PAIMI PPR Table of Comments Received

Agency Information Collection Activities: Proposed Collection; Comments Request 84 Fed. Rge. 59836 (November 6, 2019)
PAIMI Summary of Comments and SAMHSA’s Responses as of 1/8/2020
Comment
Number
1

Date
Received
12/30/2019
12/30/2019
12/27/2019
12/30/2019
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01/03/2020
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01/06/2020
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01/06/2020

P&A Organizations
Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Disability Rights Texas
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Summary of Comments
Page 3, Section A, #11 – Demographic Composition of
PAIMI Governing Board, Advisory Council, and
Program Staff - The P&As recommended changing the
title to "Gender" rather than "Sex" in the demographic
question.

SAMHSA’s Response
ACCEPTED (partial): The demographic categories of "sex"
and "gender" are not interchangeable and reflect distinct
categorical values. SAMHSA has historically collected the
categorical values of "male" and "female", which do not reflect
the range of categorical values encompassed in gender.
SAMHSA does not support expanding the categorical values
needed to gather data on gender to accurately reflect the
complexity of this term. Rather, SAMHSA will continue to
require the collection of data on sex as it is collected elsewhere
in the Federal Government, specifically the U.S. Census
Bureau. However, SAMHSA will include, in addition to
"male" and "female" values, "unknown/would not disclose", to
be consistent with the data collected on "sex" among "PAIMIEligible Individuals Served". Each P&A may choose to collect
data that they consider reflects the range of gender categories
among those who are served.

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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Disability Rights Texas
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 3, Section A, #12 – List of Mental Health
Professionals on the Advisory Council - The P&As
recommended an "Other" category to be added as an
appropriate answer for other types of mental health
professionals that may serve on the PAC.

ACCEPTED (partial): SAMHSA is interested in
understanding the number and composition of the P&A
Advisory Councils with particular reference to Mental Health
professionals. At the same time, we did not include every
possible type of Mental Health professional, only those most
commonly found in mental health treatment settings. In this
way, our goal is to limit the data collection burden. However,
SAMHSA will add two additional categories based on
submitted comments, "Peer Support Specialists" and an
"Other" category, with an instruction that this category must be
used minimally.

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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 4, Section A, #15 – Governing Board
NOT ACCEPTED: SAMHSA is not currently interested in
Composition - The P&As recommended that additional collecting additional data on expanded Governing Board
membership composition.
options, beyond individuals with mental health
disabilities, be added to the question related to the
board composition to reflect individuals with diverse
disabilities.

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01/06/2020
01/06/2020

Disability Rights North Carolina
Indiana
Disability Rights
Disability
Rights Pennsylvania
Disability Rights
Oregon
Disability Rights
New York
Alabama Disabilities
Advocacy Program Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 5, Section B, #2 – Sex of PAIMI Eligible
Individuals Served - The P&As recommended changing
the titles of "Sex" to "Gender" and "Unknown/Would
Not Disclose" to "Male, Female, Not Listed, and Chose
Not To Answer".

NOT ACCEPTED: The demographic categories of "sex" and
"gender" are not interchangeable and reflect distinct
categorical values. SAMHSA has historically collected the
categorical values of "male" and "female", which do not reflect
the range of categorical values encompassed in gender.
SAMHSA is not interested in expanding the categorical values
needed to gather data on gender to accurately reflect the
complexity of this term. SAMHSA will continue to require
the collection of data on sex as it is collected elsewhere in the
Federal Government, including the U.S. Census Bureau. Each
P&A may choose to collect data that they consider reflects the
range of gender categories among those who are served.

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01/06/2020
01/06/2020
01/06/2020
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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Disability Rights Texas
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 6, Section B, #4 - PAIMI-eligible Individuals
NOT ACCEPTED: SAMHSA believes that the data point
information is important to the program. The P&A may
Served with PAIMI Program Funds - The P&As
recommended dropping the data point for the question, choose to collect demographics of the program if desired.
which ask for the number of individuals with cooccurring mental illness and intellectual and
developmental disabilities. In addition, they believe
the question would be more useful in describing the
demographics of a program than in the eligibility
section.

