Comments

9605 Medical Center Drive, Ste 280 • Rockville, MD 20850 • Phone ~ 240-403-1901 • Fax ~ 240-403-1909 • www.ffcmh.org

August 8, 2012
Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Re: Comments on the Uniform Application for the Mental Health Block Grant and Substance Abuse Block
Grant FY 2014-2015 Application (OMB No. 0930-0168)
Dear Ms. King:
The National Federation of Families for Children’s Mental Health is a family-run organization that arose
20 years ago from a grassroots movement. Our membership includes more than 120 chapters and state
organizations representing the families of children and youth with mental health needs. We believe that
families should have a primary decision-making role in the care of their own children as well as in the
development of policies and procedures governing care for all children in their community, state, tribe,
territory, and nation.
These comments are submitted in response to the Substance Abuse and Mental Health Services
Administration’s (SAMHSA) request for comments on the Uniform Application for the Mental Health
Block Grant and Substance Abuse Block Grant FY 2014-2015 Application Guidance and Instructions
(OMB No. 0930-0168), published in the Federal Register on July 13, 2012.
Framework for Planning
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.
Children and Resilience
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.

The National Family Voice for Children’s Mental Health

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

Behavioral Health Advisor Council
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 of a family member who
is resourced by a family organization to provide sustained leadership and community-based support.

We appreciate the opportunity to comment on this proposed revision to the block grant applications
and urge that you make the changes we have proposed above before issuing the final RFA to states.

Sincerely,
National Federation of Families for Children’s Mental Health

Tennessee Voices for Children, Tennessee’s Federation of Families for Children’s Mental Health
701 Bradford Ave.
Nashville, TN 37204
Phone 615/269-7751
Fax 615/269-9914
www.tnvoices.org
August 18, 2012
Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Re:
Comments on the Uniform Application for the Mental Health Block Grant and Substance Abuse Block Grant FY
2014-2015 Application (OMB No. 0930-0168)
Dear Ms. King:
Tennessee Voices for Children, Inc. (TVC) is a state-wide non-profit family-run organization that was founded more than
twenty years ago by Tipper Gore with the mission to speak out as active advocates for the well-being of children and
families with mental health needs. TVC is the state chapter in Tennessee for the Federation of Families for Children’s
Mental Health. We provide support, information and training to more than 115,000 Tennesseans annually. We support
the principles of family-driven and youth guided care and believe families should be the primary decision makers in the
development of policies and in the care of their own children.
These comments are submitted in response to the Substance Abuse and Mental Health Services Administration’s
(SAMHSA) request for comments on the Uniform Application for the Mental Health Block Grant and Substance Abuse
Block Grant FY2014-2015 Application Guidance and Instructions (OMB No. 0930-0168), published in the Federal Register
on July 13, 2012.
As a family organization, one of our continuing concerns has been having the funding available in the children’s system to
provide the support, prevention, early intervention and treatment needed for children’s behavioral health services. We
know from analysis of expenditures on services for children in Tennessee that the cost per child is substantially less for
prevention and early intervention services than it is for intensive intervention. These services are not only more cost
effective, they are more humane than waiting until problems have escalated before providing treatment.
We request that SAMHSA address the need for substantial Block Grant resources for family support, prevention and early
intervention services and to coordinate these efforts with those of 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.
It is important to support children and adolescents by supporting the principles and values of systems of care and by
outlining the dimensions of resilience. The key principles (comprehensiveness, individualized services, community based,
culturally and linguistically appropriate, early intervention, family driven, youth guided, service coordination, protection of
rights, and support for transition to adulthood) should be combined with the circumstances that support resilience and
promote mental health for children and youth. These 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
Speaking Out For the Well-Being of Tennessee’s Children
Tipper Gore, Founder

•
•

Communities that respect and support the role of parenting
Employers who offer living wages and health insurance

We further strongly recommend that a family member supported by a family organization be named to the Behavioral
Health Advisory Council to provide the critical family voice and leadership.
Thank you so much for the opportunity to comment on this proposed revision to the block grant application and urge that
you consider the changes that have been proposed before issuing the final RFA to states.
Sincerely,
Tennessee Voices for Children
Board of Directors

Speaking Out For the Well-Being of Tennessee’s Children
Tipper Gore, Founder

National Association of State Alcohol and Drug Abuse Directors, Inc .
President
Mark Stringer
Missouri
First Vice President
Theodora Binion
Illinois
Vice President
for Internal Affairs
Barbara Cimaglio
Vermont
Vice President
for Treatment
Gajef McNeill
Illinois
Vice President
for Prevention
Janice Petersen, Ph.D.
North Carolina
Immediate
Past President
Flo Stein
North Carolina
Secretary
JoAnne Hoesel
North Dakota
Treasurer
Kathy Skippen
Idaho
Regional Directors
Joseph Harding, NH
Region I
TBA
Region II
Gary Tennis, PA
Region III
Cassandra Price, GA
Region IV
Orman Hall, OH
Region V
Rochelle Head-Dunham, M.D., LA
Region VI
Kathy Stone, IA
Region VII
JoAnne Hoesel, ND
Region VIII
Deborah McBride, NV
Region IX
Kathy Skippen, ID
Region X

Executive Director
Robert I. L. Morrison

August 30, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 8-1099
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
The National Association of State Alcohol and Drug Abuse Directors
(NASADAD) appreciates the opportunity to comment on the proposed Substance
Abuse Prevention and Treatment (SAPT) Block Grant Uniform Application FFY
2014-15 and Instructions (OMB No. 0930–0168)—Revision, published in the
Federal Register, Volume 77, Number 135, Friday, July 13, 2012. The SAPT
Block Grant is the cornerstone of States’ substance abuse prevention, treatment
and recovery systems. It accounts for approximately 40 percent of expenditures
by State substance abuse agencies across the country, and on average 64 percent
of States’ substance abuse prevention expenditures. The SAPT Block Grant is a
vital safety net service for individuals with or at risk of a substance use disorder.
We certainly support the Substance Abuse and Mental Health Services
Administration’s (SAMHSA) goal of improving and modernizing the SAPT
Block Grant application. We have a proven track record of working in
partnership with SAMHSA on data and SAPT Block Grant application matters.
We are concerned, however, that the Federal Register Notice (FRN) seems to
indicate that the proposed changes in the draft SAPT Block Grant application
were based on NASADAD recommendations. While SAMHSA did seek input
from NASADAD and individual State substance abuse directors, the proposed
draft changes does not reflect NASADAD recommendations.
We have reviewed the proposed 2014/2015 SAPT Block Grant Application and
appreciate that there is an option for State substance abuse agencies to submit a
separate SAPT Block Grant application and report. We have also highlighted our
concerns with the proposed application, and note our remaining concerns from
the 2012/2013 SAPT Block Grant application that were not addressed. We also
include a summary of our concerns and recommendations for the final
application.
We are concerned with the following provisions in the proposed FY 2014/2015
SAPT Block Grant application:

