory
requirements and new application format: The
Federal Register states (page 41432) that "while
there are some specific statutory requirements that
SAMHSA will look for in each submitted application,
SAMHSA intends to approach this process with the
goal of assisting states and Territories in setting a
clear direction for system improvements over time,
rather than as a simple effort to seek compliance
with minimal requirements." We did not find. this to
be the case in preparing the FY2012-2013 State
Plan. States were instructed after the application
instructions were issued that they needed to
65

SAMHSA is developing a comprehensive
instruction document for the Uniform
application that wil be disseminated to
States, as well as being uploaded to the
WebBGAS. This instruction will include a
grid that will indicate which sections of the
plan would be consistent with and would
provide information relating to each of the
5 Criteria.
Authorizing legislation (42 USC s/s 300x22(a)) and Implementing legislation (45 CFR
96.125) identifies what is required by

Block Grant Comment Log (Continuous)

123.

9/11/12

Marcia Fowler,
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

124.

9/11/12

Marcia Fowler,

complete Criteria 1-5 as previously done and were
not provided with any guidance on how to embed
these sections into the new format. This significantly
added to the burden of preparing the Plan and
lengthened the SFY2012-2013 State Plan document
by 15% over our previous submission. The FY20142015 Application further increases the redundancy
between statutory and new requirements. DMH
suggests that CMHS develop a crosswalk of
statutory and new requirements and provide
guidance to states on the development of a
cohesive plan that addresses all requirements while
eliminating redundancy. As an example, the
following sections of the application are addressed
in whole or in part within Criteria 1-5: Coverage
ofM/SUD Services, Use of Evidence in Purchasing
Decisions, Trauma, Justice, Primary and Behavioral
Health
Integration Activities, Health Disparities,
and Recovery.
Clarify instructions related to Child and Adolescent
Behavioral Health Services: DMH comprehensively
describes the child and adolescent system and
planning efforts throughout the State Plan, and
particularly in Criteria 1 and 3. DMH notes the
addition of Section 0: Children and Adolescent
Behavioral Health Services. Similar to the prior
bullet, DMH recommends that these instructions be
clarified
to address this redundancy.
Align Block Grant requirements with other

statute or regulation. Part of the intent of
the new BG application format is to
streamline planning information and not to
create redundancies. SAMHSA advises
States to contact State Project Officers for
recommendations on how best to
incorporate information related to
statutory requirements and new/required
information into the SABG application
format.

For the FFY 2014 – 2015 Plan CMHS will
provide instructions on how to include the
5 Criteria in the Statute into the SAMHSA
Block Grant Plan. This instruction will
include a grid that will indicate which
sections of the plan would be consistent
with and would provide information
relating to each of the 5 Criteria

SAMHSA is currently working on a

Block Grant Comment Log (Continuous)
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

125.

9/11/12

Marcia Fowler,
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

requests by SAMHSA: The new planning sections
of the State Plan contain information that is also
requested by SAMHSA throughout the year,
principally through the NRl State Profile and
other surveys. The NRI State Profiles are a
significant burden on states and
occurs during the same timeframe that states will be
preparing their FY2014-2015 State Plans. DMH
utilizes its State Plan to a large extent in completing
the State Profiles and "copies and pastes" sections
from the State Plan into the State Profiles. DMH
recommends that SAMHSA and NRl utilize the
existing State Plans to the fullest extent possible
prior to requesting additional information from
states.
Clarify use of the Behavioral Health Barometer and
the National Quality Behavioral Health Framework
in the planning process: DMH is concerned with the
lack of information regarding these two systems and
their potential impact on the planning process.
DMH places high value on performance data and is
developing a comprehensive structure to measure,
monitor and support improvement of our stateoperated and contracted services. The Block Grant
application (page 71) refers to use ofthe Behavioral
Health Barometer in "using this information, states
will select specific priority areas and develop
milestones and plans for addressing each of their
priority areas." DMH is well underway in the
planning process for the SFY2014-2015 State Plan
and expects to complete this process by December
2012 in order to allow for sufficient time for the
67

coordinated state profile which will
maximize the use of information for
multiple purposes. SAMHSA will work with
our stakeholders on that process.
Consistent with this approach, SAMHSA will
release the National and State Barometer
which can be used by states for problem
identification and planning purposes.

Block Grant Comment Log (Continuous)
writing and review of the document. Given this
timeline, we request that SAMHSA
either release the data and guidance from the
Behavioral Health Barometer and the National
Quality Behavioral Health Framework in September
or delay the implementation of these systems.
126.

9/11/12

Marcia Fowler,
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

Develop alternative approaches to fiscal reporting:
DMH has historically "blended" federal block grant
funds with state appropriated dollars and
purchased community mental health services
through contracts with providers. The State,
including DMH, is shifting to a reimbursement
strategy that is consistent with encounter based
reimbursement in response to a new state law
enacted in 2008 which provides for a process for
establishing rates of payment for social service
programs purchased by governmental units.
However, DMH intends to continue to blend
funding streams as this allows DMH to sustain its
service system to the greatest degree possible with
fluctuations in annual funding. While DMH
appreciates the need for accountability of block
grant dollars, the agency is not able to complete
Table 3 of the Block Grant Application. DMH
provides a single continuing care community
mental health system in MA. It is artificial for DMH
to distinguish individuals who are receiving block
grant funds versus state appropriated dollars as the
service system for these people are the same and
the services are tailored to meet the individual and
changing needs of each person. In addition, many

Because of the challenges that this table
presents to many states in regard to their
existing infrastructure capacity to report
the data, this table is requested and states
are asked to provide any data that is
available. States must be able to report
what they are using Block Grant dollars for.

Block Grant Comment Log (Continuous)

127.

9/11/12

Marcia Fowler,
Commissioner,
Department of
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

128.

9/11/12

Marcia Fowler,
Commissioner,
Department of

health care systems across the nation are
considering methods of financing based on global
payments, which may not allow for the tracking of
specific services to specific people. DMH supports
fiscal and programmatic accountability and would
welcome the opportunity to work collaboratively
with SAMHSA to develop an approach that is
cognizant of the state's financing
model.
Remove requirement that states provide letters of
support: DMH collaborates with its sister state
agencies on a variety of initiatives and issues. As
required by the Block Grant, these agencies are
members of the Planning Council and its
subcommittees. DMH demonstrates through the
State Plan and Implementation Report multiple
examples of its work in partnering with state
agencies. This documentation should be sufficient in
demonstrating the support of state partners. The
requirement to submit letters of support is
unnecessarily burdensome. Furthermore, the
challenges in working with state partners is less
about a willingness to collaborate and more about
the real challenges of bridging differences in priority
populations, regulations, information systems, and
other systemic issues. This is an area where technical
assistance from the block grant program would be
helpful in identifying potential solutions to these
challenges.
Reduce the data reporting requirements related to
the preparation of the URS table and Client-Level
Reporting Data Initiative: In fulfilling the
69

SAMHSA has asked that the state provide
supporting documentation which could
take any number of forms.

SAMHSA will continue to request
information to support the NOMs. During

Block Grant Comment Log (Continuous)
Mental Health,
Executive Office of
Health and Human
Services, The
Commonwealth of
Massachusetts

requirements of the Data Infrastructure Grant (DIG),
DMH is participating in the Client-Level Reporting
Data Initiative led by NRI and is preparing to submit
client-level files in December 2012. When this
initiative began, it had been stated that submission
of client-level data on five of the National Outcome
Measures (NOMs) would reduce the number ofURS
tables to be completed, as NRI would be able to
utilize the data from the client-level files to construct
the corresponding URS tables. It now appears from
the Reporting Section and other communication
from NRI that states will be required to continue to
submit all twenty-one URS Tables in addition to the
client level files. This will greatly increase the
burden on the states to produce the same data in
client-level and aggregate formats. The content of
the data reported to NRI is of limited utility to DMH
itself, as we have developed a robust system of
reporting tools and measures focusing on client
outcomes that better meet the needs of DMH staff,
contracted providers, and other stakeholders. The
layering of new data reporting requirements over
existing ones is problematic. DMH recommends
that SAMHSA review the purpose and rationale of all
of its reporting requirements, including, service
utilization and outcome data, and utilize the new
application as an opportunity to reduce reporting
requirements to those that meet a specific and
current need: In addition, DMH recommends that
SAMHSA review the successes, limitations and
challenges with NOMs reporting. DMH fully
supports the life domains that are measured in the
70

the next year, SAMHSA will engage
stakeholders in a comprehensive review of
measures to support both discretionary
and Block Grant data reporting.
The BehavioralHhealth Barometer will be
published within the next fiscal year.

Block Grant Comment Log (Continuous)

129.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

NOMs, such as employment, school attendance, and
housing. However, it is DMH's experience that the
NOMs, as currently defined, do not provide the
information needed to evaluate the effectiveness of
the service system or measure change in a
meaningful way. It appears from these materials,
that SAMHSA is reconsidering the value and role of
NOMs. While NRI has engaged the states in
workgroups on the challenges with reporting some
of the NOMs and developing potential revisions,
there has not been a broader discussion with states
about their overall utility and benefit. DMH
recommends that this discussion occur and influence
data reporting requirements moving forward.
Planning and Reporting Steps:
The planning and reporting requirements would
require changes in reporting data collected by OASAS
and our providers. In a time of staff reductions,
budget constraints and an effort to hold down
administrative cost of our providers, such changes
would be difficult to implement for both the agency
and our providers. An example of a challenge NYS
faces is found in Table 3, reporting requirements.
New York is currently unable to report the individuals
served, number of units provided and the associated
expenditures for the specific services listed.
Encounter based reimbursement data would require a
complete overhaul of its entire funding allocation
process and data systems. The agency is currently
reviewing these processes and may not be able to
meet such requirements by this Block Grant planning

SAMHSA acknowledges that not all States
will have the information/data to complete
the form. SAMHSA encourages States to
complete as much of the table as possible
in order that SAMHSA has a comprehensive
view of the service delivery system.

Block Grant Comment Log (Continuous)

130.

131.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

and reporting cycle.
Deadline for Submission:
st

The April 1 deadline for submission coincides with
the State legislative session and the date by which the
NYS budget must be approved. The budget cycle is
based on an April 1st through March 31st fiscal year.
During this time, OASAS staff in all bureaus must focus
on legislative requests, preparing budgets, preparing
budget hearing testimony, tracking legislation and
assisting the state’s Division of Budget with
negotiations with the Legislature. With a reduction in
staff through attrition, it will be challenging to
complete the application. NYS suggests that the
application deadline be reconsidered.
Behavioral Health Barometers and Data Collection
The proposed Block Grant does not identify all the
measures that will be included in the behavioral health
barometer. Some of the data elements identified for
collection are not currently collected by OASAS.
Making these changes to our system would be both
costly and time consuming.
A consistent definition for behavioral health is
necessary given the impact federal statutes and
regulation have on NYS systems as we move forward
in implementing Health Care Reform. The use of
precise, defined terminology is important as we move
forward in implementing measures and data elements
consistently. It is recommended that SAMHSA provide
more information on how it will incorporate the
“behavioral health barometers” into the existing

SAMHSA will work with states on the
implementation of the April 1 submission
date.

Block Grant Comment Log (Continuous)

132.

133.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

National Outcome Measures and OASAS current data
collection efforts.
Requested Information/Compliance Requirements:
The application should better outline what
information is required verses requested.
Clarification is needed on submission dates, what is
deemed compliant and whether non-completion of
requested sections will delay approval of applications
and award notifications. Given the number of new
topics and requirements, it is appreciated that page
16 outlines information that is requested. However, a
more detailed explanation about the expectation for
each section would be helpful to avoid confusion and
misunderstanding when trying to accurately complete
these new requirements.
Multiple Goals and Purposes of the Proposed SAPT
Block Grant Application:
The revised application incorporates multiple,
divergent purposes which creates a burden on OASAS.
The application states that the proposed revisions are
to expand areas of focuses and meet SAMHSA’s need
to assess the extent for which states plan for and
implement ACA. In addition, the revision is to look at
whether funds are being directed towards the four
recommended purposes of the grant, which are
different from the statutorily required goals of the
program. Making significant changes to the
application can dilute progress on any one goal or
area of focus. Every change that is made continues to
stretch our already thin resources and risks reducing
effectiveness and impact. It is suggested that only one

SAMHSA is developing a comprehensive
instruction document for the Uniform
Application that will be disseminated to
States, as well as being uploaded to the
WebBGAS..

SAMHSAs purposes are consistent in our
emphasis on the role of the state authority
to engage in a planning process which looks
at the state’s population, the impact of
reimbursement and coverage on access to
and receipt of services, and assure program
integrity and accountability.

Block Grant Comment Log (Continuous)

134.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

area of new focus be introduced every two years in
order to allow us sufficient time to plan and
implement changes.
Joint Planning
OASAS supports the joint planning efforts with other
agencies such as OMH. This planning is key in the
development of an integrated system of care that is
patient focused. In line with the efforts of NYS to
integrate planning and some administrative function,
OASAS and OMH will submit a combined application
for the 2014/2015 SAPTBG submission. SAMHSA
should continue to support the integrity of the
clinical, financial and programmatic needs of SUD
prevention, treatment and recovery services. OASAS
supports the additional focus on prevention and
endorses the effort to better define and establish
common prevention issues and definitions with
mental health. OASAS cautions SAMHSA not to
broaden these requirements and expectations beyond
the statutory requirements guiding their allowable use
in order to protect the funding.
OASAS also supports the movement towards better
recovery services. OASAS suggests that there be more
work done with all stakeholders to come to a
common definition of recovery services. Recovery
services for the SUD population and the mental health
population may be identical in some cases, but
different in others. For example, patients in recovery
from SUD need access to alcohol and drug free
housing. In order to start developing common
definitions of recovery services, the Block Grant could
74

Block Grant Comment Log (Continuous)

135.

136.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

ask for identification of recovery services funded by
the Block Grant.
Planning Steps
The proposed application seems to be moving in the
direction of being increasingly prescriptive in what
Block Grant funds may purchase instead of being
more flexible. The priority areas proposed to be
requested in a State plan are not included in statute
or regulations and changes the intent of the Block
Grant, which is to allow States flexibility to identify
their own needs using State data. We would suggest
that the request for information on how States are
addressing new populations and areas is optional and
the State’s award will not be impacted in any way if
the section is not completed.
Terminology
The draft document refers to the term “States” and
changes the term for the SAPT Block Grant to
Substance Abuse Block Grant (SABG). We suggest
specific references to State substance abuse agency
and recommend SAMHSA ensure that state substance
abuse agencies (SSA) have a strong role in federal ACA
dollars from other sources (e.g. Health Resources and
Services Administration) not currently going through
the SSA. We also suggest using the term for the SAPT
block grant identified in statute which is the
Substance Abuse Prevention and Treatment Block
Grant.

