Justification

The National Mental Health Services Survey (N-MHSS) (OMB No. 0930-0119, expires
02/28/2017) was approved on November 25, 2013. In March 2015, the White House’s Office of
Digital Strategy and Google expressed interest in helping the public find substance use and
mental health treatment providers by expanding the availability of and access to SAMHSA's
Behavioral Health Treatment Services Locator (https:// findtreatment.samhsa.gov). Google is
currently launching a new search feature that could provide enhanced search results for the user
(akin to how searching for a movie or a restaurant yields a map and results in the vicinity). For
this purpose, Google will use SAMHSA's API (application programmer interface) to pull
treatment facility data directly from the Locator database and render as Google search results.
The National Mental Health Services Survey (N-MHSS) is one of the surveys that feed facility
data into the Locator. As this project moved forward, SAMHSA had concerns about whether the
N-MHSS informed consent language around data use covered the situation where facility data
would be shared directly with a commercial entity.
SAMHSA had HHS OGC review the informed consent language provided in the N-MHSS
questionnaire. OGC rendered an opinion that the informed consent language that covered data
sharing with “other publically available listings” was not inclusive of Google or other
commercial entities. OGC recommended that SAMHSA give notice to facilities that their
Locator information may be shared with a commercial entity such as Google.
Action Taken: When OGC’s recommendation came to SAMHSA, there was exactly one week
before the 2016 National Survey of Substance Abuse Treatment Services (N-SSATS) (OMB No.
0930-0106, expires 12/31/2018), a sister survey of the 2016 N-MHSS, was scheduled to start
data collection. CBHSQ had little time to meet the desires of the White House for sharing data
with Google and making a good faith effort to notify facilities that their data would soon be
shared with a commercial entity. After internal discussion and weighing options on how to
notify facilities in the most expeditious manner while implementing the recommendations of
OGC, two actions were undertaken:
(1) A survey question was added to the 2016 N-MHSS questionnaire. This question permits
the facility to express permission for basic facility contact information to be shared with
large commercially available Internet search engines such as Google; and
(2) A notification flyer was added to the survey mailing packet about the change in data
sharing policy.
These changes to the N-MHSS were made to be consistent with the N-SSATS operations. The
question that was added to the N-MHSS questionnaire is:

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C1a. To increase public awareness of behavioral health services, SAMHSA may be sharing
facility contact information with large commercially available Internet search engines, such as
Google, Bing, Yahoo!, etc. Do you want your facility information shared on these Internet
search engines?
•

Information to be shared would be: facility name, location address, telephone number,
and website address.
□
□

Yes
No

Because of time constraints in making this decision, and (1) having adequate time so that the
new question C1a could be programmed into the web survey instrument and (2) getting the
notification flyer inserted into the mailing of the 2016 N-MHSS survey packets, SAMHSA
neglected to contact OMB for emergency approval of these two actions.

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