____________________________________________________________________________________________________________________________________

1025 Connecticut Avenue NW, Suite 605



Washington, DC 20036



(202) 293-0090



Fax: (202) 293-1250  Email: [email protected]

Deadline for Submission: States are increasingly concerned about the April 1 deadline for
the SAPT Block Grant application, which will coincide with State legislative sessions.
Behavioral Health Barometers and Data Collection: The proposed SAPT Block Grant
application does not identify what measures will be included in the barometer, which makes
planning difficult.
Multiple Goals and Purposes of the Proposed SAPT Block Grant Application: Multiple
divergent purposes for the revision requests place a heavy burden on States.
We remain concerned about the following provisions we highlighted in the FY 2012/2013 SAPT
Block Grant application:
Requested Information/Compliance Requirements: The application should better identify
what information is required versus requested. In addition, SAMHSA should identify which
sections may be submitted after the statutory deadline, and what SAMHSA will deem as
compliant as this has caused confusion and a delay in the approval of applications.
Planning Steps: The draft SAPT Block Grant application requests States outline actions in
their State plan pertaining to a significant number of new populations. We note that this
request for expanded activities or services comes at a time when the Administration cut
funding for the SAPT Block Grant and proposed further cuts in FY 2013 through the Public
Health Evaluation “tap.”
Joint Planning: The joint planning request should maintain and endorse clinical, financial,
and programmatic integrity of prevention and treatment for substance use disorders.
Terminology: We are concerned that the application uses the generic term “States” and
identifies the Substance Abuse Prevention and Treatment (SAPT) Block Grant as the
Substance Abuse Block Grant (SABG).
Corrective Action Plans: 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.
FY 2012 and FY 2014 Budget Request: We are concerned that the proposed application
discusses a proposed policy change to the SAPT Block Grant that has not been approved by
Congress. This mention could cause confusion.
NASADAD Recommendations
Again, we would like to reiterate our commitment to improving the SAPT Block Grant as a path
toward better service delivery. We also recognize SAMHSA’s need to streamline elements
contained in the SAPT Block Grant application. We are concerned however, about the State
burden resulting from the changes to the SAPT Block Grant application. As a result, we urge that
the following recommendations be considered for the final application:
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.

2

Recommendation: Work with NASADAD to address the concerns of State substance abuse
agencies as a result of the April 1 deadline.
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 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 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.
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
3

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 (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.
Compliance Requirements: Given the numerous changes to the SAPT Block Grant 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
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 that 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 burden to State substance abuse agencies.
Recommendation: A clear set of consistent criterion must be included in the final document
for both State substance abuse agencies and SAMHSA project officers to use when
submitting and evaluating the application and more information for completing each section.
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 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.
4

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 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.
Terminology: The document refers to the generic term “States,” and changes the term for the
SAPT Block Grant to Substance Abuse Block Grant (SABG).
Recommendation: We recommend specific references to the term State substance abuse
agency. We also 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.
In addition to our previous comments, we urge you to consider and include in the final
application the following comments:
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 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.
5

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.
Thank you for your consideration of these comments. Please feel free to contact me if you have
any questions.
Sincerely,

Robert Morrison
Executive Director

6

Page 1 of 2

From:                                         Lasser, Heidi ‐ CO 3rd [[email protected]] 
Sent:                                           Tuesday, September 04, 2012 5:10 PM 
To:                                               BlockGrants (SAMHSA) 
Cc:                                               Lasser, Heidi ‐ CO 3rd 
Subject:                                     Comments on 2014‐2015 Boock Grant Focus 

Dear Summer King and SAMHSA, 

I am the Children’s Planner for Idaho and this will be my second year helping to develop the joint 
Substance abuse and mental health Block Grant for Idaho. This year I attended the Block Grant 
conference for the second year in a row, and I again heard the strong emphasis on the Number One 
Strategic Goal of SAMHSA, which as you know is Prevention. I heard it being strongly emphasized both 
this year and last year for children. I wholeheartedly agree with this philosophy and principle. I 
attended the Children’s Prevention breakout session at this year’s Block Grant conference and I have 
attended many other webinars through Brass Tacks (spelling) and other agencies with similar goals, 
that continue to provide the same statistics and message……..That children’s mental health is where 
the states need the funding the most, that states need to plan differently and begin to reallocate their 
funding to start to address the problems in the beginning, where the mental health problems first 
arise, and eventually save millions of dollars in costly treatments when these children become adults 
and have already made the poor decisions that have messed up their lives; that most people who have 
mental illnesses, have an average age of onset as a child or teenager, etc.   But, with all this knowledge 
and all the push from SAMHSA to focus on prevention for children, 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 addition, I  see a push toward  trauma‐Informed 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. 

Imagine the domino effects this could have in a positive way, with more productive citizens, fewer 
hospitalizations, lower suicide rates, lower crime rates, lower sex offenses, etc,  if more children were 
able to deal with their victimization issues and mental health/substance abuse issues in real time, as it 
was happening and unfolding, and if families were given the tools to deal with the children as they 
were  experiencing the issues, instead of waiting for years after all the damage was done and then 
trying to unravel all the pieces. Imagine how much healthier we could all be. Imagine how much less 
expensive a system that would be.  

Right now the system is upside down because we keep putting band‐aids on the problems, and 
because of fear that it will get out of control if we allocate the funding differently. 

I believe it is already out of control….we are almost out of funding, and it is time we do the right thing 
for the children, and try something different. 

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Page 2 of 2

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. 

Thanks.   