SAMHSA has indicated in the application
that the information requested is not
required. SAMHSA has added language
which clarifies that the state award will not
be impacted if a state does not provide
requested information. However,
requested information will assist SAMHSA
in understanding state’s challenges and
plans both individually and collectively.

SAMHSA fully supports the strong role of
the state authorities. SAMHSA has not
changed the name of the block grants, only
simplified the acronyms.
States in the SABG portion of the FFY 20142015 application and plan is defined by
statue. States as defined includes the fifty
States, the District of Columbia, the
Commonwealth of Puerto Rico, the US
Virgin Islands, Guam, American Samoa, the
Commonwealth of the Northern Mariana
Islands, Palau, Micronesia, the Marshall
Islands. There is one Tribe that receives
the SABG, the Red Lake Band of Chippewa
Indians.

Block Grant Comment Log (Continuous)

137.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery

Corrective Action Plan
Page 54 of the application indicates that States should
be held accountable for meeting goals and
performance indicators in their plan. If the State has
failed to take reasonable steps to achieve its goals, it
outlines that the State should develop a corrective
action plan. It also indicates that SAMHSA may direct
the State to change their plan to ensure goals are
met. OASAS supports enhanced accountability and
has recently implemented a treatment scorecard for
all of our funded treatment providers outlining
enhanced responsibility. We would recommend that
SAMHSA collaborate on this new requirement by
76

The authorizing legislation does not define
the term “State substance abuse agency”
or acronym “SSA” or the term “State
mental health agency” of the acronym
“SMHA.” The authorizing legislation uses
the term “State” or “States” and also
defines the term “States” and “territories
of the United States” in section 1954 of
Title XIX, Part B, Subpart III of the PHS Act
(42 USC §300x-64). The term “principal
agency of State” appears in section 1930(a)
of Title XIX, Part B, Subpart II of the PHS Act
(42 USC §300x-30(a)) and the term
“principal agency” is defined in 45 CFR
96.120 as follows: “Principal Agency is the
single State agency responsible for
planning, carrying out, and evaluating
activites to prevent and treat substance
abuse and related activivites.”
One of the focus’ of the BG is on
accountability and SAMHSA recognizes that
will only be accomplished through a close
working relationship with the state
authority

Block Grant Comment Log (Continuous)

138.

139.

9/11/12

Arlene GonzálezSánchez,
Commissioner, New
York State Office of
Alcoholism &
Substance Abuse
Services, Addiction
Services for
Prevention,
Treatment,
Recovery
Malisa Pearson ,
ACMH Executive
Director, Association
for Children’s
Mental Health

allowing states more flexibility on how the Block
Grant funds are spent. We suggest that SAMHSA
continue to enhance a close working relationship with
OASAS to discuss progress, challenges and solutions
to ensure that everyone is in agreement on what are
reasonable steps to address deficiencies.
FY 2012 and FY 2013 Budget Proposal
The Block Grant references initiatives that are
included in SAMHSA’s proposed budget for FY 2013
that requires Congressional action before
implementation. This sends mixed messages to States
and creates challenges given the number of changes
SSA’s are managing. It is recommended that
information referencing the FY 2013 budget be
removed while pending direction from Congress to
SAMHSA.
Recommendation One: Full public transparency in all
block grant planning processes
States and Territories will be required to
post on a publicly accessible website the
following information:
•
Composition of membership of block grant
planning committee – Website information shall
include names of individuals, constituency and/or
agency representation (family, youth, adult, etc).
•
Announcement of Block Grant meetings
and inclusion of time for public comment ‐
Announcements of block grant meetings will
include encouragement for the public to
attend. Block grant meetings shall include
time on the agenda for public comment.

In the Background section, SAMHSA has
described it’s vision for future initiatives
which can give both context and
information to states as they engage in
their planning process.

Block Grant Comment Log (Continuous)

140.

9/11/12

141.

9/11/12

142.

9/11/12

143.

9/11/12

Process utilized for arriving at funding
recommendations ‐ The process used to develop
and implement Block Grant funding decisions will
be fully described
Recommendation Two: Equity in funding
Malisa Pearson ,
between child and adult mental health services
ACMH Executive
Director, Association Block grant plans will exhibit equity in funding for
children's mental health services that is proportional to
for Children’s
each state's child/youth population at a minimum but
Mental Health
also takes into account level of need of children and
youth with serious emotional challenges and their
families.
Malisa Pearson ,
Recommendation Three: Comprehensive Care
ACMH Executive
Coordination
Director, Association Comprehensive care coordination for children and
for Children’s
youth with serious emotional challenges and their
Mental Health
families will be considered a funding priority.
Recommendation Four: Wraparound Child and Family
Malisa Pearson ,
Teams
ACMH Executive
Director, Association Wraparound Child and Family Teams will be supported
as the vehicle to develop family‐driven and
for Children’s
youth‐guided plans to further coordinate a family
Mental Health
driven, youth guided, comprehensive
community‐based ongoing service planning and
implementation process.
Recommendation Five: Agency Contracts Must be
Malisa Pearson ,
Monitored
ACMH Executive
Director, Association Contracting between the state and local entities must
include language and conditions that support the active
for Children’s
utilization of Wraparound Child and Family Teams, Care
Mental Health
Review, as well as other areas that support system of
care principles. The responsible organization must

SAMHSA does not have Statutory authority
to require equity in funding for mental
health services for children propotional to
state population

Section O includes encouragement to the
states to use this model and asks for
information to determine the states’
activities in these areas
This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model

SAMHSA believes that state’s must have
the flexibility in determining contract
language.

Block Grant Comment Log (Continuous)

144.

9/11/12

145.

9/11/12

146.

9/11/12

147.

9/11/12

monitor all service provider organizations to ensure
adherence to active utilization of wraparound child and
family teams and care review.
Recommendation Six: Family and Youth Partners
Malisa Pearson ,
Specific funding strategies will be identified to support
ACMH Executive
Director, Association youth and family support like Family Partners or Youth
Peer Support who provide informal care coordination,
for Children’s
navigation, engagement and linkage to services for
Mental Health
children, youth and families.
Recommendation Seven: Care Review Process
Malisa Pearson ,
A community based Care Review process must be in
ACMH Executive
Director, Association place with active representative participation and
responsibility from all major child‐serving agencies,
for Children’s
organizations, youth and families.
Mental Health
Recommendation Eight: Family‐Driven and
Malisa Pearson ,
Youth‐Guided
ACMH Executive
Director, Association Plans will embrace a family‐driven and youth‐guided
approach, which requires among other things:
for Children’s
•
Stigma reduction ‐ A clear plan to reduce
Mental Health
stigma and engage in community‐based health
promotion activities.
•
Family and youth involvement in Governance ‐
Clear evidence of parents and youth involved in local
governance around the design and delivery of services
and supports to youth with emotional challenges and
their families.
Karen Orsi, Director, OMHAC joins the NCMHA recommendation that
SAMHSA "... encourage states to address the needs
Oklahoma Mental
of older adults for mental health promotion and
Health and Aging
prevention and treatment of substance use
Coalition
disorders." The combined mental health and
substance abuse block grant is just one more

This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model
SAMHSA believes state’s must have the
flexibility to determine their care review
process

This recommendation is incorporated into
the spectrum of effective, communitybased services and supports that are
organized into a coordinated network of
the system of care model

Block Grant Comment Log (Continuous)

148.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

149.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

instance where the behavioral health needs of older
adults are barely acknowledged. OMHAC urges
SAMHSA and other federal agencies to recognize
older adults as a distinct population that is
underserved. We need your support and assistance
to eliminate behavioral health disparities for older
Americans
Regulations: Current Regulations should be amended
to better align with the requirements of the Health
Care Reform and Parity Legislation. The current
regulations requirements and the added burden of the
requirements put undue burden on the already
underfunded state systems. The requirements of
additional information without removing any of the
existing reporting requirements continue to be a
concern. The new applications and reports many have
reduced the amount of responses that the State must
address but it did not relieve the burden of the
required state processes, procedures, contract
conditions, licensing requirements and more that are
needed to ensure that the regulations are met.
Maintenance of Effort: On page 5 of the proposed
application SAMHSA acknowledges that there are
inconsistencies in the way the bases for State
Maintenance of Efforts are calculated. However
the application does not address making any
change to the methodology.
The bases for the State Expenditure portion of the
State Maintenance of Efforts have not been changed
since FFY92. Many changes to the structure of
substance abuse services within state systems have
changed. Based on the description of future purpose
of the Block Grant dollars the portion to other cost
80

prioritize those populations specific to that
state.

Thank you – SAMHSA is exploring the
revision of the current regulations.

The authorizing legislation and
implementing regulation required
States to establish a methodology for
determining the amount of non-Federal
funds obligated and expended annually
for the following services:
1.

Section 1930(a) of Title XIX,
Part B, Subpart II of the PHS Act
(42 USC § 300x-30(a)) and 45
CFR 96.134(a) require States
maintain aggregate State

Block Grant Comment Log (Continuous)
may need to be included in the Base. More consistency
across state expenditures included for all states should
be reviewed and updated.

expenditures for authorized
activities at a level that is not
less than the average level of
such expenditures maintained
by the State for the 2-year
period preceding the fiscal year
for which the State is applying
for grant (See page 171, Table
8a, “Total Single State Agency
(SSA) Expenditures for
Substance Abuse”)
2. Section 1922(b)(1)(C) of Title
XIX, Part B, Subpart II of the
PHS Act (42 USC § 300x22(b)(1)(C)) requires States (See
page 172, Table 8d ,
“Expenditures for Services to
Pregnant Women and Women
with Dependent Children”).
3. Section 1924(d) of Title XIX,
Part B, Subpart II of the PHS Act
(42 USC § 300x-24(d)) requires
States to maintain non-Federal
expenditures for tuberculosis
services as described in section
1924(a) and, if a designated
State, maintain non-Federal
expenditures for early
intervention services for HIV
(See page 172, Table 8b,
“Statewide Non-Federal
Expenditures for Tuberculosis
Services to Substance Abusers

Block Grant Comment Log (Continuous)
in Treatment”; and page 172,
Table 8c, “Statewide NonFederal Expenditures for HIV
early Intervention Services to
Substance Abusers in
Treatment”).
States are required to prepare and
submit a report in accordance with the
authorizing legislation and
implementing regulation including, but
not limited to, a report of non-Federal
expenditures for authorized activities
and services as described in the
authorizing legislation and
implementing regulation. A State, in
consultation with SAMHSA, has the
flexibility to revise its methodology for
determining the non-Federal
expenditure base for activities and
services described in the authorizing
legislation and implementing
regulation; however, in determining a
revised non-Federal expenditure base,
a State is required to prepare and
submit a detailed description of the
revised methodology to SAMHSA for
review, revision, if appropriate, and
approval. Upon approval of a revised
methodology, a State will be required
to prepare and submit revised tables to
reflect the change in the amount of
base expenditures.
82

Block Grant Comment Log (Continuous)
150.

9/11/12

151.

9/11/12

152.

9/11/12

153.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse
Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse
Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse
Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

Table 3: Table 3 page 56 State Agency Planned Block
Grant Expenditures by Service. Categories listed do not
reflect the current required categories for Block Grant
funded services. Is the requested information for the”
target” population the same as the “priority
populations” listed on page 44 under the framework
for planning and on page 53.
Data Systems: How are federal data systems (e.g.
NSDUH, TEDS, SEDS) changing to be inclusive of new
populations (e.g. veterans, LGBTQ, etc.)? Changes in
federal data systems could help inform edits to State
data systems.

Behavioral Health Barometers: What measures will be
included in the behavioral health barometer? Changes
to the data system are challenging and we are
concerned about being able to collect the data
elements that will be needed if they are not currently
collected. How will these measures align with the
National Outcome Measures (NOMs) and current data
collection efforts?
Application Submission Date: The State of Illinois has
a legislative mission to develop a State Plan for
substance abuse services in Illinois on an annual basis
by the state fiscal year. The planning cycles for the
Block Grant Plan is being realigned to the State Fiscal
th
Year July 1-June 30 . This planning cycle better aligns
to the state’s planning cycle. The Planning Period on
page 41 of the proposed application is 7/13-6/30/15.
The timeframe is prior to the start of Illinois SFY2013
on July 1. State of Illinois budgets are typically not

The Behavioral Health Baromter will
include a set of indicators – reportable at
both a national and state level - collected
through various federal surveys. As such, it
is not anticipated that state reporting on
any of these indicators requires any data
collection or systems change efforts from
states.
SAMHSA has determined the application
submission date to alignwith most states
fiscal year budget cycle. SAMHSA will work
with states to implement the new
submission date.

SAMHSA is part of federal interagency
groups that is working to include these new
populations in existing surveys through the
development and testing of new and
standard questions for federal surveys.

Block Grant Comment Log (Continuous)

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9/11/12

155.

9/11/12

156.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

finalized by April. Statewide fiscal data collection
closes at the end of August each year. Please consider
changing the application due date to September 1 just
prior to the start of the federal fiscal year.
Instructions: Given the extensive changes to the
application it is essential that the instructions are clear
and specific. What are the timeframes for the data
requested? What sections are required and what
sections are recommended? What criteria will
responses be measured against?
SAPTBG: The draft application changes the term for
the SAPT Block Grant to Substance Abuse Block Grant
(SABG). This is not only confusing but dangerous as it
removes the importance of Prevention from the
Continuum and puts the focus on the issue of
substance abuse rather than the solution: prevention
and treatment of substance abuse. Please use the
term for the SAPT block grant identified in statute,
which is the Substance Abuse Prevention and
Treatment Block Grant.
Workforce: Workforce needs in this new environment
will be significant. The development of core
competencies and standards at the federal level will
help to ensure standard practice. The Substance Abuse
and Mental Health Services Administration should
continue their work in partnership with the field to
provide guidance for States to prepare staff and the
workforce for changes in expectations implicit in the
application and report. SAMHSA is commended for
publishing documents such as “Addressing the Needs
of Women and Girls: Developing Core Competencies

SAMHSA is developing a comprehensive
instruction document for the Uniform
application that wil be disseminated to
States, as well as being uploaded to the
WebBGAS. The applicaition has clarified
which sections are requested and required.
SAMHSA has not changed the name of the
Block Grants, only the acronyms used.

