ACT Should be an essential Medicaid Mental health Service -- Let's start funding it like that

Not everyone with a mental illness wants or needs Assertive Community Treatment, but for some people it is going to be the difference between jail, prison, or homelessness and a viable life in the community.  It could not be more important that this evidence-based practice is available to all where reasonably medically necessary, not only from a legal standpoint of Olmstead and Parity Compliance, but from a basic human rights perspective.     ---Orchid

Comments are limited to Capitated Behavioral Health Benefit.

 The 1915(b)(3) Non-Medicaid Services waiver to help fund essential mental health services such as assertive community treatment seems highly inappropriate possibly for other services as well such as supported employment.
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​These are not services that should be Non-Medicaid Services and in fact in many States they are Medicaid services and are funded under various different programs such as rehabilitation.  The Journal of Social Work and Disability Rehabilitation categorizes Assertive Community Treatment as a mental health long term care service (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4334111/ ) .

Of course, the problem has been that so many states such as Colorado have NOT adequately funded intensive mental health and rehabilitative services for all who need them and qualify as they would for people with physical disabilities.

​"For several reasons including the failures of de-institutionalization, the inadequacy of community resources, and poor coordination among service agencies, the needs of people with long-term mental illness living in the community have not been adequately met.

"Yet recent changes in the mental health care treatment system have sustained the shift in the locus of mental health care from inpatient settings to the community."

                        ---"Assertive Community Treatment of the Long Term Mentally Ill," Journal of the American Psychiatric Nurses Association (1997).
 http://www.sciencedirect.com/science/article/pii/S1078390397900446

         The article quoted above was written 20 years ago, and is largely still relevant today.  ACT is not some experimental treatment  it is an evidence-based practice endorsed by SAMHSA (the Substance Abuse Mental Health Services Administration).

Further, while the State is now talking about some type of “comprehensive” Statewide Behavioral Healthcare Plan – we still haven’t heard anything after almost a year and a half of asking about a waitlist  for ACT or bringing to scale to meet the need for assertive community treatment.  

​State you’ve got the soaring rhetoric – but you’re going to have to match it with the transparency, accountability, and responsiveness that you keep touting but often find hard to make good on.

The Medicaid deadline for parity is coming Sept. 30, 2017 and this certainly doesn’t meet parity.

After all this time, this draft plan is not only not okay it is scary for people with serious mental health needs in Colorado. 

So what are the main points:​

  • ​There is the grand sweep of Olmstead Compliance that the State is broadly indicating it is willing to address through: 
    • An Olmstead Compliance Working Group; and
    • A Comprehensive Behavioral Health Care Plan
    • [Of course, the State has indicated they have no idea when they will be able to get us any specifics]
    • But we are still grateful in our snarky way because this is the most responsiveness we have had after 2 years of trying AND in fairness it could be a fair amount of responsiveness. [We have still got AdSeg in County Jails to get to, etc]
  • The State now asked for comments due today Friday, Jan. 13, 2017 on the Accountable Care Collaborative.  We are only commenting on the Capitated Mental Health Benefit and on that, limiting our comments largely to our concerns regarding Assertive Community Treatment since we have been pretty vocal about this for some time.
  • The point really isn't how the State funds ACT -- the point is that it funds it to meet the need which it isn't doing.
  •  WE SHOULD NOT HAVE TO WAIT FOR THE STATE TO GET  THESE VARIOUS INITIATIVES UNDER WAY FOR HCPF TO START  ADDRESSING THIS TO COMPLY WITH BOTH OLMSTEAD & PARITY!
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