Sincerely, 

Heidi Lasser 

Heidi Lasser, MA, LCPC, NCC 
Program Specialist 
Idaho Department of Health and Welfare 
Division of Behavioral Health 
450 W. State Street, 3rd Floor 
Boise, ID 83702 
(208) 334‐4955 

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file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Pennsylvania’s Office of Mental Health and Substance Abuse Services (OMHSAS) has
reviewed the recent SAMHSA public notice regarding the Uniform Application for the Mental
Health Block Grant and Substance Abuse Block Grant FY 2014-2015 Application
Guidance and Instructions OMB No. 0930-0168)- Revision, as found in the Federal
Register/Vol. 77, No. 135/July 13, 2012/Notices. Please accept the following comments:
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.
• 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 20142015 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
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 Bullet- OMHSAS 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
grant-funded 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.
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.

Page 1 of 1

From:                                         Amy Stevens [[email protected]] 
Sent:                                           Wednesday, September 05, 2012 4:46 PM 
To:                                               BlockGrants (SAMHSA) 
Subject:                                     Comments on Block Grant Collection Activities 

Dear Ms. King.  I understand that SAMHSA is asking for input on proposed changes to block grants.  I have a few 
comments for your consideration. 

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

2. 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.  

3. 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 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.  

I realize my comments may be beyond the scope of the input you are seeking but I have not had an opportunity for input 
in the past.  Thank you for all considerations.  

Sincerely,  

Dr. Amy Stevens, EdD., LPC 
Arcadian Resources 
995 Roswell Street, Suite 100 
Marietta, GA 30060 
Office: 770‐509‐1034 
Cell: 770‐309‐7877 

Military Veteran Advocate 
Counseling and Consultant Services 
www.arcadianresources.com 

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

September 5, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2–1057
1 Choke Cherry Road
Rockville, Maryland 20857
Sent by email to [email protected].
Dear Ms. King:
On behalf of the National Coalition on Mental Health and Aging thank you for the opportunity to
comment on the proposed “Uniform Application for the Mental Health Block Grant and
Substance Abuse Block Grant FY 2014-2015 Application Guidance and Instructions (OMB No.
0930-0168)-Revision” as published in the Federal Register, July 13, 2012.
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 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.

September 5, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Page 2
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 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 National Coalition on Mental Health and Aging was founded in 1991 and is composed of
over 80 national organizations, federal agencies and state and local coalitions. The Coalition is
an educational organization with the mission of improving the mental health of older Americans.
Information about the Coalition can be obtained on our website www.ncmha.org .
Thank you for your consideration,

Alixe McNeill, Chair
National Coalition on Mental Health and Aging

STATE OF CONNECTICUT
DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES
A Healthcare Service Agency

DANNEL P. MALLOY
GOVERNOR

PATRICIA A. REHMER, MSN
COMMISSIONER

September 7, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, Maryland 20857
Dear Ms. King:
Connecticut appreciates the opportunity to comment on the Substance Abuse and Mental Health
Services Administration’s (SAMHSA) proposed Block Grant applications, as issued in the Federal
Register Notice (Volume 77, Number 135, Friday, July 13, 2012). Connecticut’s comments also
reflect information provided in the draft FY 2014 - 2015 Community Mental Health Services Block
Grant and Substance Abuse Prevention and Treatment Block Grant application as posted on the
SAMHSA block grant website http://www.samhsa.gov/grants/blockgrant/.
We recognize SAMHSA’s continued leadership role in aligning services funded under the Substance
Abuse Prevention and Treatment (SAPT) and Community Mental Health Services (CMHS) Block
Grants with provisions in the Affordable Care Act (AKA health reform). The proposed FY 20142015 Block Grant application contains a number of meaningful components meant to encourage
States in advancing their behavioral health service systems. Some of these are improving
coordination of care especially between primary and behavioral health providers, expanding
recovery supports and advancing wellness services, increasing the quality of services by investing in
best practice models and demonstrating system improvements through performance measurement.
Connecticut shares this vision and has made significant inroads in these and other system
enhancements over the years.
Since 1995 Connecticut’s Single State Agency for Substance Abuse and the State Mental Health
Authority for adults has been one, cabinet-level state agency (Department of Mental Health and
Addiction Services – DMHAS). This unified organizational structure has facilitated the integration
of behavioral health services. DMHAS has learned over the past 17 years that change must be well
managed and implications understood by all stakeholders to be successful. While the planning and
implementation of health reform continues to take shape in Connecticut, there is still a ways to go.
The implications of health reform on DMHAS and its partners, i.e. service providers and fellow state
agencies, are continually evolving. Therefore, we feel that some proposed changes in the SAPT and
CMHS Block Grants require more time and input from States in order to fully realize the costs, time
required, and overall burden. DMHAS has several comments in this regard as to the proposed
(AC 860) 418-7000
410 Capitol Avenue, P.O. Box 341431, Hartford, Connecticut 06134
www.dmhas.state.ct.us
An Equal Opportunity Employer

Ms. Summer King
September 7, 2012
Page 2

FY 2014 - 2015 CMHS and SAPT Block Grant application as specified in the Federal Register
Notice as follows.
• 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 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.
• 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.
• 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
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.
• 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 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.

Ms. Summer King
September 7, 2012
Page 3

DMHAS looks forward to working with SAMHSA and its staff during this period of transition. The
Department is supportive of a collaborative effort aimed at improving the delivery of behavioral
health preventive, treatment, and recovery support services.
Sincerely,

Patricia A. Rehmer, MSN
Commissioner

September 7, 2012
Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Re: Comments on the Uniform Application for the Mental Health Block Grant and Substance
Abuse Block Grant FY 2014-2015 Application (OMB No. 0930-0168)
Dear Ms. King:
The Children’s Mental Health Network appreciates the opportunity to provide suggestions for
improving the Uniform Application for the Mental Health Block Grant and Substance Abuse Block
Grant FY 2014-2015. These comments are submitted in response to the Substance Abuse and
Mental Health Services Administration’s (SAMHSA) request for comments on the Uniform
Application for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015
Application Guidance and Instructions (OMB No. 0930-0168), published in the Federal Register
on July 13, 2012.
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.
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.
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.