States have the flexibility to utilize SABG
funds targeted towards the SABG subrecipient workforce as described in the
Behavioral Health Assessment and Plan
(See page, Table 6a, “SABG Resource
Development Activities Planned
Expenditures”) and the SABG report (See
page 168, Table 6, Resource Development
Expenditure Checklist, Row 3 “Training”
and Row 4 Education ) Further, SAMHSA’s
Addiction Technology Transfer Centers and

Block Grant Comment Log (Continuous)

157.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

158.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

for Mental Health and Substance Abuse Services
Professionals” and could continue to do so for special
populations such as the ones described in the
application.

Centers (ATTC) and Collaborative for the
Advancement of Prevention Technology
(CAPT), in collaboration with SAMHSA’s
block grant technical assistance resources,
support development of the behavioral
health workforce.

Special Populations: SAMHSA’s support of technical
assistance to smaller non-profits is much needed to
ensure that the goal of the Affordable Care Act to
focus on health disparities of special populations.
The Block Grant has historically directed funding
and resources to hard to reach populations. Services
are provided in the communities where the
populations reside. Added regulations and data
technology requirements that may unduly force
these smaller non-profit providers out of business
while encouraging other providers to survive may
not be the effect that the health care legislation has
planned. State and Federal resources have
supported the building of these smaller facilities.
Support by SAMHSA should be provided to ensure
that these providers are given the necessary
support to continue to operate.
Criminal Justice: Referrals from the criminal justice
system already are filling available treatment slots in
the Illinois System. The services are much needed to
this population. Additional resources from the
Department of Justice and other resources should be
accessed to aid in serving this population. SAMHSA’s
technical assistance is needed to leverage support.
Training of community health care workers to better
serve this population is also needed.

We appreciate this very important
comment. SAMHSA is making efforts to
strengthen the business operations
relevant to health reform for smaller non
profit community based organizations that
serve disparities vulnerable populations.

SAMHSA is aware of this issue and very
much appreciates your comment.

Block Grant Comment Log (Continuous)
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9/11/12

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9/11/12

Recovery Support: Guidance from SAMHSA is needed
regarding evidence-based recovery support services
models and definitions.

Prevention Comment to Page13: Under header
Prevention, 3rd paragraph:
• 1st sentence: Community settings and
service systems is the terminology used.
What happened to the focus on the
community itself, working with various
sectors?
nd
• 2 sentence: There is a list of settings
including substance abuse treatment
centers. This example is confusing for
States. It clearly states that the 20% setaside may not be used for treatment, yet
it is
identified as a possible setting. It may
put States at risk without further
guidance about what type of service
and audience may be served. More
information is needed if this setting
remains in the list.
• 3rd sentence: Two new areas have been
introduced, violence and bullying. These
are unique disciplines that have their own
evidence-base. Violence, bullying and
substance abuse prevention are not always

SAMHSA has numerous TA resources to
assist states in these efforts.

Block Grant Comment Log (Continuous)

161.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

162.

9/11/12

Theodora Binion,
Director, Illinois

interchangeable. While some model
programs may be effective at addressing
multiple disciplines, other strategies are not
designed to achieve multiple outcomes. It
is a mixed message. On p.71 of the
application, Youth and Adult Heavy Alcohol
Use – Past 30 Day is listed as a goal. If a
State chose to focus solely on bullying or
violence, would this goal be achieved? By
generally incorporating these new focus
areas; there is a risk of diluting the efforts
needed to effectively impact alcohol,
tobacco and other drug outcomes.
Prevention Comment to Page 14: The Mental Health
Block Grant (MHBG) limits the work to the SMI and
children with SED. With the limitation, the SABG funds
would be needed to address universal and selective
populations with violence and bullying activities. The
MHBG needs to be more flexible as the target
populations that can be served.

Block Grant Comment Log (Continuous)

163.

164.

9/11/12

Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

ensure for the coordination or duplication of services.

substance abuse primary prevention and
primary prevention on mental health
disorders. Based on statute, the possibility
of duplication of services for primary
prevention services for substance abuse
and primary prevention services for mental
health disorders would not occur.
The Interim Final Rule for primary
substance prevention, §96.125 (a), and for
purposes of §96.124, states that “each
State/Territory shall develop and
implement a comprehensive substance
abuse primary prevention program which
includes a broad array of substance abuse
primary prevention strategies directed at
individuals not identified to be in need of
treatment. The 20% set aside funds of the
Substance Abuse Block Grant must be used
only for substance abuse primary
prevention activities by the State.”

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

Prevention Comment to Page 22: Under header
Primary and Behavioral Healthcare Integration
Activities, 1st dot point, 2nd paragraph: utilizing no

Theodora Binion,
Director, Illinois
Department of
Human Services,

Prevention Comment to Page 32: Leverage Scarce
Resources: As in other parts of the application,
SAMHSA should provide other known federal funding
sources that should be considered.

The grant program referred to in the
second paragraph is the MHBG and not the
SABG. States will be allowed to use some of
their current MH Block Grant to support
mental health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances.
Some States are receiving funding from
other federal sources for substance abuse
prevention programming activites/services.
Those States that do, in the past have

less than 10% of grant funding. Specify the grant
program – 20% set-aside or the SABG?

Block Grant Comment Log (Continuous)
Division of
Alcoholism and
Substance Abuse

165.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

Prevention Comment to Page.42: Guidance is
provided sections that must be completed for each
block grant. The same guidance should be provided for
prevention.

166.

9/11/12

Prevention Comment to Page 50: Tobacco cessation –
is this a prevention or treatment activity? Is addiction
to nicotine a health issue that should be addressed by
treatment?

167.

9/11/12

Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse
Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of

Health Information Technology: What is allowed
under Information Systems for Table 6a, Resource
Development? There are no instructions about what is
allowable under each category. Is it allowable to
improve Health Information Technology?

reported those funds in the Substance
abuse block grant on the State Agency
Planned Expenditures Table. On the table,
SAMHSA gives some examples of other
federal funders/ agencies, for example,
ACF, CDC. Also, States may leverage other
State and Local funds and from other
Sources known to the State that should be
considered.
“In the Current Environmental Factors
section of the SABG application (Part B),
under the heading “Current Environmental
Factors regarding Substance Abuse Primary
Prevention and Mental Health Promotion
and Mental Illness Prevention,” the
application provides the statutory
requirements for the primary prevention
set aside, and also lists six main areas
states should focus on in developing their
comprehensive primary prevention plans.”
Tobacco cessation is a treatment activity.
Addiction to nicotine is a health issue that
should be addressed by treatment.

States have the flexibility to obligate and
expend SABG and MHBG funds to improve
health information technology (HIT).
Planned and actual HIT expenditures
should be entered on the Resource

Block Grant Comment Log (Continuous)
Alcoholism and
Substance Abuse

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9/11/12

169.

9/11/12

Coverage for M/SUD Services: Page 67, how is the
block grant defining “access”? Does it include the
number of people who get assessed for treatment,
measured against a penetration rate, actual
enrollment in treatment, or something else?

Program Integrity: Page 69, what meant in the
reference to a SAPTBG integrity plan? What is it and
where can we read about it?

Development Checklist in the States’ plans
and reports. SAMHSA recommends that
States contact their State Project Officer for
guidance on specific questions related to
planned expenditures for resource
development.
SAMHSA will rely on the state’s definition
of “access”.

Section 1.v, Program Integrity, and 3.e,
Program Integrity,
The term “program integrity” refers to the
quality assurance steps initiated by States
to ensure that SAMHSA’s block grant funds
are utilized in accordance with the
authorizing legislation and implementing
regulation governing the SABG program.
For example, general management
controls, e.g., compliance with the
authorizing legislation and implementing
regulation, resource allocation for
authorized activities, and safeguards to
avoid waste, fraud, and abuse; and specific
management controls, e.g., delegations of
authority, audit resolutions, and recording
and documentation of financial
transactions that have been implemented
by the State executive branch responsible
for the administration of SAMHSA’s block

Block Grant Comment Log (Continuous)
grant programs.
There is additional information available
from the Office of the Assistant Secretary
for Financial Resources (ASFR), Office of
Finance, Division of Systems Policy,
Program Integrity and Audit Resolution and
contained in Executive Order 13520
“Reducing Improper Payments and
Eliminating Waste in Federal Programs”.
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9/11/12

171.

9/11/12

Word Document: From a practical standpoint, it
would be useful to have the application and report
available in Microsoft Word for easier manipulation of
the document for planning purposes. In Illinois the
Block Grant application is a team process. The block
grant coordinator needs to create tables of tasks and
distribute instructions. It is very difficult to cut and
paste this information from BGAS or a PDF.
Monica Cissell, Chair, Our nation is aging rapidly and it is critical that
Aging and Wellness
SAMHSA and other federal,state and local
Coalition of
agencies focus greater attention on the
Sedgwick County,
behavioral health needs of the growing number
Sedgwick County
of older Americans. However, noticeably lacking
Department on
in the Federal Register Notice,and the related
Aging, Sedgwick,
County, Kansas
guidance and application instructions, is the
previous SAMHSA commitment of services across
the lifespan. The Aging and Wellness Coalition of
Sedgwick County recognizes that within the
Framework for Planning, SAMHSA calls the states
Theodora Binion,
Director, Illinois
Department of
Human Services,
Division of
Alcoholism and
Substance Abuse

SAMHSA will be happy to make a word
document of the final approved application
and report available upon request.

Block Grant Comment Log (Continuous)
to address "Older Adults with SMI." The Coalition
calls on SAMHSA to encourage states to address
the needs of older adults for mental health
promotion and prevention and treatment of
substance use disorders.
Adults 18 and over and children and adolescents
are mentioned throughout the documents with
almost no reference to older adults. This is
inconsistent with the recommendations
regarding the SAMHSA Block Grants in the
Institute of Medicine Report "The Mental
Health and Substance Use Workforce for Older
Adults: In Whose Hands?" issued in July of this
year. The Coalition strongly supports the IOM
recommendations and urges SAMHSA to fully
adopt those regarding the Block Grants and those
related to SAMHSA in general as well.
The 10M report cites many studies, documenting
that older adults with mental health and/or
substance use disorders are an underserved
population,that the necessary workforce to
address their needs does not exist, and that current
funding policies in Medicare and Medicaid do not
support current best practices of care including
many of those listed in the SAMHSA National
Registry of Evidence-Based Practices (NREPP). These
factors make it extremely important that SAMHSA
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Block Grant Comment Log (Continuous)
identify older adults as a distinct population.
Without specific language regarding older adults in
the SAMHSA documents the Block Grants state may
ignore their needs in the planning process for the
Block Grants or in developing the state insurance
exchanges.

172.

9/11/12

Abbe Land,
Executive Director &
CEO, The Trevor
Project, saving
young lives

The four (4) purposes proposed for the Block Grant
funding fit well with the needs of older aduIts. The
issue is that older adults are not included in the Block
Grant planning and application process and
subsequent reporting requirements, proportionate to
their mental health and substance abuse needs. Again,
without designation of older adults as a distinct
population this is not likely to happen.
Include details about existing nondiscrimination
This requirement is already present in the
requirements for grantees. The application should
Assurances which are signed on an annual
clearly define applicant’s nondiscrimination
basis by the Governor or their designee.
requirements under federal law. Under Section 1557
of the Affordable Care Act (42 U.S.C. 18116),
individuals may not be subject to discrimination on the
grounds prohibited in Federal law3 under any health
program or activity, any part of which is receiving
Federal financial assistance, or under any program or
activity that is administered by an Executive Agency or
any entity established under Title I of the Affordable
Care Act or its amendments. The Department of
Health and Human Services recently confirmed that
this nondiscrimination protection extends to
discrimination based on gender identity and gender
nonconformity.4

173.

9/11/12

Abbe Land,

Require certification of compliance with all applicable
93

Section 1557 of the Affordable Care Act

Block Grant Comment Log (Continuous)
Executive Director &
CEO, The Trevor
Project, saving
young lives

174.

9/11/12

Abbe Land,
Executive Director &

nondiscrimination laws. State authorities should
provide methods for monitoring compliance of all
state and local contracting entities with the applicable
Federal nondiscrimination laws. The current
Assurances – Non-Construction Programs document
does not specifically require compliance under Section
1557 of the Affordable Care Act, nor does it convey the
protection that is offered on the basis of gender
identity and gender nonconformity.

provides for federal nondiscrimination
protection in the health care system,
including on the basis of “sex.” HHS
clarified that this prohibition includes
discrimination based on gender identity
and sex stereotyping. HHS intends to
propose rules on section 1557 in the future,
offering an opportunity for comment and
input into this interpretation and others.

Support for stigma reduction efforts. Both LGBTQ
populations generally and individuals seeking mental
health care and substance abuse treatment continue

The document, “Assurances - NonConstruction Programs,” is utilized by
SAMHSA’s discretionary grant programs
authorized under Title V of the PHS Act and
formula grant programs authorized by Title
XIX, Part B, Subparts , II, and III of the PHS
Act. Further, the chief executive officer of
a State or Jurisdiction (or designee)
provides an assurance to the Secretary of
the Department of Health and Human
Services (HHS) that the State or Jurisdiction
will comply with the nondiscrimination
provision as described section 1947 of Title
XIX, Part B, Subpart III of the PHS Act (42
USC § 300x-57). SAMHSA may amend its
assurances in the future after HHS
publishes a Notice of Proposed Rulemaking
in the Federal Register and subsequently
publishes a Final Rule regarding the
interpretation of section 1557.
SAMHSA does focus on challenges to
accessing services for diverse populations
and strategies to address this.

Block Grant Comment Log (Continuous)
CEO, The Trevor
Project, saving
young lives

175.

9/11/12

Abbe Land,
Executive Director &
CEO, The Trevor
Project, saving
young lives

176.