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01/06/2020
01/06/2020
01/06/2020
01/06/2020

Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Disability Rights Texas
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Section C (Instructions): Complaints/Problems of
PAIMI-eligible individuals - The P&As stated that they
appreciate SAMHSA considering the outcomes of the
One PPR (PPR form used by other federal agencies for
P & A grants) when constructing the outcomes of the
new PPR so that they more accurately reflect the P&A
individual and group advocacy. However, the
instructions for the abuse section on page 3 do not
reflect theses updated outcomes.

NOT ACCEPTED: SAMHSA considers the outcomes
required in Section C, columns A through F related to
allegations of Abuse, distinct from those required in Section
12, End Outcomes of P&A Activities. The outcomes in
Section C are required GPRA measures.

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01/06/2020
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01/06/2020
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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Disability Rights Texas
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Iowa
Disability Rights Maryland
National Disability Rights Network

Page 12, Section C, #8 – Intervention Strategies - The
P&As recommended that the definitions of the One
PPR and the PAIMI PPR be the same between the two
PPRs.

ACCEPTED: SAMHSA agrees that the addition of the
Intervention Strategy "negotiation" would better reflect the
activities of the P&A with regard to interventions. A definition
of "negotiation" will be added to the list of definitions in the
PPR instructions. It is: "Negotiation: Negotiation is a
problem-solving process in which two or more people
voluntarily discuss their differences and attempt to reach a
joint decision on their common concerns." The definitions for
the remaining Intervention Strategies in the PPR Instructions
already reflect those mentioned in the comments.

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01/06/2020
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01/06/2020
01/05/2020
01/06/2020
01/06/2020
01/06/2020
01/06/2020

Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 15, Section C, #11 - 5E - Interventions on behalf
of groups of PAIMI-eligible individuals - The P&As
recommended that the definitions for the group
advocacy interventions be consistent with those in the
One PPR, which more accurately reflect the work of the
P&As.

ACCEPTED: SAMHSA will change the category "Other" to
"Other Systemic Advocacy". SAMHSA's definitions currently
coincide with the comments for the following terms: Systemic
Litigation and Monitoring. SAMHSA also agrees to modify
the remaining definitions to be in line with those in the
comments.

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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 15, Section C, #12 - End Outcomes of P&A
ACCEPTED: SAMHSA concurs and will add the proposed
Activities - The P&As recommended that the outcome language, i.e. the inclusion of "…maintaining already existing
community integration" in "a" of this section.
reads "PAIMI-eligible individuals who are provided
with appropriate community-based services resulting in,
or maintaining, community integration and
independence."

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Disability Rights North Carolina
Arizona Center for Disability Law
Indiana Disability Rights
Disability Rights Pennsylvania
Disability Rights Oregon
Disability Rights New York
Alabama Disabilities Advocacy Program
Disability Rights Mississippi
Disability Rights Ohio
Disability Rights Arkansas
Disability Rights New Jersey
Disability Rights Connecticut
Oklahoma Disability Law Center, Inc.
Protection & Advocacy System for SC
Disability Rights Maryland
National Disability Rights Network

Page 21 - Section G #1 - PAIMI Personnel - The P&As
state they were unclear as to the importance for
SAMHSA to collect data on the salaries for its PAIMI
program staff. The commentors are not favor of
providing this data.

NOT ACCEPTED: SAMHSA collects data on the salaries of
the PAIMI program staff for financial accountability,
oversight, and monitoring purposes. SAMHSA also collects
the data on the salaries to ensure none of the funds provided
under the PAIMI grant awards are used to pay the salary of an
individual at a rate in excess of Level I of the Executive
Schedule, as stated and required in the Notices of Award.

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Arizona Center for Disability Law
Alabama Disabilities Advocacy Program
Disability Rights Texas
Disability Rights Iowa
National Disability Rights Network

Page 10, Section C, #5 – Areas of Alleged Rights
Violation - The P&As recommended additions,
consistent with the One PPR, to the tracking of alleged
rights violations.

NOT ACCEPTED: SAMHSA considers the list of types of
Alleged Rights Violations to be sufficient. SAMHSA also
considers "refuse to take prescribed medications" and "right to
refuse treatment" to be distinct categories. Furthermore,
SAMHSA is interested in the collection of data specific to the
rights of individuals served in general and is not collecting this
data for specific sub-populations. The P&As may, however,
choose to do so.