2201 Wilshire Drive • Durham, NC 27707
http://www.cmhnetwork.org

September
 7,
 2012

Page
 2

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
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 Youth-Guided
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
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.
We appreciate the opportunity to provide suggestions for ways to improve the Uniform Application
for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015.
Sincerely,

Scott Bryant-Comstock
President and CEO
Children’s Mental Health Network

Cc:

Children's Mental Health Network Board of Directors
Children's Mental Health Network Advisory Council

Children’s
 Mental
 Health
 Network
 Solutions

2201 Wilshire Drive • Durham, NC 27707
http://www.cmhnetwork.org

Page 1 of 2

From:                                         Sharon Kramer [[email protected]] 
Sent:                                           Monday, September 10, 2012 9:53 AM 
To:                                               BlockGrants (SAMHSA) 
Subject:                                     Uniform Application for the Mental Health Block Grant and Substanvec Abuse Block 
Grant FY2014‐2015 (OMB No. 0930‐0168) 

Importance:                            High 

Dear Ms. King: 

Manatee County Substance Abuse Coalition (MCSAC) which represents more than 300 coalition members 
appreciates the opportunity to comment on the proposed Uniform Application for the Mental Health Block 
Grant and Substance Abuse Block Grant FY 2014‐2015 Application Guidance and Instructions (OMB No. 0930–
0168)—Revision, published in the Federal Register, Volume 77, Number 135, Friday, July 13, 2012.  

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 following specific provisions in the FY 2014‐2015 Guidance Instructions.  

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 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. 

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.  

MCSAC 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.  

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Page 2 of 2

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.  

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.   

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.  

Thank you for considering Manatee County Substance Abuse Coalition’s views on the provisions in the FY 2014‐
2015 Guidance Instructions in the Uniform Block Grant Application. Please feel free to contact me if you have 
any questions or concerns.  

Sincerely, 

Sharon Kramer, M.Ed., CPP 
Executive Director 
Manatee County Substance Abuse Coalition 
1112 Manatee Avenue West, Suite 303 
Bradenton, Florida 34205 
941-749-3030 Extension 3491 
941-932-5620 (cell) 
www.drugfreemanatee.org 

The information contained in this e-mail and any accompanying documents is confidential, may be
privileged, and is intended solely for the person and/or entity to whom it is addressed (i.e. those
identified in the "To" and "cc" box). They are the property of the Manatee County Substance Abuse
Coalition, Inc. Unauthorized review, use, disclosure, or copying of this communication, or any part
thereof, is strictly prohibited and may be unlawful. Manatee County Substance Abuse Coalition, Inc.
thanks you for your cooperation.  

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

NASMHPD
Board of Directors
Michael Maples, L.P.C., L.M.F.T.
President
Texas
Nancy Rollins
Vice President
New Hampshire
Scot L. Adams, Ph.D.
Secretary
Nebraska
Terri White, M.S.W.
Treasurer
Oklahoma
Kevin Huckshorn, R.N., M.S.N.,
C.A.D.C., I.C.R.C.
Past President
Delaware
Patricia Rehmer, M.S.N.
At-Large Member
Connecticut

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

September 10, 2012
Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
RE: SAMHSA Agency Information Collection Activities – Federal Register Doc
No: 2012-17084 (Project: Uniform Application for the Mental Health Block
Grant and Substance Abuse Block Grant FY 2014– 2015 Application Guidance
and Instructions (OMB No. 0930–0168)–Revision)
Dear Ms. King:
On behalf of the National Association of State Mental Health Program Directors
(NASMHPD), we thank you for this opportunity to submit comments on SAMHSA
Agency Information Collection Activities: Federal Register Doc No: 2012-17084,
Agency Comment Request Issued on July 13, 2012.

Craig Stenning
Northeastern Regional
Representative
Rhode Island

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.)

Doug Varney
Southern Regional
Representative
Tennessee

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.

Lynda Zeller
At-Large Member
Michigan
Tracy J. Plouck
Mid-Western Regional
Representative
Ohio

Lana Stohl, M.B.A., L.C.S.W.
Western Regional
Representative
Utah
Robert W. Glover, Ph.D.
Executive Director
NASMHPD

Current URS Age Groups (and age groups used for most tables in the new MHBG
announcement):
0-12
13-17
18-20
21-64
65-74
75+

(elementary school ages)
(middle/high school)
(older teenagers up to age 21 when the IMD rule kicks in)
(adults—again starting with age 21 because of the MH IMD rule
(older adults)
(much older adults)

OPERATING UNDER A COOPERATIVE AGREEMENT WITH THE NATIONAL GOVERNORS ASSOCIATION

September 10, 2012
Page 2

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:
Existing URS and most
proposed MHBG 2012
Tables

SAMHSA Proposed new
Table 13 A & B Age
Grouping

Age Categories
NRI/NASMHPD could
Recommend

0-12 Years
13-17 years
18-20 years

0-17

25-44
45-64

0-12 Years*
13-17 years*
18-20 years*
21-24*
25-44
45-64

65+

65+

21-64 years
65-74 years
75+ years
Not Available

18-24

Not Available*

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.

September 10, 2012
Page 3

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.
We thank you again for the opportunity to provide these comments, and we would be pleased to answer
any questions on this submission.
Sincerely,

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

September 10, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
CADCA has forwarded this letter to us, as a coalition member of the organization, we echo the
articulated concerns in this letter and wish to go on record as such. Thank you for seeking comments on
this application.
Community Anti-Drug Coalitions of America (CADCA), which represents more than 5,000 community
coalitions nationwide, appreciates the opportunity to comment on the proposed Uniform Application
for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015 Application Guidance
and Instructions (OMB No. 0930–0168)—Revision, published in the Federal Register, Volume 77,
Number 135, Friday, July 13, 2012.
Although CADCA fully understands 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 following specific provisions in the FY 2014-2015 Guidance Instructions.
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
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.
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.
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.
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 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.
Thank you for considering CADCA’s views on the provisions in the FY 2014-2015 Guidance Instructions in
the Uniform Block Grant Application. Please feel free to contact me if you have any questions or
concerns.
Sincerely,

Pat VanOflen
Coalition Coordinator
Coalition for Safe and Drug-Free Fairfield
33 Donald Drive
Fairfield, OH 45014