9/11/12

Abbe Land,
Executive Director &
CEO, The Trevor
Project, saving
young lives

177.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of

to be stigmatized in ways which can exacerbate
existing conditions or discourage seeking care. Plans
should describe a clear process to reduce stigma and
engage in community-based health promotion
activities.
Support for promising practices for LGBTQ
populations. Unfortunately, there is a dearth of
evidence-based approaches designed to meet the
behavioral health needs of LGBTQ populations. The
application should make clear that states may take
advantage of innovative promising practices that seek
to address the needs of these populations. In this
context, promising practices are services that have not
yet had the opportunity to be studied and become
evidence-based practices, but anecdotal data and
early studies indicate that the services are effective.
Require data collection for LGBTQ populations.
Although more states are choosing to collect health
data regarding LGBTQ populations, the majority of
state and federal health data collection tools do not
include suitable questions to assess the health
disparities of these populations. This data is essential
for understanding the behavioral health needs of
LGBTQ people and appropriately targeting
programming. Therefore, the application should
require inclusive data collection through existing state
and federal surveys.
Due to repercussions from severe State budget
deficits and lowered forecasts of State revenues,
ADAD, like many SSAs, continues to endure the
impacts of significant cuts to its State budget, loss of
staff and positions, paycuts, and hiring difficulties

SAMHSA recognizes that many evidence
based practices have not been studied
with, or adapted with diverse populations.
In general, SAMHSA supports the use of
practices that might be developed or
adapted specifically for diverse populations
and that shows some level of effectiveness
with these populations.

HHS is in the process of developing data
standards for the collection of LGBT
identifiers. In the meantime, we
recommend that states use existing LGBTQ
data elements used within their state.

SAMHSA is working on and soon will have
in place a SAMHSA wide technical
assistance mechanism through which TA
will be delivered to the States and SAMHSA
staff will continue to ascertain the TA needs

Block Grant Comment Log (Continuous)
Hawaii

178.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

while grappling with ever-increasing workloads.
SAMHSA is asking States to identify their technical
assistance needs to implement the strategies
identified in their plans for FY 2014 and 2015. While
we appreciate SAMHSA's efforts to obtain
information on States' technical assistance needs,
there is no assurance that SAMHSA would be able to
meet such needs and provide the requisite technical
assistance in a timely manner. The broad scope and
nature of SAMHSA's proposed planning, application,
and reporting requirements involving health care
reform, financing, and expanded uses of the SAPT
Block Grant would require the State to undertake
numerous, fundamental, and complex changes while
struggling on a prolonged basis with inadequate
staffing capacity and resources.
For the proposed FY 2014-2015 Block Grant
Application, States have the option of submitting a
combined or separate applications for the SAPT
Block Grant and CMHS Block Grant. While we
support collaborative planning efforts, we would
have objections to SAMHSA requesting or moving
towards requiring States to submit a combined
application or planning sections for the two
separate Block Grants. We strongly urge SAMHSA
to continue to provide SSAs·and State Mental
Health Authorities (SMHAs) the flexibility to
submit separate or combined applications. This
would recognize and take into account the
organizational structures, staffing and fiscal
resources, economic conditions, political
circumstances, and other factors that differ among
96

of the States through System Reviews/Site
visits and will continue providing TA.

SAMHSA is not requiring states to submit a
combined application, but allowing states
to submit either separate applications or a
combined application at their discretion.

Block Grant Comment Log (Continuous)
States.

179.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

The reporting burden would not be reduced in
developing and submitting a combined
application for States like Hawaii. Hawaii's
State substance abuse and mental health
authorities do not have integrated operations
and are physically scattered in distant areas.
This makes joint planning and coordination
more time-consuming and challenging,
especially since for the past several years our
agencies have been and continue to be severely
impacted by State budget cuts, layoffs, elimination
of positions, and paycuts. Also, since our staffing
and operations are not integrated or co-located, the
logistics of submitting a combined application using
SAMHSA's Web Block Grant Application System
(BGAS) would be more difficult and complicated,
especially pertaining to security and user access
levels.
We appreciate SAMHSA's inclusion of prevention
as an area of focus in the FY 2014-2015 Behavioral
Health Assessment and Plan. However, we have
objections to SAMHSA's request, as stated on
page 15 of the proposed application, "that states
provide a coordinated and combined plan
addressing services and activities for the primary
prevention of mental and substance use
disorders.. .in the planning section ofthe current
Block Grant application. SAMHSA will work with
states to develop and/or amend their FY 2013
Block Grant State Plans(s) once a budget for FY

“SABG prevention funds must be used for
practices and programs that have a
demonstrated impact on substance abuse
prevention. Many of these practices and
programs may also have an impact on
other areas of wellness.”

Block Grant Comment Log (Continuous)
2013 is finalized." We do not disagree with
SAMHSA's intention to require States to revise
planned amounts of the 20 percent primary
prevention set aside based on revised FY 2013
SAPT Block allotments to States once the FY 2013
budget is finalized. However, as we explained
above, SAMHSA, should continue to provide SSAs
and SMHAs the flexibility to submit separate or
combined applications due to organizational
structures, staffing and fiscal resources, economic
conditions, political circumstances, and other
important factors that differ among States.
Moreover, SAMHSA should not require States to
retroactively amend their approved FY 2012-2013
application plans to develop a new and combined
plan for the primary prevention of mental and
substance abuse disorders without first receiving
direction or approval from Congress. Congress
rejected SAMHSA's FY 2012 proposal to reallocate
the SAPT Block Grant's 20 percent primary
prevention set aside funds to a new Substance
Abuse State Prevention Grant program. The Senate
Appropriations Committee Report expressed concern
"that creating another State grant program with new
requirements would represent an unnecessary and
burdensome approach and would not support
services being delivered on a continuum of
prevention, treatment and recovery support services.
Furthermore, a 1-year waiver of the setaside is not a
stable basis for States to make long-term plans for
substance abuse prevention programming."
Congress also rejected SAMHSA's FY 2012 budget
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Block Grant Comment Log (Continuous)
request to merge funding for Programs of Regional
and National Significance under CSAT, CMHS, and
the Center for Substance Abuse Prevention (CSAP)
into a single behavioral health account for Innovation
and Emerging Issues. The proposed consolidation,
according to the Senate Appropriations Committee
Report, "would be detrimental to the specific
programmatic and policy expertise of each center,
especially as it relates to substance abuse prevention
and substance abuse treatment." The Senate Caucus
on International Narcotics Control, in its June 2012
report, "Reducing the U.S. Demand for Illegal Drugs,"
urged SAMHSA "to follow the limitations set forth in
appropriations law and to not merge substance
abuse and mental health prevention programs in
future budget proposals. Doing so would only
reduce the impact of each program."
We would like to also reiterate and emphasize
comments and recommendations dated August
30, 2012, that the National Association of State
Alcohol and Drug Abuse Directors (NASADAD),
submitted to SAMHSA on the proposed FY 20142015 SAPT Block Grant Application. NASADAD
noted "that much work remains to better define and
establish common terminology regarding substance
abuse prevention and mental health promotion.
To protect prevention funding, we caution SAMHSA
not to broaden prevention requirements and
expectations far beyond the statutory requirements
guiding their allowable use. We recommend that
work first move forward to establish common
99

Block Grant Comment Log (Continuous)

180.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

definitions pertaining to substance abuse
prevention, mental health promotion, and other
relevant and related terms. We recommend working
through NASADAD on this topic."
SAMHSA's attempts towards alignment and
consistency-in application planning and reporting
for the SAPT and CMHS Block Grants has not only
created confusion, but it does · not help to maintain
the clinical, financial, and programmatic integrity of
prevention, treatment and recovery services for
substance use disorders that NASADAD has
emphasized in its comments on joint planning.
While SAMHSA acknowledges the SAPT and CMHS
uniform behavioral health application format.
Please note the following:
• In 2010, the Office ofManagement and
Budget (OMB) approved SAMHSA's major
revisions to the FY 2011 SAPT Block Grant
Application Guidance and Instructions
with an expiration date of?/3112013. In
compliance, States submitted a 3-year
intended use plan for FY 2011-2013. If
the State's plan remained unchanged for
FY 2012 and 2013, no new narrative
would be required, only updates as
needed. This was intended to minimize
the reporting burden. However, last year,
SAMHSA split the SAPT Block Grant
Application into two documents with
different due dates: (1) a two-year

100

SAMHSA has established the Uniform
application to allow states to choose
between submitting a separate application
and plan for each block grant, or to submit
a single application and plan which
addresses each block grant. In the prior
submission period, over half of the states
chose to submit a single application and
plan. In all cases, the reports have to be
separate to allow for the appropriate
tracking of funds for each block grant.
SAMHSA has not changed the name of the
block grants but has only simplified the
acronym for each.
SAMHSA will ensure that the funding
agreements for the block grants are posted
on the website.

- Block

Block Grant Comment Log (Continuous)
Behavioral Health Assessment and Plan
due October 1 or September 1 for States
submitting a combined application plan
for the SAPT Block Grant and CMHS Block
Grant, and (2) an annual SAPT Block Grant
report due December 1. This two-part
application plan and report follows the
CMHS Block Grant application model. The
long- standing OMB control number 09300080 used for the SAPT Block Grant
Application was replaced with the OMB
control number 0930-0168 for the CMHS
Block Grant Application, although the
annual appropriation for the SAPT Block
Grant is more than three times larger than
the CMHS Block Grant.
• The cover page for the proposed
application guidance and instructions is
titled, "FY 2014-2015 Block Grant
Application: Community Mental Health
Services Plan and Report --Substance
Abuse Prevention and Treatment Plan
and Report." This gives the misleading
impression that States are applying for
just one Block Grant instead of two
separate Block Grants. Moreover, the
Table of Contents presents, organizes,
and pages the guidance and
instructions as one continuous
document which includes a Behavioral

101

Block Grant Comment Log (Continuous)
Health Assessment and Plan, a CMHS
Block Grant Reporting Section, and a
SAPT Block Grant Reporting Section.
This single application structure is also
misleading and creates confusion.
There is a single Behavioral Health
Assessment and Plan format that must
be used by States to submit separate or
combined application plans for the
SAPT Block Grant and CMHS Block
Grant. However, the Reporting
Sections listed in the Table of Contents
are actually separate reports for the
SAPT Block Grant and CMHS Block
Grant that must be submitted
separately. The reports have different
formats and reporting requirements
that reflect, in part, statutory,
regulatory, and programmatic
differences between the SAPT and
CMHS Block Grants.
• To minimize confusion and improve clarity
and usefulness, we recommend separating
the guidance and instructions for the
Behavioral Health Assessment and Plan,
SAPT Reporting Section, and CMHS
Reporting Section into separate documents
each with its own Table of Contents. This
would be consistent with the way these
documents are arranged in BGAS. The

102

Block Grant Comment Log (Continuous)
Table of Contents for the SAPT Report and
CMHS Report should identify the different
tables required for each Block Grant. This
would also be consistent with how the
Table of Contents for each Block Grant
Report appears in BGAS. In the
instructions for the Behavioral Health
Assessment and Plan and SAPT Block Grant
Report, as well as in BGAS, the term,
Substance Abuse Block Grant (SABG), is
often used to refer to the SAPT Block
Grant. To improve clarity and consistency
and to conform with the proper
terminology used in statute, we
recommend replacing all references to the
SABG with SAPT Block Grant.

181.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,

• Please note that at the SAMHSA Block
Grants website
http://www.samhsa.gov/grants/blockgrant/,
the ChiefExecutive Officer's Funding
Agreements/Certifications for the CMHS Block
Grant Application was posted, but not for the
SAPT Block Grant Application to date. We
recommend posting the Chief Executive
Officer's Funding Agreements/Certifications for
the SAPT Block Grant Application since they are
statutorily very different from those for the
CMHS Block Grant Application.
We disagree with SAMHSA's proposal to change the SAMHSA will work with states on the
submittal date for the Behavioral Health Assessment implementation of the April 1 submission
and Plan for the SAPT Block Grant Application from
date.
103

Block Grant Comment Log (Continuous)
Department of
Health, State of
Hawaii

182.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

October 1 to April 1 in order to "better comport with
most states fiscal and planning years (July 1st
through June 30th ofthe following year)." This does
not appear to be a compelling justification for such a
major change. Please note that the April1 deadline
conflicts with Hawaii's regular State legislative
session which starts on the third Wednesday in
January and generally ends during the first week in
May. The demands of Hawaii's legislative session
are intense and very time consuming. This includes
justifying budget requests, reviewing and monitoring
State legislation, preparing testimonies, attending
legislative hearings, and responding to
legislative requests, usually on very short notice.
Other major projects are generally not scheduled
during the State legislative session unless necessary.
This helps to keep ADAD's reduced and limited staff
from being further overstretched. Thus, we
recommend that the deadline for submittal of the
Behavioral Health Assessment and Plan for the SAPT
Block Grant Application remain unchanged in
alignment with the October 1 statutory deadline and
consistent with the October 1 to September 30 twoyear award (obligation and expenditure) period for
the SAPT Block Grant.
Given the major changes and complexities involved
in the proposed SAPT Block Grant Application, we
are very concerned about the review, revision and
approval process for the Behavioral Health
Assessment and Plan and annual SAPT Block Grant
Report. In previous years during the SAPT Block
Grant Application review process, Hawaii and other
States have encountered inconsistent and misguided
104

A series of trainings have been developed
for SPOs who monitor the block grant.
Some of those training have taken place.
SPOs will coordinate the review of the
application and plan. Cross Center
communication between the SPOs during
the review of State block grant applications
will occur to ensure limited to no

Block Grant Comment Log (Continuous)
requests from Project Officers to make revisions to
the application that are of little or no practical utility,
time consuming, unduly burdensome, and/or outside
the parameters of the written instructions.
Inappropriate revision requests also delay approval
of the SAPT Block Grant Application and issuance
ofthe Block Grant award notice. To address these
problems, we provide the following
recommendations:
• For the Behavioral Health Assessment and
Plan, the guidance and instructions that
discuss the required and optional items
are not clear, and there is a lack of
differentiation in the list of populations
that must be addressed for the SAPT Block
Grant versus the CMHS Block Grant. Thus,
SAMHSA should identify in each narrative
and table whether it is required or not
required (optional) and which specific
items are required for the
SAPT Block Grant Behavioral Health
Assessment and Plan, or the CMHS
Block Grant Behavioral Health
Assessment and Plan, or both. Each
narrative and table in BGAS should also
be clearly identified as to whether it is
required or optional for the SAPT Block
Grant Behavioral Assessment and Plan.
• Make available to States the criteria that
CSAT and CSAP Project Officers will use to
105

inconsistencies in the review of State block
grant applications.
Because of the challenges that this table
presents to many states in regard to their
existing infrastructure capacity to report
the data, this table is requested and states
are asked to provide any data that is
available.

