On behalf of the membership of the Association for Behavioral Healthcare (ABH), formerly Mental Health and Substance Abuse Corporations of Massachusetts, thank you for the opportunity to comment on the FY 2011 budget. As you know, ABH is a statewide association representing ninety-one community-based mental health and substance abuse provider organizations. Our members are the primary providers of publicly-funded behavioral healthcare services in the Commonwealth, serving approximately 117,000 Massachusetts residents daily and employing 22,000 people.
While we realize that you will be faced with many difficult decisions in the coming weeks and months, we strongly urge you to hold community-based mental health and substance use disorder services harmless from further cuts.
STABILITY FOR COMMUNITY SERVICES
Lack of access to critical health care services remains a significant barrier to preventing and treating health disorders before they intensify and require costlier treatment in more intensive settings. ABH providers know from experience that access barriers to community-based mental health and substance use disorder services can be debilitating or even fatal.
While we have been encouraged by the Legislature’s recognition of the importance of community mental health and substance use disorder services, the community behavioral healthcare system has not yet recovered from the budget cuts of a few years ago, not to mention the mid-year cuts sustained in FY 2009. Thousands of individuals and families are not able to access services and supports for mental health and/or substance use disorders. In light of this unacceptable situation, current levels of services must be maintained in order to ensure that individuals are able to access needed care and to provide stability for the community behavioral health system.
DEPARTMENT OF MENTAL HEALTH
The Department of Mental Health has cut funding for community based services by over $10 million during the current fiscal year, including the elimination of two Programs for Assertive Community Treatment (PACT) teams and a reduction of over $8 million in funding for Community Based Flexible Supports (CBFS) through the Department’s reprocurement process. Adequate funding is absolutely essential in order to ensure access to appropriate community services for clients who are being discharged from Westborough State Hospital and the inpatient unit at Quincy Mental Health Center and for the system to adjust to the new community based system of care (Community Based Flexible Supports). Therefore, preservation of funding for the Department of Mental Health (DMH) is essential in order to maintain treatment for individuals across the Commonwealth in need of mental health services. DMH offers individuals with mental illness many critical community-based services that are not available through MassHealth or private insurance, including CBFS, Clubhouses, PACT, and Respite.
We urge you to maintain funding for the DMH community accounts (line items 5042-5000; 5046-0000; 5046-2000; 5047-0001; and 5055-0000) in order to avoid a shift toward more expensive interventions such as emergency rooms, acute inpatient care and homeless shelters. In addition to maintaining existing services, additional funding for community based services will be required if the Department proceeds with further reductions to DMH inpatient capacity. According to the final report of the DMH Inpatient Study Commission, The community system must be strengthened. Community based services have been the heart of the DMH service delivery system for more than 30 years. Previous state hospital closings have succeeded as consumers were transitioned to high-quality services in or near their own communities. The community system, however, experienced significant mid-year “9C” budget cuts in October 2008. An investment of funding for community services is necessary for DMH to replicate the success of earlier hospital closings.1 Individuals affected by this will require intensive care if they are to be served in community settings. Currently, the community system does not have sufficient funding and resources to serve these individuals. Funding for community services must be increased dramatically to meet the needs of DMH clients who may be moved from hospitals to community settings in fiscal year 2011.
BUREAU OF SUBSTANCE ABUSE SERVICES The passage of the alcohol sales tax demonstrated a spirit of collaboration between the Legislature, the Administration and all citizens to use these new revenues to preserve funding for substance use disorder services and to retain access to treatment. We ask that the Legislature hold true to the intent of that legislation, and keep faith with the spirit of the initial proposal by dedicating the revenues to a Substance Abuse Health Protection Fund to provide funding or supplement existing funding for a comprehensive continuum of substance abuse care. The need for such a fund has become even more urgent given that the initiative petition to repeal the sales tax on alcohol has received enough signatures to appear on the November 2010 ballot.
Furthermore, we strongly urge you to preserve existing funding for the DPH/Bureau of Substance Abuse Services (line items 4512-0200, 4512-0201, 4512-0202, and 4512-0203). As it stands now, the demand for substance use disorder treatment exceeds capacity and during difficult economic times, demand for treatment increases. In times such as these, it becomes even more essential to protect substance use disorder treatment and services. When funding for treatment is cut, access to treatment is reduced, and the state will end up paying more to serve these clients in emergency rooms, our court system and prison beds.
MASSHEALTH BEHAVIORAL HEALTH
As you know, Medicaid finances medically necessary behavioral health services for individuals and families and helps ensure stability for some of the most vulnerable individuals in our society. For example, MassHealth psychiatric day treatment services provide essential services for individuals being discharged from state hospitals and help ensure that individuals are able to remain in their communities. In addition, MassHealth behavioral health services also include vital substance use disorder services for individuals across the Commonwealth.
As you know, service implementation for the Children’s Behavioral Health Initiative (CBHI) is underway. As the state continues to work to develop this new system, funding is necessary to ensure successful implementation of the Rosie D. court order. This funding is essential to strengthen our community-based mental health system to better serve children living with Severe Emotional Disturbance (SED) in Massachusetts.
Furthermore, behavioral health services must continue to be exempt from MassHealth co-payments. We are concerned that increased cost-sharing will limit access to care. While this issue affects all individuals with significant healthcare needs, it is particularly burdensome for those with behavioral health needs because treatment is often necessary several times per week, as is the case with medication management in conjunction with therapy services, or even daily, as is the case with methadone maintenance treatment. MassHealth outpatient services will be one of the core services for CBHI and co-payments will serve as an additional barrier to treatment. In addition, children’s services routinely involve multiple family members in successive visits, and multiple co-payments can be an insurmountable economic burden for some families. If cost-sharing becomes a major obstacle, individuals will be forced to wait until the illness is more acute, resulting in increased use of higher, costlier levels of care. High out-of-pocket costs will only serve to prevent necessary treatment and exacerbate the stigma faced by individuals with behavioral health disorders.
MassHealth behavioral health services do more than keep ill people off the streets; they keep people alive. As such, the Commonwealth must take steps to ensure that these valuable services continue to be available to the state’s residents.
IMPLEMENTATION OF CHAPTER 257 OF THE ACTS OF 2008
Chapter 257 of the Acts of 2008 (formerly S. 2764) must be adequately funded. At a minimum, we ask that you include a reserve account to fund potential rate increases for the portion of the purchase of service system whose rates must be adjusted by October 1, 2010. Adequately funding Chapter 257 must be a priority and is essential in order to address currently underfunded existing contracts and improve the precarious condition of many provider organizations.
Human Services Salary Reserve
While we recognize that implementation of Chapter 257 will, over time, rectify the fact that human service employees are too often among the Commonwealth’s working poor who struggle to meet basic needs; we are asking you to level-fund the salary reserve at $28 million until the new law is fully implemented. This is a modest request to assist direct support staff making less than $40,000 per year as they struggle with the condition of our state’s economy.
If you have any questions or comments, I am happy to address them at your convenience. Thank you for your consideration.
On the Issues, People & Organizations in Behavioral Health in the Commonwealth
No comments:
Post a Comment