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01/06/2020 Disability Rights Florida

Timing of proposed changes to PAIMI PPR reporting - ACCEPTED: Once OMB approves the use of SAMHSA's
The P&A requested that final changes be announced
proposed forms, SAMHSA will distribute these immediately to
well in advance of the fiscal year for which changes
the P&A.
will be implemented.

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01/06/2020 Disability Rights Florida
01/06/2020 Disability Rights Texas

Page 13, Section C., #9 – Death Investigation Activities
- The P&As recommended retaining the reference to
and expectation that the State report to the P&A deaths
of individual in their care.
Page 5 #1. Age of PAIMI-eligible Individuals Served The P&A recommended that "Race Unknown" be
added to the selection of individual served.
Page 8 - Areas of Alleged Abuse - The P&A
recommended deleting the 1% limit just as it has been
deleted for neglect and rights. In addition, it
recommended adding additional outcomes to the abuse
disposition.

ACCEPTED: SAMHSA will include "State" as one of the
sources of death notifications.

ACCEPTED: SAMHSA will add the age category
"unknown".

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Page 10 - Neglect Complaints Disposition - The P&A
recommended adding additional outcomes to the
neglect complaints disposition.

ACCEPTED: SAMHSA will add the following disposition
categories: Lost Contact, Outcome Unknown, and Lack of
Resources.

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01/06/2020 Disability Rights Texas

Page 12 - Rights Violations Disposition - The P&A
recommended adding additional outcomes to the right
violations disposition.

ACCEPTED: SAMHSA will add the following disposition
categories: Lost Contact, Outcome Unknown, and Lack of
Resources.

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01/06/2020 Disability Rights Texas

Page 12, #7 - Reasons for Closing Individual Advocacy ACCEPTED: SAMHSA will add the following disposition
Case File - The P&A recommended adding additional categories: Lost Contact and Lack of Resources.
dispositions to the category.

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01/06/2020 Disability Rights Iowa

Page 24, Section H - Statement of Priorities (Goals) One of the P&As stated that Section A & C are
repetitive and narratives may be duplicative for case
level work. The other P&A stated that the wording of
the instructions are not clear and needs clarification
whether it should list only one exemplar case narrative
or whether it have to briefly list all of the cases under
the priority. In addition, the P&A recommended
"Partially Met" be included as an option when reporting
the outcomes of the priorities.

ACCEPTED: SAMHSA will delete the requirement that the
use of the "other" category contain less than 1% of the
responses and indicates in instructions that the P&A make
every effort to minimize the use the "other" category.
SAMHSA will also add the following disposition categories:
Lost Contact, Outcome Unknown, and Lack of Resources.

NOT ACCEPTED: SAMHSA does not consider this as
duplicative. WebBGAS automatically populates these data
fields in the PPR from data submitted in the application.
Therefore, the data is only entered one time, in the PAIMI
Application. SAMHSA will clarify in the PPR instructions
that states provide a minimum of one narrative example for
each Priority/Objective. In addition, SAMHSA only requires
that states indicate whether a priority was met or not met. It
does not include a category "partially met". The latter must
be counted as "not met". However, if the state wishes to
explain why a Priority was "partially met", they can submit a
footnote in WebBGAS.

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Page 2, #10 - Commissioner/Director of State Mental
Health Agency - The P&A recommended that the
federal citation be cited as a reminder that the P&As are
required to provide a copy of their annual PPR to the
head of their state mental health agency.

ACCEPTED: SAMHSA agrees to include the federal statute
citation as a reminder requiring the P&A to provide the annual
PPR to the head of their state mental health agency. 42 U.S.
Code Section 10805(7) states that the system established in a
State shall on January 1, 1987, and January 1 of each
succeeding year, prepare and transmit to the Secretary and the
head of the State mental health agency of the State in which
the system is located a report describing the activities ,
accomplishments, and expenditures of the system during the
most recently completed fiscal year, including a section
prepared by the advisory council that describes the activities of
the council and its assessment of the operation of the system.

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Section D. 3 - Reporting the # of Individual Receiving NOT ACCEPTED: SAMHSA does not require such
Information from Public Awareness Activities/Events - reporting, however the P&A may choose to collect such data.
The P&A recommended adding a field to allow the
reporting of the number of individuals who received
information from public awareness activities/events.