Block Grant Comment Log (Continuous)
review and approve the SAPT Block Grant
Behavioral Health Assessment and Plan
and annual SAPT Block Grant Report at
least two-four months prior to the due
dates. The review criteria should include
how compliance and completeness are to
be determined in a reasonable and logical
manner for narratives and tables that are
required and not required. In previous
years during conference calls between
NASADAD members and CSAT on the
SAPT Block Grant Application, CSAT
indicated that review criteria would be
made available to States, but this has not
yet occurred.
• Significantly improve the training of
Project Officers to enable them to
provide consistent, clear and practical
guidance to States. We urge SAMHSA
to implement the following
recommendations from the "Final
Evaluation Report Executive Summary
of the Independent Evaluation of the
Substance Abuse Prevention and
Treatment Block Grant Program"
conducted by the Altarum Institute for
SAMHSA and released in July
2009:
• Provide opportunities for internal
communication within CSAT and

106

Block Grant Comment Log (Continuous)

183.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

CSAP, training and mentoring staff
to ensure that consistent guidance
is provided to States.
•
Strengthen ongoing communication between
State Project Officers and their assigned states via
devoted resources for knowledge management.
During SAMHSA's past negotiations with the States
which resulted in agreement on the National
Outcome Measures (NOMs) for substance abuse
treatment and prevention, SAMHSA had pledged to
reduce respondent burden of the SAPT Block Grant
Application. We believe this pledge is not supported
by the broad and expanded scope and nature of the
proposed application. We believe SAMHSA
continues to significantly underestimate the burden.
Please note the following:
Although the OMB clearance
received last year for the current 20122013 Application Guidance (0930-0168)
does not expire until July 31,2014,
SAMHSA is already proposing revisions
that would considerably expand the
areas of focus in the proposed FY 20142015 Behavioral Health Assessment and
Plan. While five areas of focus from the
current FY 2012-2013 Behavioral Health
Assessment and Plan would be dropped,
13 new ones would be added to the FY
2014-2015 version. However, the
estimates ofthe FY 2014-2015
application burden published in the
107

Through the development of the National
Behavioral Health Quality Framework,
SAMHSA is working to reassess its data
collection and reporting requirements , and
is committed to engaging states as part of
this process to develop a system that will
reduce burden yet provide the data
necessary to adequately manage and
monitor federal investments in promoting
quality behavioral health services.
.

Block Grant Comment Log (Continuous)
Federal Register notice of July 13, 2012,
do not reflect this increase. The
estimates of the burden are the same as
the estimates for the FY 2012-2013
application burden published in the
previous Federal Register notice of June
17, 2011. In NASADAD's comments on
the proposed FY 2014-2015 SAPT Block
Grant Application, NASADAD noted,
"Significant year-to-year changes by
SAMHSA to the application can
undermine enthusiasm and dilute
progress on any one area of focus or
goal. Every change, especially additional
requirements without corresponding
eliminations, spreads resources too thin
and risks reducing effectiveness and
impact."
• We have serious concerns and questions
regarding the major new planning and data
collection elements involving SAMHSA's
Behavioral Health Barometer proposed in
new section G-Quality in the Behavioral
Health Assessment and Plan. Using
information from the Behavioral Health
Barometer, states are asked to (1) provide
up to three additional measures that each
State will focus on in developing the State's
Block Grant Plan, (2) provide information
on any additional measures identified

108

Block Grant Comment Log (Continuous)
outside of the core measures and state
barometer, (3) describe the State's specific
priority areas to address the issues
identified by the data, and (4) describe the
milestones and plans for addressing each
of the State's priority areas. States are
also asked a series of additional questions
regarding the use of measures from the
National Quality Behavioral Health
Framework which "may require states
and/or their providers to report new
information." Section G appears to be a
request for a separate mini-plan within the
Behavioral Health Assessment and Plan.
This section appears to overlap with the
requirements for Table 1-Priority Area and
Annual Performance Indicators, but the
instructions for Table 1 do not specify that
the State must use three measures from
the Behavioral Health Barometer for its
priority areas and performance indicators.
According to the instructions for Table 1,
"SAMHSA will provide each state with its
state specific outcome data for several
indicators from the Behavioral Health
Barometer. States can use this to compare
their data to national data and to focus
state efforts and resources on the areas
where the state needs to improve."
It is unclear whether States are required

109

Block Grant Comment Log (Continuous)
to use information from the Behavioral
Health Barometer in Table 1. SAMHSA
does not indicate when it will provide
each State with information from the
Behavioral Health Barometer. It is
unclear if/how SAMHSA will hold States
accountable in addressing measures from
the Behavioral Health Barometer. Due to
this lack of clarity and information, we
recommend that SAMHSA clarify the
instructions for Table 1 regarding the use
of information from the Behavioral
Health Barometer and delete or revise
section G to address questions or issues
that differ from Table 1. Also, we would
like to reiterate NASADAD's
recommendation on the Behavioral
Health Barometer: "SAMHSA should
provide more clarity on how the agency
intends to incorporate "behavioral health
barometers," and how they will work with
the National Outcome Measures (NOMs)
and States' current data collection
efforts. We also urge SAMHSA to provide
State substance abuse agencies flexibility
based on a State substance abuse
agency's data infrastructure and
capabilities."
• According to the instructions for Table 1Priority Area and Annual Performance

110

Block Grant Comment Log (Continuous)
Indicators in the proposed FY 2014-2015
Behavioral Health Assessment and Plan,
"If a state fails to achieve its goals as
stipulated in its application(s) approved
by SAMHSA, the state will provide a
description of corrective actions to be
taken. If further steps are not taken,
SAMHSA may ask the state for a revised
plan to achieve its goals. SAMHSA will
work with the state on the development
of the plan." We would like to reiterate
NASADAD's recommendation on the
corrective action plan: "We believe
criteria should be developed to help
assess whether or not a State has taken
"reasonable" actions with regard to its
corrective action plan. We also
recommend the development of a
formalized consultation process that
would convene SAMHSA and the
impacted State should any disagreements
develop with regard to goals, corrective
action plans, and success in taking
"reasonable" steps to improve services."
• In the proposed FY 2014-2015 Behavioral
Health Assessment and Plan, Table 3-State
Agency Planned Block Grant Expenditures by
Service, is an expanded version of Table 5Projected Expenditures for Treatment and
Recovery Supports, from the FY 2012-2013
Behavioral Health Assessment and Plan. Table
111

Block Grant Comment Log (Continuous)
3 includes three new columns, Unduplicated
Individuals, Unit Type, and Unit Quantity, for
each of the 49 services listed, thus substantially
expanding the table by adding 147 new cells.
No service definitions or instructions on how to
complete these columns are provided. Table 3
has also been revised to collect information on
the dollar amounts of Block Grant expenditures
projected for each ofthe 49 services listed.
Last year, States were requested to only
provide projected Block Grant expenditures by
percent ranges, <10%, 10-25%, 26-50%, 5175%, and over 75%, for the services listed. The
proposed revision from percent ranges to
dollar amounts would significantly increase the
level of detail regarding projected expenditures
for each service, as well as increase the
difficulty in developing meaningful projections
at such detailed service levels for both
expenditures and numbers of unduplicated
individuals served. We question the practical
utility of so many detailed projections. Thus,
we recommend deleting Table 3 or replacing it
with last year's Table 5 instead. This would
help to minimize the reporting burden and
maintain consistency with the FY 2012-2013
Behavioral Health Assessment and Plan.
• In the proposed FY 2014-2015
Behavioral Health Assessment and Plan
and the proposed FY 2014 SAPT Block
Grant Report, Table Sa would require

112

Block Grant Comment Log (Continuous)
States to report their primary prevention
expenditures, planned and actual
respectively, by the six CSAP strategies
and Section 1926-Tobacco stratified by
the Institute of Medicine (IOM)
categories of universal, selective and
indicated. SAMHSA does not provide
definitions or examples for each of
these new 21 stratified prevention
categories which appear to result in
some
incompatible
definitional
breakdowns, e.g., universal within
problem identification and referral. A
new Table 5b, which has been added to
the proposed FY 2014-2015 Behavioral
Health Assessment and Plan and the
proposed FY 2014 SAPT Block Grant
Report, would require States to report
their primary prevention expenditures,
planned and actual, based on the IOM
categories. Tables 5a and 5b overlap
and are redundant. We recommend
revising and simplifying Table 5a by
removing the stratification using the
10M categories, and giving States the
option of reporting their primary
prevention expenditures using either
Table 5a or Table 5b plus Section 1926Tobacco. This would be consistent with
the option that CSAP had been providing
to States for the FY 2008 to 2011 SAPT

113

Block Grant Comment Log (Continuous)
Block Grant applications in which States
could report their primary prevention
expenditures
using either the six
prevention strategies or the IOM
categories.
• SAMHSA proposes to include a new
Table 5c-SABG Planned Primary
Prevention Targeted Priorities in both
the Behavioral Health Assessment and
Plan and SAPT Block Grant Report. This
increases the application and reporting
burden.
• The reporting burden for the treatment
and prevention NOMs and the Annual
Synar Report, included in past Federal
Register notices on revisions to the
SAPT Block Grant Application, were not
included in the Federal Register notice
of July 13, 2012.
• SAMHSA's estimates of the application
and reporting burden do not reflect the
many months each year that most States,
including Hawaii, spend on reviewing the
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
According to the Final Evaluation Report

114

Block Grant Comment Log (Continuous)
Executive Summary of the Independent
Evaluation of the Substance Abuse
Prevention and Treatment Block Grant
Program, conducted by the Altarum
Institute for SAMHSA and released in July
2009, "The majority of States spend 6 to 9
months each year gathering information
for and developing the BG application,
using staff resources that States argue
could be better spent on TA for providers
and other BG
subrecipients."

184.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

• To help reduce the reporting burden for
requested or optional data and minimize unduly
burdensome and inappropriate application revision
requests for such data, we urge SAMHSA to utilize
other data collection mechanisms such as surveys
conducted by NASADAD and other contractors to
collect non-required data.
There continue to be delays and glitches in utilizing
BGAS to complete and submit the application due
to numerous and substantive changes that must be
operationalized as a result of combining and
restructuring the substance abuse and mental
health applications and reporting sections with
different due dates. These delays and glitches are
compounded by the transition to a new BGAS
contractor last year and launching of a new version
ofBGAS where many new technical as well as
policy and procedural issues continually arise. We

115

SAMHSA agrees with the commenter
regarding the impact of the application
format introduced in the FY 2012-2013
Behavioral Health Assessment and Plan and
the proposed revisions introduced in the FY
2014-2015 Behavioral Health Assessment
and Plan. Further, SAMHSA agrees with the
commenter regarding the fidelity issues
between the FY 2014-2015 Behavioral
Health Assessment and Plan and the
instructions embedded in Web BGAS.
SAMHSA’s Contract Officer Representative

Block Grant Comment Log (Continuous)

185.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

appreciate the hard work and diligent efforts of the
new BGAS contractor to improve the system, and
we understand that BGAS has been and continues
to be an evolving system. But SAMHSA's
numerous, unclear, and late changes to the
application process, instructions and forms have
increased fidelity problems between BGAS and the
hard copy of the application and report instructions
and forms. In tum, these problems have increased
the application and reporting burden.
We appreciate removal ofthe 17 Federal Goals
from the SAPT Block Grant Application's planning
and reporting requirements. However, their
removal has been replaced by the new planning
and data collection requirements, expanded areas
of focus, and new tables. Moreover, SAMHSA still
requires States to submit the SAPT Block Grant
Funding Agreements/Certifications and Assurances
signed by their Governors or designees to ensure
compliance with these requirements. Thus,
substantial State time, efforts and resources will
continue to be needed to ensure compliance with
these extensive statutory requirements which are
mischaracterized as "minimal requirements" in the
Federal Register Notice of July 13, 2012. States
must continue to document compliance for
independent audits, for CSAT technical/compliance
reviews, and for CSAP prevention and Synar
system/compliance reviews. Unless States are
provided with flexibility or relief from some
outdated and unduly restrictive requirements, it

116

is working closely with SAMHSA’s centers
and the Web BGAS contractor to resolve
the fidelity issues.

The Interim Final Rule still remains in
effect for the SABG.
States must continue to document
compliance for independent audits, for
CSAT technical/compliance reviews, and
for CSAP prevention and Synar
system/compliance reviews.
For those requirements that are contained
in statute, SAMHSA will consider the need
for continuation in discussions regarding
SAMHSA’s reauthorization.

Block Grant Comment Log (Continuous)
would not be very reasonable or realistic to expect
States to effectively address the increased and
expanded initiatives in the proposed FY 2014-15
Behavioral Health Assessment and Plan without
adequate staffing and funding.
An example of an outdated and unduly restrictive
requirement is the maintenance of effort (MOE)
requirement for pregnant women and women with
dependent children. We believe it is essential to
provide services for this vulnerable population.
Please note, however, that this requirement is
especially restrictive for Hawaii. In compliance with
42 U.S.C. 300x-22(b)(l) and the 19-year old formula
in the 1993 Interim Final Rule (45 C.P.R. §96.124(c),
Hawaii's MOE base was set at $1,719,039. This is
still23% of our FY 2012 SAPT Block Grant
allotment, a substantial amount relative to meeting
other service needs. While the State may use any
combination of SAPT Block Grant and State general
funds to meet the MOE spending requirement for
this population, the State is prohibited from
adjusting or determining spending levels based on
current needs. This lack of flexibility is exacerbated
by cutbacks in State general funds due to State
budget deficits.
The HIV early intervention services
requirement (42 U.S.C. 300x-24(b) and 45
C.P.R. §96.128) is also outdated and unduly
restrictive. Designated States must spend 5%
117

Block Grant Comment Log (Continuous)
oftheir current SAPT Block Grant allotment to
provide HIV early intervention services to
substance abusers at the site at which they
receive substance abuse treatment. At the
time this requirement was established 19
years ago, it probably was not anticipated that
AIDS case rates would fluctuate above and
below the 10 per 100,000 threshold which
determines a designated State. Since then,
Hawaii and other States have experienced
AIDs case rates that fluctuate above and
below the designated State threshold. Based
on policy guidance from the Office of General
Counsel in 2002, SAMHSA prohibits nondesignated States from expending any SAPT
Block Grant funds for HIV early intervention
services. This prohibition also applies to
formerly designated States during a nondesignated year. Such States like Hawaii must
find other sources of funding in order to
maintain former Block Grant-funded programs
for HIV early intervention services and
prevent disruptive and detrimental impacts
on clients.
Congressional reauthorization of the Block Grant,
which would presumably eliminate certain statutory
requirements no longer deemed useful or
necessary and provide States with more flexibility
in managing their Block Grant funds, has not
occurred since 2000. Moreover, the

118

Block Grant Comment Log (Continuous)

186.