Page 1 of 1

From:                              Michael J. Kramer [[email protected]]
Sent:                               Monday, September 10, 2012 12:36 PM
To:                                   BlockGrants (SAMHSA)
Subject:                          Attn: Summer King re: comments on SAMHSA Block Grants
September 10, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
re: Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015 Application
Guidance and Instructions
Dear Ms. King
I am writing regarding the request for comments regarding the application guidance and
instructions for the Mental Health Grants and Substance Abuse Block Grants.
I am a superior court judge in Indiana who has taken an interest in seeing that, in addition to
treatment, prevention services are provided to reduce the number of people who suffer from the
disease of addiction, many of whom become incarcerated. I also serve on the Indiana Division of
Mental Health and Addictions advisory committee and am a board member of Community AntiDrug Coalitions of America.
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 chance to a happy and productive future, I object to any
reduction or watering down of substance abuse prevention to our youth.
Sincerely,
Michael J. Kramer
Judge, Noble Superior Court, Div. 2
101 N. Orange St.
Albion, IN 46701
(260) 636-2129
fax (260) 636-3053
[email protected]
[email protected]

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

September 7, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
Community Anti-Drug Coalitions of America (CADCA), which represents more than 5,000 community
coalitions nationwide, appreciates the opportunity to comment on the proposed Uniform Application
for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015 Application Guidance
and Instructions (OMB No. 0930–0168)—Revision, published in the Federal Register, Volume 77,
Number 135, Friday, July 13, 2012.
Although CADCA fully understands 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 following specific provisions in the FY 2014-2015 Guidance Instructions.
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
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.
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.
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.
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 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.
Thank you for considering CADCA’s views on the provisions in the FY 2014-2015 Guidance Instructions in
the Uniform Block Grant Application. Please feel free to contact me if you have any questions or
concerns.
Sincerely,

Arthur T. Dean
Major General, U.S. Army, Retired
Chairman and CEO

Page 1 of 2

From:                                         Cindy Grant [[email protected]] 
Sent:                                           Monday, September 10, 2012 1:36 PM 
To:                                               BlockGrants (SAMHSA) 
Subject:                                     Uniform Application for the Mental Health Block Grant and Substanvec Abuse Block 
Grant FY2014‐2015 (OMB No. 0930‐0168) 

Dear Ms. King: 

Hillsborough County Anti Drug Alliance, Inc. (HCADA) which represents over 200 coalition members in the 
Tampa Bay Area of Florida appreciates the opportunity to comment on the proposed Uniform Application for 
the Mental Health Block Grant and Substance Abuse Block Grant FY 2014‐2015 Application Guidance and 
Instructions (OMB No. 0930–0168)—Revision, published in the Federal Register, Volume 77, Number 135, 
Friday, July 13, 2012.  

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 following specific provisions in the FY 2014‐2015 Guidance Instructions.  

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.  

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. 

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.  

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.  

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Page 2 of 2

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.  

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.   

HCADA 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.  

Thank you for considering Hillsborough County Anti Drug Alliance’s  views on the provisions in the FY 2014‐2015 
Guidance Instructions in the Uniform Block Grant Application. Please feel free to contact me if you have any 
questions or concerns.  

Best regards, 

Cindy 

Cindy Grant, Director 
Hillsborough County Anti Drug Alliance, Inc. 
813‐238‐4034  cell:  352‐871‐8016 
[email protected] 

Take Care of Yourself . . . Take Care of Each Other . . . Take Care of This Place 
hcada

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Page 1 of 2

From:                                         Griffin, Jackie [[email protected]] 
Sent:                                           Monday, September 10, 2012 3:10 PM 
To:                                               BlockGrants (SAMHSA) 
Cc:                                               Griffin, Jackie 
Subject:                                     Uniform Application for the Mental Health Block Grant and Substance Abuse Block 
Grant FY 2014‐2015  

Attention Summer King 
Dear Ms. King: 

Thank you for the opportunity to provide feedback concerning the Mental Health Block Grant and Substance 
Abuse Block Grant.  The LiveFree! Substance Abuse Prevention Coalition of Pinellas County (LiveFree!) Florida 
represents more than 195 individuals collectively working toward improving and enhancing our prevention 
system of care.  We are a proud recipient of the Substance Abuse Mental Health Services Administration Drug 
Free Communities coalition and are grateful for the opportunity to comment on the proposed Uniform 
Application for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014‐2015 Application 
Guidance and Instructions (OMB No. 0930–0168)—Revision, published in the Federal Register, Volume 77, 
Number 135, Friday, July 13, 2012.  

We agree with concerns expressed by CADCA and other Florida coalitions as noted below: 

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 following specific provisions in the FY 2014‐2015 Guidance Instructions.  

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.  

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. 

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.  

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Page 2 of 2

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.  

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 language be 
stricken pending definitive congressional action on these proposed changes.   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 Mental Health and Substance Abuse purposes, be required to ensure fair, balanced and 
appropriate representation from the substance abuse prevention, treatment and recovery communities.  

Thank you for the views on the provisions in the FY 2014‐2015 Guidance Instructions in the Uniform Block Grant 
Application.  

Sincerely, 
Jackie Griffin, MS 
LiveFree! Executive Director 
[email protected] 
(813) 503‐5658 

?Re-disclosure Prohibited?
This message may include information that has been disclosed to you from records whose confidentiality is protected by State and Federal
Law. 42 CFR, Part 2, prohibits you from making any further disclosure without specific written authorization of the person to whom it
pertains or as otherwise permitted by 42CFR, Part2. A general authorization is NOT sufficient for this purpose. The Federal rules restrict any
use of the information to criminally investigate or prosecute any alcohol or drug abuse patient. 

file://C:\Documents and Settings\Jeffery.Hunter\My Documents\Filing_Cabinet\Projects\B... 9/14/2012

Prevention Coalition, Inc.

