North
			Carolina Division of Mental Health, Developmental Disabilities and
			Substance Abuse Services 
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			Staff
			Training:
			The revision is to add to the Budget Section to collect
			information about the number of trainings provided by PATH funded
			staff. The question about training had been removed as it really
			is not in line with what PATH staff do. The intensity it takes to
			work with individuals literally homeless with serious mental
			illness to connect to all the needed services, placed in supported
			housing and connected to mental health services prevents time for
			PATH staff to train. I understand that some states may do this,
			but it is not connected to reach the outcome of living in
			supported housing and transitioned to community mental health
			services. I recommend this be an optional question so as not to
			have it appear that this is a major role for PATH funded staff. 
			I
			want to extend a huge thank you for removing the data collection
			under services, referrals and demographics. 
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			An
			issue is raised related to the addition of staff training and one
			recommendation is offered. 
			
				Respondent
				reports that training the community is not the primary objective
				of many PATH programs and is not connected to the PATH program’s
				intended outcomes of connecting individuals to housing and
				community mental health services. 
				Respondent
				offered a recommendation to make tracking staff-funded training
				optional for all PATH programs. 
			 
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			SAMHSA
			offers the following responses to the concerns and recommendations
			raised by the respondent: 
			
				Providing
				training to community support networks is included in the PATH
				legislation as an appropriate use of PATH funds. While this
				service is not required of PATH programs, it is important to
				track the activities of providers that train others in their
				community. Though not directly related to PATH-funded services,
				staff training indirectly serves and improves the community’s
				homeless services system by providing information about working
				with individuals who have a serious mental illness and improving
				services to the PATH target population. 
				Information
				has been added to the proposed PATH Annual Report Manual to
				provide additional clarification on this data element. The PATH
				Annual Report Manual will reflect that PATH providers are not
				required to provide this service. However, if the service is
				provided, the collection and reporting of this service is
				required. Making the element optional will not allow for
				meaningful data to be collected. 
			 
			SAMHSA
			will allow the recording of this data element to be optional for
			the initial year of its implementation to allow providers of this
			service to put a mechanism in place to accurately track the
			information. Community training provided by PATH staff will remain
			an optional service while the recording of such activity will be
			required after the initial year. 
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			New
			York State Office of Mental Health 
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			Staff
			Training
			– an element has been added to collect info on the # of
			trainings provided by PATH-funded staff. In NY, our PATH funds are
			used primarily for support services, with some funds going towards
			training. I would not like to see SAMHSA’s efforts in this
			area make our PATH service providers feel they need to shift some
			of their resources to training. 
			#
			8 – Demographics, 1st
			paragraph last sentence—an element has been added to report
			on the # of clients connected to their benefits using the SAMHSA
			funded SOAR model. In NY, SOAR is utilized but so are many other
			models to connect folks to SSI, etc. I would not like to see PATH
			sponsors feel they are limited to SOAR only. In fact, I have just
			learned from the SOAR TA Center that in NY, regional in person
			SOAR trainings will no longer be available. All available SOAR
			training will only be accessed thru the SOAR website. 
			Lastly,
			the estimated annual burden table on the bottom of the page is not
			clear. If it is suggested that OMH and the local providers spend @
			20 hours on annual reporting for PATH, that is inaccurate. The
			annual report process is time consuming and takes weeks to
			accomplish. 
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			The
			respondent raised four issues regarding the new report form. The
			issues include: 
			
				Training
				the community is not the primary objective of many PATH programs
				and is not something that is often provided in New York. 
				Focusing
				on PATH-funded community training may pressure projects to divert
				resources from working with individuals in need to providing
				training to communities. 
				The
				respondent is concerned that PATH providers will feel they are
				limited to SSI/SSDI Outreach, Access, and Recovery (SOAR)
				programs when seeking to connect individuals with Supplemental
				Security Income (SSI)/Social Security Disability Insurance (SSDI)
				benefits. New York uses other models in addition to SOAR to
				connect individuals to SSI/SSDI benefits. 
				The
				respondent is concerned that providers and State PATH Contacts
				(SPCs) spend much more than 20 hours when completing the PATH
				Annual Report. 
			 
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			SAMHSA
			offers the following responses to the concerns raised by the
			respondent: 
			
				Providing
				training to community support networks is included in the PATH
				legislation as an appropriate use of PATH funds. While this
				service is not required of PATH programs, it is important to
				track the activities of providers that train others in their
				community. 
				Information
				has been added to the proposed PATH Annual Report Manual to
				provide additional clarification on this data element. The PATH
				Annual Report Manual will reflect that PATH providers are not
				required to provide this service. However, if the service is
				provided, then the collection and reporting of this service is
				required. 
				Information
				has been added to the proposed PATH Annual Report Manual to
				provide additional clarification on this data element. In the
				“Outcomes” section, the new report form proposes to
				collect information on all connections to SSI/SSDI regardless of
				the model used. The SOAR-specific data element is intended to
				determine the extent to which PATH is connected to SOAR and is
				not intended to limit PATH to only using the SOAR model. 
				The
				burden estimate is intended to reflect the time required for
				states/territories and providers to complete the PATH Annual
				Report form itself. If providers are consistently collecting
				accurate data throughout the year, it is estimated that the
				burden would be 20 hours for each provider agency and 20 hours
				for each state/territory. These estimates were based on feedback
				from providers and states regarding the burden associated with
				the PATH Annual Report. 
			 
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