187.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of

1993 Interim Final Rule still remains in effect.
We have serious concerns about SAMHSA's efforts
in trying to align the activity and expenditure
reporting periods for the SAPT Block Grant with the
CMHS Block Grant. The SAPT Block Grant
Application has historically required States to
report close-out expenditures for the Block Grant
that was awarded three years prior to the Federal
fiscal year Block Grant for which States are
applying. This takes into account the two-year
obligation and expenditure period for the SAPT
Block Grant. Hawaii has historically spent the
annual SAPT Block Grant allotment primarily during
the second year of the two-year obligation and
expenditure period.
Please note that Hawaii and other States may still be
spending their "close-out" annual SAPT Block Grant
allotment until the September 30 Block Grant closeout date which is just three months after the
preceding State fiscal year ends on June 30. Also,
the December 1 due date of the annual SAPT Block
Grant Report is 30 days prior to the December 31
due date of the annual Federal Financial Report for
the close-out Block Grant allotment. We urge
SAMHSA to continue to allow States to report their
close-out expenditures according to the State fiscal
year consistent with each State's close-out period.
For Table 1-Priority Area and Annual Performance
Indicators- Progress Report, "States are required
to indicate whether each first-year performance
target/outcome measurement identified in the
119

Section 1932(a)(1)(5) of Title XIX, Part B,
Subpart II of the PHS Act (42 USC 300x32(a)(1)(5)) and 45 CFR 96.122(f) require a
State to prepare and submit a report for
the fiscal year three years prior to the fiscal
year for which a State is applying for a
grant and such reports were to be
submitted on or before October 1 of the
fiscal year for which a State is applying for a
grant. During 2011, SAMHSA announced its
plan to (1) change the timeframe covered
by a report, i.e., the State fiscal year
immediately preceding the Federal fiscal
year for which a State is applying for a
grant and (2) change the receipt date for
such reports. The rationale for the change
was described in the June 17 edition of the
Federal Register (76 FR 35454) and
subsequently approved by the Office of
Management and Budget.

States may report progress towards the
goals. In cell 7 States can select Goal Not
Achieved and provide an explaination in
the comment section that the fiscl year has

Block Grant Comment Log (Continuous)
Health, State of
Hawaii

188.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

2014/2015 Plan was 'Achieved" or "Not Achieved."
If a target was not achieved, a detailed explanation
must be provided as well as the remedial steps
proposed to meet the target." The period for the
first-year target/outcome measurement is
"Progress- end ofSFY 2014." However, the FY
2014 SAPT Block Grant Report is due by December
1, 2013, before SFY 2014 ends on June 30, 2014.
How can the State be expected to report on
whether the first-year target was achieved seven
months before the first year (SFY 2014) ends?
Should the first-year be based on SFY 2013 instead
ofSFY 2014? Could SAMHSA please correct or
clarify the reporting period for the first and second
years?
A new Table 3-Substance Abuse Block Grant
Expenditures by Service, has been added to the
already considerable list of tables and data
elements for which States are required to report
expenditures and services. This Table 3 is the same
as the Table 3 in the proposed FY 20142015 Behavioral Health Assessment and Plan, except
SAMHSA would be collecting information on actual
instead of projected data. We recommend deleting
Table 3 in the SAPT Block Grant Report. States
cannot reasonably be expected to retroactively
report actual expenditures, numbers of unduplicated
individuals served, and unit type and quantity for so
many new services when State data systems are not
designed to collect such extensive data by detailed
breakdowns. Additional funding and time would be
needed to incorporate and test modifications to
120

not ended – and procide update the
following year.

Block Grant Comment Log (Continuous)

189.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,
Department of
Health, State of
Hawaii

190.

9/11/12

Nancy A. Haag,
Chief, Alcohol and
Drug Abuse Division,

State data systems as well as to train providers in
appropriate reporting. Since SAMHSA has not
provided service definitions for these services, data
reported by States would not be comparable. In
addition, some services listed do not align with the
statutory and regulatory purposes ofthe SAPT Block
Grant, e.g., acute primary care, general health
services, tests and immunization, homemaker
services, and mental health residential services for
adults and children.
For Table ?-Statewide Entity Inventory, which is a
version of the previous Form 9 from the FY 2012
SAPT Block Grant Application, five new columns
have been added: provider/program name, street
address, city, state, and zip code. This would
significantly increase the reporting burden for each
entity. Adding a separate column to identify the
State for each entity appears to be especially
redundant and superfluous since the table has a
State Identifier. Historically, for the SAPT Block
application, a separate list of provider's name,
street address, city/state and zip code was required
only for entities that did not have an Inventory of
Substance Abuse Treatment Services (1-SATS) ID.
There does not appear to be a compelling reason to
require this information for each entity in Table 7.
Thus, we recommend deleting the five new columns,
and instead requiring a separate list only for entities
without an 1-SATS ID.
For Table 32-Population-Based Programs and
Strategies-Number ofPersons Served by Age,
Gender, Race, and Ethnicity, we continue to believe
the requirement to report the numbers of persons
121

SAMHSA will use the historical process and
ask for that information for those providers
that do not yet have an I-SATS ID. It should
be noted that a National identifier is
required.

This Table will be removed from the
application

Block Grant Comment Log (Continuous)
Department of
Health, State of
Hawaii

served by detailed age, gender, race, and ethnicity
breakdowns for population-based programs is
unrealistic and impractical. It is not possible to
collect individual data or calculate reliable or
meaningful estimates on the age, gender, race, and
ethnicity on all persons impacted by populationbased programs and strategies, especially for single
events involving large masses of people or activities
that do not register individual participants.
Recommendation One supports the first
recommendation submitted by the Children’s Mental
Health Network, namely that there be full public
transparency in all block grant planning processes. In
my twenty years of experience as a policy advocate in
New York State, I found that, even with initial good
intentions, the process quickly becomes a closed and
technical one, involving a small group of compliant
participants. Given SAMHSA’s intention of making the
combined Block Grants a major vehicle for
funding and implementing programs with the states, a
far more inclusive process must be required. Beyond
posting announcements of meetings and of planning
committee membership, efforts must be made to build
and engage the multiple constituencies with possible
interests.

191.

9/11/12

Evelyn R. Frankford,
MSW , Principal,
Frankford
Consulting

192.

9/11/12

Evelyn R. Frankford, Recommendation Two again supports the
Children’s Mental Health Network, namely that
MSW , Principal,
Frankford Consulting there be equity in funding between child and
adult mental health services.
This equitable funding strategy needs also to take
into account Transition Age Youth and Young Adults,

122

SAMHSA believes that state’s should have
the flexibility in providing funding for
mental health services for
childrenaccording to the state’s identified
need.

Block Grant Comment Log (Continuous)

193.

9/11/12

who fall, in terms of age, into both groups and
sometimes in-between them. Transition Age Youth
have specific needs, both clinical and non-clinical
(education completion, workforce preparation,
housing), and they themselves should be the
primary expositors of what these needs and
aspirations are. Block Grant guidelines for the states
should provide direction for incorporating the full
range of challenges and opportunities around
Transition Age Youth. (Please see my comments of
May 12, 2011 to SAMHSA on the Block Grant
Collection Activities.) Block Grant funds can serve as
behavioral health hubs from which spokes funded
by other systems (education, workforce) emanate.
Evelyn R. Frankford, Recommendation Three urges that SAMHSA take a
public health approach to children’s mental health
MSW , Principal,
Frankford Consulting and require states to do the same, that is, an
approach based in a population focus rather than
medical models only; that systemically promotes
mental health and prevents problems; that
addresses social determinants of health; and that
gathers data for decision-making.
In the Block Grant Application, SAMHSA recommends
that such funds be directed to fund primary
prevention for persons not identified as needing
treatment (p. 7). Such a focus will build on the
wellness promotion and prevention strategies that
are incorporated into health reform. The IOM report
Preventing Mental, Emotional, and Behavioral
Disorders Among Young People: Progress and

123

Thank you for your comment

Block Grant Comment Log (Continuous)
Possibilities, cited in your document, concludes that
successful interventions were oriented not to the
individual but were systemic and that individual
interventions were not sustainable.

194.

9/11/12

Unlike the substance abuse agencies, which have
worked with the Strategic Prevention Framework,
State Mental Health Authorities have traditionally not
seen prevention or systemic interventions as part of
their responsibilities and they may not be aware of the
advances in prevention for children and youth. They
will likely need some prodding from SAMHSA to
incorporate this knowledge and to conceptualize their
plans along these lines.
Evelyn R. Frankford, Recommendation Four urges that SAMHSA use the
Block Grant to ensure that states engage with and
MSW , Principal,
Frankford Consulting promote comprehensive approaches to schoolbased behavioral health. Again, the IOM report
demonstrates that long-term interventions built on
a developmental framework are successful and can
target risk factors and strengthen protective factors
in young people.
Since they are systemic rather than clinical, schoolbased approaches involve deep collaboration with
the education system, including building on schools’
initiatives in social and emotional development and
learning and they may involve restructuring to ensure
an environment more conducive to child development.
Given SAMHSA’s recognition of trauma as a public
health problem, with associated disruptions in daily
functioning such as education, we bring to your
124

Thank you for your comment

Block Grant Comment Log (Continuous)
attention initiatives that specifically address trauma by
restructuring schools to encompass health and
wellness and promote social and emotional learning.

125

Block Grant Comment Log (Continuous)
BEHAVIORAL HEALTH ASSESSMENT AND PLAN SECTION
#

Date
Received

Commenter/
Section

Organization

Comment/Question

Disposition of Comment/ Rationale

8/13/12

Framework
for Planning

National
Federation of
Families for
Children’s
Mental Health

One of the biggest concerns of the family
movement has been the disproportionality of
spending on children’s behavioral health
services in comparison to adult services.
Therefore, we request SAMHSA to include
language such as, “At a minimum, the plan
should address the following populations with
representation that is equal to state
demographics”. We do not request a specific
percentage of dollars be spent on children,
because we do not want to cause the
unintended consequence of a few progressive
states decreasing their spending on children.

Mental Health Block Grant statute indicates
that the State must provide social services,
educational services, juvenile services,
substance abuse services and mental health
services for children with serious emotional
disturbance; however, it does not require a
specified amount. SAMHSA’s addition of the
Children and Adolescents Behavioral Health
Services section in the FY 2014/15 plan and
application recognizes the importance of
children services. Additionally, SAMHSA
carefully reviews the appropriateness of
children and adolescent services during the
plan approval process.

8/13/12

Children
and
Adolescents

National
Federation of
Families for
Children’s
Mental Health

Just as adult consumers are able to recover from
mental illness, children are able to bounce back
from adversity as long as certain circumstances
exist to support the child and the child’s family.
The 10 guiding principles of recovery are
appropriate for adult consumers, and we believe
that under the “Children and Adolescents
Behavioral health Services” section, it is
important to similarly delineate the dimensions
of resilience.

Recovery is addressed in the Children and
Adolescents Behavioral Health Services
section, as well as, the Recovery sections.

126

Block Grant Comment Log (Continuous)
Some of the circumstances that support
resilience and mental health promotion for
children and youth include:
•
At least one supportive adult
outside a child’s family
•
Places to live, learn and play that are
safe, supportive, and have clear and
appropriate rules and consequences
•
Service providers that know how to
identify and build on unique
strengths, skills, and abilities of
children and youth
•
Neighborhoods that are safe, value
their children and expect them to
succeed
•
Communities and schools that have
appropriate and purposeful roles for
their youth
•
Communities with affordable
housing
•
Communities that respect and
support the role of parenting
•
Employers who offer living wages
and health insurance
3.

8/13/12

Behavioral
Health
Advisory
Council

National
Federation of
Families for
Children’s
Mental Health

SAMHSA values the presence of family members
representing children and youth. It is equally
important that parents and caregivers have a
level of preparation to serve as strong advocates
on behalf of families. Therefore, we suggest
adding language that encourages appointment

127

The Behavioral Health Planning Council
requires the representation of family
members of youth or children, leading State
experts, and representation from Children
serving agencies.

Block Grant Comment Log (Continuous)
of a family member who is resourced by a family
organization to provide sustained leadership and
community-based support.
4.

8/24/2012 Children
and
Adolescents

Tennessee’s
Federation of
Families for
Children’s
Mental
Health/Board of
Directors

8/24/2012 Children
and
Adolescents

Tennessee’s
Federation of
Families for
Children’s
Mental
Health/Board of
Directors

8/24/2012 Children
and
Adolescents

Tennessee’s
Federation of
Families for
Children’s
Mental
Health/Board of
Directors

We request that SAMHSA address the need for
substantial BG resources for family support,
prevention and early intervention services and
coordinate these efforts with the Affordable
Care Act. We request that states not decrease
their level of funding for children’s mental
health and that as a minimum that funding
representation is equal to state demographics
Support children and adolescents through the
principles and values of systems of care and
outlining the dimensions of resilience

Key principles should be combined with:
1. At least one supportive adult outside
child’s family
2. Places to live, learn and play that are
safe, supportive and have clear and
appropriate rules & consequence
3. Service providers that know how to
identify & build on unique strengths,
skills and abilities of children and youth
4. Neighborhoods that are safe, value their
children and expect them to success

128

For FY 2014/2015, SAMHSA requested states
to not spend less state funding on child mental
health services than was spent in FY 2008.

SAMHSA’s addition of the Children and
Adolescents Behavioral Health Services section
in the 2014/15 combined plan and application
recognizes the importance of the principles
and values of systems of care and dimensions
of resilience. SAMHSA will carefully review
the appropriateness of children and
adolescent services during the plan approval
process.
SAMHSA Mental Health BG and Children’s
Mental Health staff are currently collaborating
to develop guidelines to review state plans to
appropriately address the key principles
during the plan review process.

Block Grant Comment Log (Continuous)
5. Communities and schools that have
appropriate and purposeful roles for
their youth
6. Communities with affordable housing
7. Communities that respect and support
the role of parenting
8. Employers who offer living wages and
health insurance
7.