Excellence in Community Service

September 7, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
Genesis Prevention Coalition, Inc. (GPC) represents a network of over 29 faith and community-based
organizations providing substance abuse prevention and mental health services/resources in the
Metropolitan Atlanta area. Our Coalition appreciates the opportunity to submit comments on the
proposed Uniform Application for the Mental Health Block Grant and Substance Abuse Block Grant FY
2014-2015 Application Guidance and Instructions (OMB No. 0930–0168)—Revision, published in the
Federal Register, Volume 77, Number 135, Friday, July 13, 2012.
Although GPC fully understands 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 following specific provisions in the FY 2014-2015 Guidance Instructions.
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
SAPTBG shall NOT be reallocated in this Uniform Application to mental health promotion activities.
P. O. Box 92059  Atlanta, GA 30314-2059  (404) 522-9690  www.genesiscoalition.net

Ms. Summer King
SAMHSA Reports Clearance Officer
Page Two

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.
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.
GPC 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.
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.
Thank you for considering GPC’s views on the provisions in the FY 2014-2015 Guidance Instructions in
the Uniform Block Grant Application. Please feel free to contact me if you have any questions or
concerns.
Sincerely,

Gwendolyn Brown
Gwendolyn W. Brown
Chairman and CEO

P. O. Box 92059  Atlanta, GA 30314-2059  (404) 522-9690  www.genesiscoalition.net

North Coastal Prevention Coalition
Serving the communities of Carlsbad, Oceanside and Vista
National Exemplary Award for Innovative Substance

Got Outcomes! Coalition of Excellence
COALITION OF THE YEAR
Board of Directors:
President:
Aaron Byzak, Government Affairs,
UC San Diego Health Sciences
Vice President:
Fred Becker, Becker Institute
Secretary:
Ray Pearson, Carlsbad Resident
Treasurer:
Margie O’Hern, Oceanside Resident
Directors:
Nicole Pappas, Carlsbad Resident
Leonard Mata, Oceanside Police
Department
Maria Russell, Eastside Neighborhood
Association
Ray Thomson, Occupational
Health Services
Maria Yanez, Vista Community
Clinic
General Membership:
Becker Institute

September 7, 2012

Abuse Prevention Programs, Practices, & Policies

Got Outcomes! Coalition of Excellence
COALITION OF THE YEAR

Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
On behalf of the North Coastal Prevention Coalition, we appreciate the opportunity

to comment on the proposed Uniform Application for the Mental Health Block
Grant and Substance Abuse Block Grant FY 2014-2015 Application Guidance
and Instructions (OMB No. 0930–0168)—Revision, published in the Federal
Register, Volume 77, Number 135, Friday, July 13, 2012.
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 communitylevel substance abuse prevention.

Carlsbad Police Department
Carlsbad Unified School District
City of Vista/Weed & Seed Program
City of Oceanside
County of San Diego, H&HS Agency,
Alcohol and Drug Services
Drug Enforcement Administration
Eastside Neighborhood Association
Mothers Against Drunk Driving
Occupational Health Services
Oceanside Police Department
Oceanside Unified School District
San Dieguito Alliance for
Drug Free Youth
The Fellowship Center
Vista Community Clinic
Vista Unified School District
Vista Sheriff’s Department
University of CA San Diego

…and various community members

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, 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.”

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.
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 addressed “at a
minimum,” and taken out of the “encouraged to be considered” category.
Thank you for the opportunity to provide input. Please feel free to contact me if you have any questions or
concerns.

Erica Leary, MPH
Program Manager
[email protected]
760-631-5000 x7150

c/o Vista Community Clinic
1000 Vale Terrace, Vista, CA 92084
760-631-5000 Ext. 7174 Fax 760-414-3736
Website: www.northcostalpreventioncoalition.org Email: [email protected]

September 7, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
Dear Ms. King:
Community Anti-Drug Coalitions of America (CADCA), which represents more than 5,000 community
coalitions nationwide, appreciates the opportunity to comment on the proposed Uniform Application
for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015 Application Guidance
and Instructions (OMB No. 0930–0168)—Revision, published in the Federal Register, Volume 77,
Number 135, Friday, July 13, 2012.
Although CADCA fully understands 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 following specific provisions in the FY 2014-2015 Guidance Instructions.
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
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.
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.
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.
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 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.
Thank you for considering CADCA’s views on the provisions in the FY 2014-2015 Guidance Instructions in
the Uniform Block Grant Application. Please feel free to contact me if you have any questions or
concerns.
Sincerely,

Debbie Moskovitz
Project Director
Council Rock Coalition for Healthy Youth
30 N. Chancellor St.
Newtown, PA 18940
215-944-1006

VERMONT’S FEEDBACK COMMENTS ON
THE PROPOSED SAPT BLOCK GRANT APPLICATION FY14-15
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.
Vermont has the following concerns about FY14 Block Grant application revisions and subsequent
recommendations:
• 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 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 environmental factors of health reform, namely coverage for M/SUD Services,
Insurance exchanges, and program integrity.
o 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.
1

o 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.
o 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 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.
o 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.
o 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.
o Intended use has been disassociated from progress and compliance.
o The requirement for financial projections for intended use and planned expenditures for
areas of focus yet developed are very difficult to calculate reasonably.
o Technical assistance needs should focus on transitions through health reform and
support in meeting goals in the midst of significant and fast paced change.

•

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

2

Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
September 11, 2012
Dear Ms. King:
The New York State Office of Alcoholism and Substance Abuse Services (OASAS) is pleased to
be able to comment on the proposed Substance Abuse Prevention and Treatment (SAPT) Block
Grant Uniform Application FFY 2014-15 and Instructions (OMB No. 0930–0168)—Revision,
published in the Federal Register, Volume 77, Number 135, Friday, July 13, 2012. The SAPT
Block Grant is a vital safety net service for individuals with or at risk of a substance use disorder
In partnership with local, State and Federal entities, OASAS plans and monitors services
throughout New York to prevent substance abuse and/or substance use disorders and problem
gambling, provide treatment where indicated, and support the recovery of individuals, families and
communities. OASAS oversees one of the nation’s largest systems with more than 1,550 programs
in communities across the State that offer treatment to 110,000 persons in a variety of settings on
any given day.
New York has a robust Medicaid program in place, and OASAS has been using SAPTBG
funding to support substance use disorder (SUD) services for the uninsured and underinsured for
many years. New York is already working to implement provisions of the Patient Protection and
Affordable Care Act to enhance access to prevention and treatment support services for persons
with or at risk of mental and substance use disorders, and our work to identify and address gaps
in services will continue for several years. OASAS is now focusing on health care reform and
services redesign efforts, working with providers and other State agencies to: define SUD
benefits; innovate, protect, and reform the funding structures that support the SUD services
system; develop viable Health/Medical Home models that include SUD providers; develop
electronic health record and health information technology systems; and assist SUD providers in
marketing to the health insurance exchanges, insurance and managed care organizations. A
revised configuration and array of new SUD funding and service delivery approaches will be
implemented and tested over the next several years.
This year, OASAS has collaborated with the New York State Office of Mental Health (OMH) to
contract with five Regional Behavioral Health Organizations (BHO’s) throughout New York
State (NYS). The tasks of these BHO’s include:

o

Advising providers and the Offices regarding Medicaid fee-for service inpatient
behavioral health service use. For SUD providers that means:
• Concurrent reviews of admissions and continued stay in Detox programs
& Inpatient rehabilitation programs
• Monitoring of inpatient discharge planning
o Provide data and provider profiling to OASAS on SUD provider behavior.