8/24/2012 Behavioral
Health
Advisory
Council

9/4/12

Prevention,
Children
and
Adolescents

Tennessee’s
Federation of
Families for
Children’s
Mental
Health/Board of
Directors
Heidi Lasser,
Program
Specialist,
Idaho
Department of
Health and
Welfare,
Division of
Behavioral
Health

Recommend that a family member supported by
a family organization be named to BH Advisory
council

The Behavioral Health Planning Council
requires the representation of family
members of youth or children, leading State
experts, and representation from Children
serving agencies.

I still do not see ANY funding being allocated
from SAMSA for prevention in the 2014-2015
Block Grant. I recommend SAMHSA allocate
some funding toward Children’s Prevention in
the next Block Grant. I also still see a lack of
emphasis toward funding children’s mental
health treatment in general.

In the 2014-2015 application and plan,
substance abuse primary prevention is
described in detail. The comprehensive
substance abuse primary prevention program
shall include activities and services provided
in a variety of settings for both the general
population as well as targeting subgroups who
are at high risk for substance abuse. This
includes age groups across the lifespan which
also gives States the opportunity to implement
and fund utilizing the 20% set aside of the
SABG for substance abuse primary prevention
activities and services directed at children.
However, States should be focused on
following the Strategic Prevention Framework
Logic model to develop a comprehensive plan
for substance abuse primary prevention

129

Block Grant Comment Log (Continuous)
programming and ensures that data is
collected and analysed to identify the
substances of abuse and populations that
should be targetd with substance abuse
primary prevetion set aside funds.

9/4/12

Trauma

Heidi Lasser,
Program
Specialist,
Idaho
Department of
Health and
Welfare,
Division of
Behavioral
Health

10.

9/4/12

Prevention,
Children
and
Adolescents
, Trauma

Heidi Lasser,
Program
Specialist,
Idaho
Department of
Health and
Welfare,
Division of
Behavioral
Health

In addition, I see a push toward traumaInformed and trauma treatment by SAMHSA.
This is excellent and a long time coming.
However, most trauma is experienced in
childhood. Again, childhood would be an
excellent time to begin the funding and focus of
programs for both male and female victims of
trauma throughout the country to begin a
prevention and treatment campaign, in order to
save millions of dollars for states for these teens
and children later in life, since it would no longer
be necessary for many of them to enter into the
adult mental health system in the intensive way
that they would have.
I recommend this upcoming 2014-205 Block
Grant allocate a great deal of funding toward
Children’s prevention, and Children’s mental
health treatment, including trauma treatment.

130

Thank you for your comment.

In the FY 2014-2015 application and plan,
substance abuse primary prevention is
described in detail. The comprehensive
substance abuse primary prevention program
shall include activities and services provided
in a variety of settings for both the general
population as well as targeting subgroups who
are at high risk for substance abuse. However,
States should be focused on following the
Strategic Prevention Framework Logic model
to develop a comprehensive plan for
substance abuse primary prevention

11.

9/6/12

Health
Disparities

Alixe McNeill,
Chair, National
Coalition on
Mental Health
and Aging

12.

9/7/12

Framework
for Planning

Arthur T. Dean,
Major General,
U.S. Army,
Retired,
Chairman and
CEO, Community
Anti-Drug
Coalitions of
America
(CADCA)

An example of the lack of attention to older
adults is found in the discussion of “Health
Disparities” which defines subpopulations.
Although older adults clearly meet the definition
of having “…disparate access to, use of, or
outcomes from provided services…” they are not
addressed in any of the discussion. Additionally,
“age” is not included in the list of factors that
states will be required to address regarding
access, use, and outcomes for subpopulations as
it had been previously.
The confusion concerning adding mental
health promotion as a priority in the
joint application is further exacerbated
by the fact that the "Framework for
Planning" on page 44 does not actually
require, but only encourages states to
consider both "community settings for
universal, selective and indicated
prevention interventions" and
"community populations for
environmental prevention activities,"
which are the key components of

131

Thank you for your comment. The populations
identified in the Block Grant application were
selected based on Section 4302 of the
Affordable Care Act and the Secretary’s Action
Plan for Eliminating Racial and Ethnic
Disparities. In addition to the populations
identified in the Block Grant application and
these HHS documents, states may report on
additional populations serviced that may be
vulnerable to disparities.
States will be allowed to use some of their
current CMHS Block Grant to support mental
health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for substance
abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as

Block Grant Comment Log (Continuous)
substance abuse prevention as currently
authorized in current law for the
use of the 20% prevention set aside in the
SAPTBG.

13.

9/7/12

Behavioral
Health
Advisory
Council

Arthur T. Dean,
Major General,
U.S. Army,
Retired,
Chairman and
CEO, Community
Anti-Drug
Coalitions of
America
(CADCA)

CADCA recommends that given substance
abuse prevention is a major authorized
priority of the current SAPTBG, with a
required 20% set aside of state allocated
funding for this purpose, the Framework for
Planning section in the Uniform Application
on page 44 be changed to require that
community settings for universal selected
and indicated prevention and intervention
be moved to the category for items
that must be addressed "at a minimum," and
taken out of the "encouraged to be
considered" category.
CADCA also has concerns about the new
State Behavioral Health Advisory
Committee being only "encouraged" to
include appropriate representation from
both the substance abuse prevention and
treatment communities.
CADCA recommends that states opting
to use the Uniform Application, and
thus having only one state council for

132

education, juvenile justice involvement,
violence prevention and mental health..

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Health Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.

Block Grant Comment Log (Continuous)
both the Mental Health and Substance
Abuse purposes, be required to ensure
fair, balanced and appropriate
representation from the substance
abuse prevention, treatment and
recovery communities.
14.

9/7/12

Table 3

Patricia A.
Rehmer, MSN,
Commissioner,
State of
Connecticut
Department of
Mental Health
and Addiction
Services, A
Healthcare
Service Agency

SAMHSA continues to request States
provide more details of services received
and individuals served through Block Grant
funds, as relates to Table 3 – State Agency
Planned Block Grant Expenditures by
Services of the application. DMHAS mostly
funds community based addiction and
mental health services through grants.
While community providers report to the
Department both expenditure and client
information, these data are not specific to
persons receiving services funded only
through Block Grant dollars. As community
providers have various funding streams
(state general funds, client fees, Medicaid,
etc.) including the SAPT and CMHS Block
Grants, DMHAS would need to move to an
entirely different method of funding and
tracking services and clients to comply with
SAMHSA’s proposed reporting

133

This is a requested table. States can provide
whatever level of data that are currently
available.

Block Grant Comment Log (Continuous)
requirement. This would entail major
changes to both the Department’s
information and accounting system. The
exact cost and burden is unknown but
would be significant.
15.

9/7/12

Quality

Patricia A.
Rehmer, MSN,
Commissioner,
State of
Connecticut
Department of
Mental Health
and Addiction
Services, A
Healthcare
Service Agency

Connecticut supports SAMHSA’s efforts at
establishing quality measures to assure the
most efficient and effective use of Block
Grant funds. DMHAS is committed to
evaluating its behavioral health services
based upon relevant outcomes and quality
of care measures and has been developing
provider report cards over the last year.
These report cards are based upon a
number of key performance measures
which will be shared with our providers and

As envisioned, the Barometer will include and
report on data collected through SAMHSA and
other federal survey efforts, and thus should
not represent any additional data collection
burden to states.

the public. What concerns Connecticut is
SAMHSA’s development of a National
Behavioral Health Barometer and how that
will fit with Connecticut’s efforts? Any
changes in data collection from DMHAS
provider agencies would be costly and
certainly would require sufficient time for
implementation.
16.

9/10/12

Framework
for Planning

Sharon Kramer,
M.Ed., CPP,
Executive

The confusion concerning adding mental health
promotion as a priority in the joint application is
further exacerbated by the fact that the

134

States will be allowed to use some of their
current CMHS Block Grant to support mental
health promotion and mental illness

Block Grant Comment Log (Continuous)
Director,
Manatee County
Substance Abuse
Coalition

prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for substance
abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health...

require that community settings for
universal selected and indicated prevention
and intervention be moved to the category
for items that must be addressed “at a
minimum,” and taken out of the
“encouraged to be considered” category.
17.

9/10/12

Sharon Kramer,
M.Ed., CPP,
Executive
Director,
Manatee County
Substance Abuse

MCSAC also has concerns about the new State
Behavioral Health Advisory Committee being
only “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.

135

Block Grant Comment Log (Continuous)
Coalition

18.

9/10/12

Karen A. Murray,
County Coalition
Director, The
Butler County
Coalition for
healthy, safe &
drug-free
communities

MCSAC recommends that states opting to use
the Uniform Application, and thus having only
one state council for both the Mental Health and
Substance Abuse purposes, be required to
ensure fair, balanced and appropriate
representation from the substance abuse
prevention, treatment and recovery
communities.
The confusion concerning adding mental
health promotion as a priority in the
joint application is further exacerbated
by the fact that the "Framework for
Planning" on page 44 does not actually
require, but only encourages states to
consider both "community settings for
universal, selective and indicated
prevention interventions" and
"community populations for
environmental prevention activities,"
which are the key components of
substance abuse prevention as currently
authorized in current law for the
use of the 20% prevention set aside in the
SAPTBG.
The BCC recommends that given substance
abuse prevention is a major authorized
priority of the current SAPTBG, with a

136

to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.

Block Grant Comment Log (Continuous)

19.

9/10/12

Behavioral
Health
Advisory
Council

Karen A. Murray,
County Coalition
Director, The
Butler County
Coalition for
healthy, safe &
drug-free
communities

required 20% set aside of state allocated
funding for this purpose, the Framework for
Planning section in the Uniform Application
on page 44 be changed to require that
community settings for universal selected
and indicated prevention and intervention
be moved to the category for items
that must be addressed "at a minimum," and
taken out of the "encouraged to be
considered" category.
The BCC also has concerns about the new
State Behavioral Health Advisory
Committee being only "encouraged" to
include appropriate representation from
both the substance abuse prevention and
treatment communities.
The BCC recommends that states opting
to use the Uniform Application, and
thus having only one state council for
both the Mental Health and Substance
Abuse purposes, be required to ensure
fair, balanced and appropriate
representation from the substance
abuse prevention, treatment and

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.

recovery communities.
20.

9/10/12

Framework
for Planning

Pat VanOflen,
Coalition

The confusion concerning adding mental health
promotion as a priority in the joint application is
137

States will be allowed to use some of their
current CMHS Block Grant to support mental

Block Grant Comment Log (Continuous)
Coordinator,
Coalition for Safe
and Drug-Free
Fairfield

further exacerbated by the fact that the
“Framework for Planning” on page 44 does not
actually require, but only encourages states to
consider both “community settings for universal,
selective and indicated prevention
interventions” and “community populations for
environmental prevention activities,” which are
the key components of substance abuse
prevention as currently authorized in current
law for the use of the 20% prevention set aside
in the SAPTBG.
CADCA recommends that given substance
abuse prevention is a major authorized
priority of the current SAPTBG, with a
required 20% set aside of state allocated
funding for this purpose, the Framework
for Planning section in the Uniform
Application on page 44 be changed to
require that community settings for
universal selected and indicated prevention
and intervention be moved to the category
for items that must be addressed “at a
minimum,” and taken out of the
“encouraged to be considered” category.

21.

9/10/12

Behavioral
Health
Advisory
Council

Pat VanOflen,
Coalition
Coordinator,
Coalition for Safe
and Drug-Free

CADCA also has concerns about the new State
Behavioral Health Advisory Committee being
only “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.
138

health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for substance
abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health.

Block Grant Comment Log (Continuous)
Fairfield
CADCA recommends that states opting to
use the Uniform Application, and thus
having only one state council for both the
Mental Health and Substance Abuse
purposes, be required to ensure fair,
balanced and appropriate representation
from the substance abuse prevention,
treatment and recovery communities.
22.

9/10/12

Framework
for Planning

Sarah C.
Dinklage, LICSW,
Executive
Director, Rhode
Island Student
Assistance
Services, a
division of
Coastline EAP

The confusion concerning adding mental health
promotion as a priority in the joint application is
further exacerbated by the fact that the
“Framework for Planning” on page 44 does not
actually require, but only encourages states to
consider both “community settings for universal,
selective and indicated prevention
interventions” and “community populations for
environmental prevention activities,” which are
the key components of substance abuse
prevention as currently authorized in current
law for the use of the 20% prevention set aside
in the SAPTBG.
CADCA recommends that given substance abuse
prevention is a major authorized priority of the
current SAPTBG, with a required 20% set aside
of state allocated funding for this purpose, the
Framework for Planning section in the Uniform
Application on page 44 be changed to require
that community settings for universal selected
and indicated prevention and intervention be
139

SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
The table has been changed to capture this
information.

Block Grant Comment Log (Continuous)

23.

9/10/12

Behavioral
Health
Advisory
Council

Sarah C.
Dinklage, LICSW,
Executive
Director, Rhode
Island Student
Assistance
Services, a
division of
Coastline EAP

24.

9/10/12

Framework
for Planning

Greg Puckett,
Executive
Director,
Community
Connections, Inc.

moved to the category for items that must be
addressed “at a minimum,” and taken out of the
“encouraged to be considered” category.
CADCA also has concerns about the new State
Behavioral Health Advisory Committee being
only “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
CADCA recommends that states opting to use
to a State Behavioral Helath Advisory
the Uniform Application, and thus having only
Committee which will include adequate
one state council for both the Mental Health and representation of SA prevention and
Substance Abuse purposes, be required to
treatment and individuals in recovery from SA.
ensure fair, balanced and appropriate
SAMHSA has modified the table to collect this
representation from the substance abuse
information.
prevention, treatment and recovery
communities.
The confusion concerning adding mental health
States will be allowed to use some of their
promotion as a priority in the joint application is current CMHS Block Grant to support mental
further exacerbated by the fact that the
health promotion and mental illness
“Framework for Planning” on page 44 does not
prevention activities related to adults with
actually require, but only encourages states to
serious mental illnesses and children with
consider both “community settings for universal, serious emotional disturbances disturbances
selective and indicated prevention
and their families.
interventions” and “community populations for
The 20% set aside funds of the Substance
environmental prevention activities,” which are Abuse Block Grant must be used for substance
the key components of substance abuse
abuse primary prevention activities by the
prevention as currently authorized in current
state. Many evidenced-based substance
law for the use of the 20% prevention set aside
abuse programs have a positive impact on the
in the SAPTBG.
prevention of substance use and abuse as well
as other health and social outcomes such as
Community Connections recommends that given education, juvenile justice involvement,
substance abuse prevention is a major
violence prevention and mental health...
140

Block Grant Comment Log (Continuous)

25.

26.

9/10/12

Behavioral
Health
Advisory
Council

Framework
for Planning

Greg Puckett,
Executive
Director,
Community
Connections, Inc.

Cindy Grant,
Director,
Hillsborough
County Anti Drug
Alliance, Inc.

authorized priority of the current SAPTBG, with
a required 20% set aside of state allocated
funding for this purpose, the Framework for
Planning section in the Uniform Application on
page 44 be changed to require that community
settings for universal selected and indicated
prevention and intervention be moved to the
category for items that must be addressed “at a
minimum,” and taken out of the “encouraged to
be considered” category.
We also have concerns about the new State
Behavioral Health Advisory Committee being
only “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.
Community Connections recommends that
states opting to use the Uniform Application,
and thus having only one state council for both
the Mental Health and Substance Abuse
purposes, be required to ensure fair, balanced
and appropriate representation from the
substance abuse prevention, treatment and
recovery communities.
The confusion concerning adding mental health
promotion as a priority in the joint application is
further exacerbated by the fact that the
“Framework for Planning” on page 44 does not
actually require, but only encourages states to
consider both “community settings for universal,
selective and indicated prevention
interventions” and “community populations for
environmental prevention activities,” which are
141

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.

Block Grant Comment Log (Continuous)
the key components of substance abuse
prevention as currently authorized in current
law for the use of the 20% prevention set aside
in the SAPTBG.

27.

9/10/12

Behavioral
Health
Advisory
Council

Cindy Grant,
Director,
Hillsborough
County Anti Drug
Alliance, Inc.

28.

9/10/12

Framework
for Planning

Jackie Griffin,
MS, LiveFree!
Executive

HCADA recommends that given substance abuse
prevention is a major authorized priority of the
current SAPTBG, with a required 20% set aside
of state allocated funding for this purpose, the
Framework for Planning section in the Uniform
Application on page 44 be changed to require
that community settings for universal selected
and indicated prevention and intervention be
moved to the category for items that must be
addressed “at a minimum,” and taken out of the
“encouraged to be considered” category.
HCADA also has concerns about the new State
Behavioral Health Advisory Committee only
being “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.

abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health.

Block Grant Comment Log (Continuous)
Director

29.

9/10/12

Behavioral
Health
Advisory
Council

Jackie Griffin,
MS, LiveFree!
Executive
Director

“Framework for Planning” on page 44 does not
actually require, but only encourages states to
consider both “community settings for universal,
selective and indicated prevention
interventions” and “community populations for
environmental prevention activities,” which are
the key components of substance abuse
prevention as currently authorized in current
law for the use of the 20% prevention set aside
in the SAPTBG.
LiveFree! Pinellas recommends that given
substance abuse prevention is a major
authorized priority of the current SAPTBG, with
a required 20% set aside of state allocated
funding for this purpose, the Framework for
Planning section in the Uniform Application on
page 44 be changed to require that community
settings for universal selected and indicated
prevention and intervention be moved to the
category for items that must be addressed “at a
minimum,” and taken out of the “encouraged to
be considered” category.
LiveFree! Pinellas also has concerns about the
new State Behavioral Health Advisory
Committee being only “encouraged” to include
appropriate representation from both the
substance abuse prevention and treatment
communities.
LiveFree! Pinellas recommends that states
opting to use the Uniform Application, and thus
having only one state council for both the
143

prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for substance
abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health.

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.

Block Grant Comment Log (Continuous)

30.

31.

9/10/12

Framework
for Planning

Behavioral
Health
Advisory

Gwendolyn W.
Brown, Chairman
and CEO, Genesis
Prevention
Coalition, Inc.,
Excellence in
Community
Service

Gwendolyn W.
Brown, Chairman
and CEO, Genesis

Mental Health and Substance Abuse purposes,
be required to ensure fair, balanced and
appropriate representation from the substance
abuse prevention, treatment and recovery
communities.
The confusion concerning adding mental health
promotion as a priority in the joint application is
further exacerbated by the fact that the
“Framework for Planning” on page 44 does not
actually require, but
only encourages states to consider both
“community settings for universal, selective and
indicated prevention interventions” and
“community populations for environmental
prevention activities,” which are the key
components of substance abuse prevention as
currently authorized in current law for the use of
the 20% prevention set aside in the SAPTBG.
GPC recommends that given substance abuse
prevention is a major authorized priority of the
current SAPTBG, with a required 20% set aside
of state allocated funding for this purpose, the
Framework for Planning section in the Uniform
Application on page 44 be changed to require
that community settings for universal selected
and indicated prevention and intervention be
moved to the category for items that must be
addressed “at a minimum,” and taken out of the
“encouraged to be considered” category.
GPC also has concerns about the new State
Behavioral Health Advisory Committee being
only “encouraged” to include appropriate
144

SAMHSA has modified the table to collect this
information.

The Mental Health Planning Council is defined
in the MHBG Statute including required
membership. SAMHSA does not have

Block Grant Comment Log (Continuous)

32.

9/10/12

Council

Prevention
Coalition, Inc.,
Excellence in
Community
Service

Framework
for Planning

Erica Leary, MPH,
Program
Manager, North
Coastal
Prevention
Coalition, Serving
the Communities
of Carlsbad,
Oceanside and
Vista

representation from both the substance abuse
prevention and treatment communities.
GPC recommends that states opting to use the
Uniform Application, and thus having only one
state council for both the Mental Health and
Substance Abuse purposes, be required to
ensure fair, balanced and appropriate
representation from the substance abuse
prevention, treatment and recovery
communities.
NCPC is concerned that the “Framework
for Planning” on page 44 does not
actually require, but only encourages
states to consider both “community
settings for universal, selective and
indicated prevention interventions” and
“community populations for
environmental prevention activities,”
which are the key components of
substance abuse prevention as currently
authorized in current law for the use of
the 20% prevention set aside in the
SAPTBG.
We recommend that given substance abuse
prevention is a major authorized priority of the
current SAPTBG, with a required 20% set aside of
state allocated funding for this purpose, the
Framework for Planning section in the Uniform
Application on page 44 be changed to require
that community settings for universal selected
and indicated prevention and intervention be
moved to the category for items that must be
145

authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.
States will be allowed to use some of their
current CMHS Block Grant to support mental
health promotion and mental illness
prevention activities related to adults with
serious mental illnesses and children with
serious emotional disturbances and their
families.
The 20% set aside funds of the Substance
Abuse Block Grant must be used for substance
abuse primary prevention activities by the
state. Many evidenced-based substance
abuse programs have a positive impact on the
prevention of substance use and abuse as well
as other health and social outcomes such as
education, juvenile justice involvement,
violence prevention and mental health...

Block Grant Comment Log (Continuous)

33.

34.

9/10/12

Framework
for Planning

Behavioral
Health

Debbie
Moskovitz,
Project Director ,
Council Rock
Coalition for
Healthy Youth

Debbie
Moskovitz,

addressed “at a minimum,” and taken out of the
“encouraged to be considered” category.
The confusion concerning adding mental health
promotion as a priority in the joint application is
further exacerbated by the fact that the
“Framework for Planning” on page 44 does not
actually require, but only encourages states to
consider both “community settings for universal,
selective and indicated prevention
interventions” and “community populations for
environmental prevention activities,” which are
the key components of substance abuse
prevention as currently authorized in current
law for the use of the 20% prevention set aside
in the SAPTBG.
CADCA recommends that given
substance abuse prevention is a major
authorized priority of the current
SAPTBG, with a required 20% set aside
of state allocated funding for this
purpose, the Framework for Planning
section in the Uniform Application on
page 44 be changed to require that
community settings for universal
selected and indicated prevention and
intervention be moved to the category
for items that must be addressed “at a
minimum,” and taken out of the
“encouraged to be considered”
category.
CADCA also has concerns about the new State
Behavioral Health Advisory Committee being
146

The Mental Health Planning Council is defined
in the MHBG Statute including required

Block Grant Comment Log (Continuous)
Advisory
Council

35.

9/11/12

Health
Disparities

Project Director ,
Council Rock
Coalition for
Healthy Youth

Monica Cissell,
Chair, Aging and
Wellness
Coalition of
Sedgwick County,
Sedgwick County
Department on
Aging, Sedgwick,
County, Kansas

only “encouraged” to include appropriate
representation from both the substance abuse
prevention and treatment communities.
CADCA recommends that states opting
to use the Uniform Application, and
thus having only one state council for
both the Mental Health and Substance
Abuse purposes, be required to ensure
fair, balanced and appropriate
representation from the substance
abuse prevention, treatment and
recovery communities.
An example of the lack of attention to older
adults is found in the discussion of "Health
Disparities" which defines subpopulations.
Although older adults clearly meet the
definition of having "...disparate access to, use
of,or outcomes from provided services..." they
are not addressed in any of the discussion.
Additionally, "age" is not included in the list
offactors that states wil! be required to
address regarding access,use, and outcomes for
subpopulations as it had been previously.

147

membership. SAMHSA does not have
authority to require the states to expand the
existing required membership. However, it is
SAMSHA’s intent to encourage states to move
to a State Behavioral Helath Advisory
Committee which will include adequate
representation of SA prevention and
treatment and individuals in recovery from SA.
SAMHSA has modified the table to collect this
information.

The populations identified in the Block Grant
application were selected based on Section
4302 of the Affordable Care Act and the
Secretary’s Action Plan for Eliminating Racial
and Ethnic Disparities. In addition to the
populations identified in the Block Grant
application and these HHS documents, states
may report on additional populations serviced
that may be vulnerable to disparities.

Block Grant Comment Log (Continuous)
REPORTING SECTION
#
1.

Date
Received
9/10/12

Section

Commenter/
Organization
Robert W.
Glover, Ph.D,
Executive
Director,
National
Association of
State Mental
Health Program
Directors
(NASMHPD)

Comment/Question

Disposition of Comment/ Rationale

We are taking this opportunity to comment on reporting
tables for the Mental Health Block Grant (MHBG) that were
included in the new Federal Register Announcement (and
that were first made last year), where SAMHSA changed
the age categories for one of the main URS tables to
standardize the age groupings with Substance Abuse data.
However, SAMHSA has only proposed changing the
categories for one table (labeled Table 11 in the new
Federal Register Packet) and while all the other tables
retained the existing Mental Health age breakout
categories. This lack of internal consistency with tables
reported causes states and SAMHSA to (1) lose the ability
to compare mental health service data across time, (2)
make data edit comparisons between URS tables and (3)
causes State Behavioral Health Agencies (SBHAs) and
SAMHSA to lose information about the important mental
health population of Adults age 21 and over (since age 21 is
important to mental health providers due to the Medicaid
Institution for Mental Disease {IMD} restriction on
payments to adults age
21 and over.)

CMHS will work with NASMHPD to
develop a mechanism for continuing
to collect data with the existing age
ranges in URS from the states, and
developing a translation of the data
to fit the SAMSHA age ranges when
the data is uploaded into BGAS

By SAMHSA simply adding two subgroups to their new
table, it could have data that would be both consistent with
Substance Abuse and with their history in the URS and with
other MHBG tables in the new Application.
Current URS Age Groups (and age groups used for most tables
in the new MHBG
148

Block Grant Comment Log (Continuous)
announcement):
0-12 (elementary school ages)
13-17 (middle/high school)
18-20 (older teenagers up to age 21 when the IMD rule kicks
in)
21-64 (adults—again starting with age 21 because of the MH
IMD rule
65-74 (older adults)
75+
(much older adults)
Proposed age groups in the MHBG announcement for
Table 11A & B (based on Substance Abuse age
groupings):
0-17
18-24
25-64
65+
NASMHPD suggests splitting the new table into the
following age groups in order to provide SAMHSA with its
desired consistency in age groups between mental health
and substance abuse, while allowing mental health
systems and SAMHSA to have information about the IMD
(over age 21) population and provide better historical
trend analyses:
Proposed 0-17 ages would become (1) 0 to 12 and (2) 13-17
Proposed 18-24 ages would become (1) 18-20 and (2) 21-24
We have developed the proposed table below to further
describe these modifications. The categories in
Red and with an * are the proposed changes:
149

Block Grant Comment Log (Continuous)

9/10/12

Robert W.
Glover, Ph.D,
Executive
Director,
National
Association of
State Mental
Health Program
Directors
(NASMHPD)

9/10/12

Robert W.
Glover, Ph.D,
Executive
Director,
National
Association of
State Mental
Health Program
Directors
(NASMHPD)

Similarly, SAMHSA added (last year) reporting of the report of
Pregnant Women to one of the URS
tables (Table 11 A and B in the new Federal Register
Announcement). A few SBHAs that have integrated behavioral
health data systems report to us that they will be able to
report this data, but for states that do not have this data
element it will be expensive to start collecting. Based on our
discussions, SBHAs are unclear on the purpose of collecting
data about Pregnant Women in the mental health system.
Given the expense of adding data elements and the SBHA need
for new data for health care reform implementation,
behavioral health integration, and other issues, we are unclear
on why is SAMHSA asking for “Pregnant Women” as a new
data element.
NASMHPD and SBHAs commend SAMHSA for compiling
important information about how states use of the Block
Grants and making several of the tables that would be difficult
(or impossible for many states to report) be “Requested”
rather than “Required”. We support SAMHSA’s gathering this
information from states that can report these tables.
However, we want to express a concern from SBHAs that
some of these tables (such as Table 3) would be incredibly
burdensome if made “Required” in the future. As long as the
tables remain “Requested” but not “Required”, SBHAs are not
as concerned, but they are concerned that the tables could be
made a requirement in the future.

150

If states have this data available it
can be reported. If they do not, they
are not required to report this data.

SAMHSA recognizes the additional
burden that would be imposed by
requiring the reporting of these data
for states that do not have the
infrastructure to report .
Because of the challenges that this
table presents to many states in
regard to their existing infrastructure
capacity to report the data, this table
is requested and states are asked to
provide any data that is available.

File Type	application/pdf
File Title	Block Grant Comment Log (Continuous)
Author	Department of Health and Human Services
File Modified	2012-10-03
File Created	2012-09-28