The goals of BHO’s include saving money and assisting OASAS, OMH and the SUD field
with transition to for Phase II of this project in 2013. Phase II of this project is currently in
development and will involve fully managing all behavioral health care for Medicaid
participants. We expect to transition to the fully managed system in the next year.
OASAS has reviewed the proposed 2014/2015 SAPT Block Grant Application. There are
several areas of concern in the proposed application that we would like to comment on.

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 and reporting cycle.

Deadline for Submission:
The April 1st 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 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 noncompletion 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 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 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.
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 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.
Thank you for your consideration of these comments. Please feel free to contact me if you have
any questions.
Sincerely,

Arlene González-Sánchez
Commissioner

Association for Children’s Mental Health

September 11, 2012 

Summer King 
SAMHSA Reports Clearance Officer 
Room 2‐1057 
One Choke Cherry Road 
Rockville, Maryland  20857 

Re: Comments on the Uniform Application for the Mental Health Block Grant and Substance 
Abuse Block Grant FY 2014‐2015 Application (OMB No. 0930‐0168) 

Dear Ms. King: 

The Association for Children’s Mental Health (ACMH), Michigan’s statewide family network for 
families raising children and youth with emotional, behavioral, and mental health needs, 
appreciates the opportunity to provide suggestions for improving the Uniform Application for 
the Mental Health Block Grant and Substance Abuse Block Grant FY 2014‐2015. These 
comments are submitted in response to the Substance Abuse and Mental Health Services 
Administration’s (SAMHSA) request for comments on the Uniform Application for the Mental 
Health Block Grant and Substance Abuse Block Grant FY 2014‐ 
2015 Application Guidance and Instructions (OMB No. 0930‐0168), published in the Federal 
Register on July 13, 2012. 

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. 
  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 

Malisa Pearson
Executive Director

ACMH BOARD
OF DIRECTORS
__________________________________________________

Gail Lanphear
President
Mary McLeod
Past President
Judith Taylor, Ph.D.
Treasurer
Dalia Smith
Secretary
Joanne Riebschleger, Ph.D
Janet Davis
Anne Lange
Charle Kline

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. 
6017 W St Joe Hwy, Suite 200, Lansing MI 48917
Phone: 517-372-4016 ♦ Fax: 517-372-4032 ♦ Parent Line: 1-888-ACMHKID(226-4543)
www.acmh-mi.org

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. 

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 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 Youth‐Guided 

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 
•  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. 

We appreciate the opportunity to provide suggestions for ways to improve the Uniform Application for the Mental 
Health Block Grant and Substance Abuse Block Grant FY 2014‐2015. 

Sincerely, 

Malisa Pearson 
ACMH Executive Director 

Division of Alcoholism and Substance Abuse
100 West Randolph, Suite 5-600
Chicago, IL 60601-3224

September 11, 2012 

Ms. Summer King 
SAMHSA Reports Clearance Officer 
Room 2–1057 
1 Choke Cherry Road 
Rockville, Maryland 20857
Dear Ms. King:
Thank you for the opportunity to comment on the Proposed Project: Proposed FY 2014-2015 Block Grant
Application, Community Mental Health Services Plan and Report, Substance Abuse Prevention and Treatment
Plan and Report.
Overall, the State of Illinois agrees with the comments made by other states as summarized by NASADAD in
the attached letter. We remain concerned about additional requirements that must be supported by significant
state infrastructure improvements, such as data system enhancements that are necessary for additional reporting
requirements. Illinois continues to take steps to address many of the system changes necessary for the new
requirements. When SAMSHA makes additional changes to the application each year the focus on any one
goal is scattered and the progress diluted. The risk with adding requirements without eliminating others is that
resources are spread thin and the impact is dulled.
The new application will require training of staff and providers about the changes brought about by the
Affordable Care Act. Illinois encourages SAMHSA to provide webinars and training of the new application
prior to the new application roll out for FFY2014-2015. The due date of April 1st does not allow sufficient time
to put in place training and then to undertake an extensive planning process which is described in the proposed
application. Please consider extending the due date to September 1, 2013.
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.

Ms. Summer King
September 11, 2012
Page 2

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 may need to be included in
the Base. More consistency across state expenditures included for all states should be reviewed and updated.
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 Year July 1-June 30th. 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 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

Ms. Summer King
September 11, 2012
Page 3

Girls: Developing Core Competencies 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.
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.
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?
• 2nd sentence: There is a list of settings including substance abuse treatment centers. This example is
confusing for States. It clearly states that the 20% set-aside 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
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.
Prevention Comment to Page 15: How do the three new grants work together? No guidance is provided to
ensure for the coordination or duplication of services.

Ms. Summer King
September 11, 2012
Page 4
Prevention Comment to Page 22: Under header Primary and Behavioral Healthcare Integration Activities, 1st
dot point, 2nd paragraph: utilizing no less than 10% of grant funding. Specify the grant program – 20% set-aside
or the SABG?
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.
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.
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?
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?
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?
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.
During this comment period, a Microsoft Word document would have provided the functionality for keeping
personal notes, making annotations and more easily coping and pasting sections for internal communications
from which multiple staff could compile our responses into a single working document.
When the application and reporting documents are final, a Microsoft Word version of the document would be
useful for annotation and also for copying and pasting drafted sections into planning documents before posting
them on the BGAS system. The PDF version is difficult to work with for these purposes.
Sincerely,

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

September 11, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2—1057
One Choke Cherry Road
Rockville, MD 20857
Via email to [email protected]
Re:
Uniform Application for the Mental Health Block Grant and Substance Abuse Block
Grant FY 2014 - 2015 Application Guidance and Instructions (OMB No. 0930-0168)- Revision
Dear Ms. King:
The Trevor Project respectfully submits the following comments in response to the request for
comments concerning the proposed “Uniform Application for the Mental Health Block Grant
and Substance Abuse Block Grant FY 2014 - 2015 Application Guidance and Instructions.”
The Trevor Project is the leading national organization providing crisis intervention and suicide
prevention services to lesbian, gay, bisexual, transgender and questioning (LGBTQ) young
people under 24. Every day, The Trevor Project saves young lives through its free and
confidential lifeline, in-school workshops, educational materials, online resources and
advocacy. The proposed collection requested comment in four areas concerning the combined
application for SAMHSA state block grants; 1) whether the proposed collection of information
is necessary, 2) the accuracy of the agency’s estimate of the burden, 3) ways to enhance the
quality, utility, and clarity of the information to be collected, and 4) ways to minimize the
burden of collection. The Trevor Project believes that this data collection is certainly necessary
and well-tailored in order to allow the agency to review and assess state programs and award
block grants, and so we will limit our comments to ways to enhance the quality, utility, and
clarity of information to be collected.
Over the course of the last several years, SAMHSA has made a genuine and thorough effort
through its publications and programs to increase inclusiveness and focus on LGBTQ
populations, including LGBTQ youth. The Trevor Project applauds SAMHSA for continuing
this inclusivity throughout the proposed application in areas such as behavioral health
assessment and planning, reduction of health disparities, data collection, cultural competency,
trauma faced by young people, and mission and values with regard to subpopulations.
We know that crisis intervention, suicide prevention, and mental health are especially critical
issues for LGBTQ youth populations. Research has shown that LGB youth are 4 times more

likely, and questioning youth are 3 times more likely to attempt suicide as their straight peers.1
Young people who experience family rejection based on their sexual orientations face
especially serious health risks. In one study, lesbian, gay, and bisexual young adults who
reported higher levels of family rejection during adolescence were 8.4 times more likely to
report having attempted suicide, 5.9 times more likely to report high levels of depression, 3.4
times more likely to use illegal drugs, and 3.4 times more likely to report having engaged in
unprotected sexual intercourse compared with peers from families that reported no or low
levels of family rejection.2 We hope and believe that states will take advantage of the inclusivity
of the proposed application to create innovative and inclusive programs that will fully address
the mental health needs of this vulnerable population.
In order to increase quality, utility, and clarity of information to be collected, The Trevor
Project recommends the following:
1. Include details about existing nondiscrimination requirements for grantees. The
application should clearly define applicant’s nondiscrimination 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
2. Require certification of compliance with all applicable 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.
3. Support for stigma reduction efforts. Both LGBTQ populations generally and
individuals seeking mental health care and substance abuse treatment continue 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.
4. 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
1

Kann, L, et al. 2011. Sexual identity, sex of sexual contacts, and health‐risk behaviors among students in
grades 9‐12 – Youth Risk Behavior Surveillance, selected sites, United States, 2001‐2009. MMWR
60(SS07): 1‐133.
See Caitlyn Ryan et al, “Family Rejection as a Predictor of Negative Health Outcomes in White and
Latino Lesbian, Gay, and Bisexual Young Adults,” 123 PEDIATRICS 346 (2009).
3
Including Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq. (race, color, national origin),
Title IX of the Education Amendments of 1972, 20 U.S.C. 1681 et seq. (sex), the Age Discrimination
Act of 1975, 42 U.S.C. 6101 et seq. (age), or Section 504 of the Rehabilitation Act of 1973, 29 U.S.C.
794 (disability).
Letter from Leon Rodriguez, Director, Office for Civil Rights, to LGBT Organizations, July 12, 2012
(OCR Transaction No. 12-0008000), available at
http://www.advocate.com/politics/transgender/2012/08/06/hhs-says-antitransgender-discrimination-illegalunder-health-reform.
2

4

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.
5. 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.
The Trevor Project appreciates the opportunity to provide suggestions for improving the
Uniform Application for the Mental Health Block Grant and Substance Abuse Block Grant
FY 2014 – 2015. If you should have any questions regarding these suggestions, please contact
myself or Alison Gill, Government Affairs Director, at 202-204-4730 or by email at
[email protected].
Sincerely,

Abbe Land
Executive Director & CEO

Evelyn R. Frankford, MSW
Frankford Consulting
40 Williams St.
Brookline, Massachusetts 02446
[email protected]
www.frankfordconsulting.com
September 10, 2012
Ms. Summer King
SAMHSA Reports Clearance Officer
Room 2-1057
One Choke Cherry Road
Rockville, MD 20857
RE: Comments on SAMHSA Mental Health and Substance Abuse Block Grants FY2014-15
Dear Ms. King:
I write as a Consultant with 35 years of experience in a wide range of mental health issues, areas, and
intervention approaches. As well, I am current associated with two university research and policy action
centers (George Washington University’s Center for Health and Health Care in Schools and University of
Massachusetts Boston’s Center for Social Policy).
The following recommendations are in response to the request for comments on the Uniform
Application for the Mental Health Block Grant and Substance Abuse Block Grant FY 2014-2015 published
in the Federal Register on July 13, 2012.
As the proposed Block Grant Application notes, the advent of health reform via the Affordable Care Act
(ACA) provides important new opportunities to change states’ approaches to using Block Grant funds.
People with behavioral health conditions will have access to insurance, especially via Medicaid, and
thereby to community-based interventions and services if they are available. As well, the ACA
authorizes preventive approaches and some states, for example, Massachusetts, have already enacted
provisions to realize them. This is the context for the recommendations listed below.
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.

Recommendation Two again supports the Children’s Mental Health Network, namely that 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,
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.
Recommendation Three urges that SAMHSA take a public health approach to children’s mental health
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 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.
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.
Recommendation Four urges that SAMHSA use the Block Grant to ensure that states engage with and
promote comprehensive approaches to school-based 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, school-based 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 attention initiatives that specifically
address trauma by restructuring schools to encompass health and wellness and promote social and
emotional learning.

These are challenging fiscal times, of course, and asking states to include more stakeholders and to shift
their priorities while funds continue to decrease is a tall order.
Nevertheless, with health reform implementation, Medicaid expansion, and new benefit definitions
under Essential Health Benefits, if SAMHSA is pursuing the Block Grants as a major strategy for directing
the behavioral health system of tomorrow, leadership by SAMHSA is essential on these child and youth
policy questions.
I look forward to your response.
Sincerely,
Evelyn R. Frankford, MSW
Principal, Frankford Consulting