Earlier this month, the Substance Abuse and Mental Health Services Administration (SAMHSA) announced that the agency’s draft Strategic Plan is now open for public comment. Most of Mississippi’s federal money for mental health and substance use services comes from SAMHSA.
The five priority areas on the plan are:
- Preventing Overdose
- Enhancing Access to Suicide Prevention and Crisis Care
- Promoting Resilience and Emotional Health for Children, Youth and Families
- Integrating Behavioral and Physical Health Care
- Strengthening the Behavioral Health Workforce
Comments on the draft 2023-2026 SAMHSA Strategic Plan will be accepted now through 5 p.m. ET on April 27, 2023. For more information on the draft plan and to submit comments, please visit the Strategic Plan webpage on SAMHSA’s website. Anyone can submit comments on the plan. Remember: You know something no one else knows. You know what your family has experienced and what has been most helpful to you. Sharing your ideas could make a difference for many families.
These are Families as Allies’ initial draft comments on the plan.
General comments about the plan:
- In the discussion of equity and throughout the plan, place more emphasis on state behavioral health systems complying with the Americans with Disabilities Act and the Olmstead decision and not discriminating against people with disabilities and state this is an expectation of SAMHSA. The ADA and the Olmstead decision are in jeopardy for all people with disabilities due to at least one state’s response to a pending federal lawsuit related to mental health. This response does not seem to align with SAMHSA’s mission to “foster recovery while ensuring equitable access and better outcomes.”
- Add strategies that ensure states and local entities meaningfully collaborate with peer and family-run organizations (such as chapters of the National Federation of Families and local peer associations), SAMHSA-funded statewide family and consumer-run organizations and SAMHSA-funded joint behavioral planning councils in any efforts involving SAMHSA funding.
- Throughout every section, stress the relationship between state planning councils and peer and family-run groups, verifying that meaningful collaboration occurs from the initial stages of applying for funding through all stages of implementation and evaluation and SAMHSA’s consideration of initial and ongoing funding to states and related entities.
- The emphasis on peer support throughout the plan is very good, but language needs to be added to ensure that peers lead efforts to define and implement peer support. Even when well-intentioned, state-led efforts can intimidate peers, limit perspectives, and perpetuate system-driven practices.
Priority One: Preventing Overdose
- SAMHSA-funded statewide family and consumer-run networks already do the coordinating/networking this section describes. Add language throughout this section to leverage this work, consider enhancing it, and ensure any new funding proposals coordinate with these groups.
- Statewide Family Networks and National Federation of Families chapters already have the values and engage in the activities outlined in the National Strategy to Support Family Caregivers. Because these groups have lived experience, they are person-centered with families, know the systems and rights involved and can help families navigate complex systems and issues. Add language indicating this and urge collaboration with these groups in Objective 2.3.
Priority Two: Enhancing Access to Suicide Prevention and Crisis Care
- In Objective 1.1, specifically list SAMHSA-funded statewide family and consumer-run networks and National Federation of Families chapters as potential community gatekeepers in suicide prevention and crisis intervention.
- Increase the emphasis on people with lived experience and the groups composed of them in objective 2.1.
Priority Three: Promoting Resilience and Emotional Health for Children, Youth and Families
- Add partnerships with the SAMHSA-funded Statewide Family Networks, the National Federation of Families and the National Family Support Technical Assistance Center throughout this section. These groups already support tens of thousands of families nationwide effectively and culturally responsively.
- Statewide Family Networks and Federation chapters help families negotiate across education, child welfare, juvenile justice, primary care and crisis systems. The plan needs to recognize this and leverage these efforts.
- CMHI projects sometimes appear to be focused on primarily adding services and activities for a period of time without changing the nature of partnerships with families and youth or meaningfully building/reforming the system of care. Clarify the initiative’s purpose and stress that meaningful partnerships with families, youth and the organizations representing them in all design, implementation and evaluation aspects are essential.
- Stress that SAMHSA expects states and other government entities to partner with family and youth-run organizations to develop CMHI proposals, and SAMHSA expects government entities to follow through with including and funding family and youth organizations as written.
- In objective 2, include High Fidelity Wraparound as an evidence-based practice.
- The plan should prioritize families and youth being involved in all aspects of evaluation to ensure that services are effective and are delivered with fidelity to evidence-based protocols.
- Add an objective to make technical assistance on family-driven practice and parent peer support available through Statewide Family networks and the Family-run TA centers.
- Discourage the creation of new task forces and advisory groups based on system and provider concepts of partnerships with peers and families. Instead, emphasize that state and local entities partner with the existing peer and family-run groups and networks and learn about these groups from these groups.
Priority Four: Integrating Behavioral and Physical Health Care
- Certified Community Behavioral Health Centers (CCBHC) represent a very promising model, but only if they are implemented in true partnership with service recipients and their families and result in system improvement. Add language urging collaboration with family and peer-run organizations, especially those funded by SAMHSA, to ensure CCBHCs are patient and family-centered, and that peer support for all populations is designed and implemented in a peer and family-led manner.
- Urge that peers and families and SAMHSA-funded family and consumer networks are integrated into all evaluation processes for CCBHCs.
- Encourage that care coordination for children with significant needs to be delivered via high-fidelity wraparound in CCBHCs.
Priority Five: Strengthening the Behavioral Health Workforce
- In objective 1.3, add that SAMHSA will collaborate with SAMHSA-funded statewide family and consumer networks to the already existing objective “SAMHSA will work with stakeholders to educate them on what peer support providers and paraprofessionals are doing across the nation to help address the acute need for behavioral health care.”
- Involve families and family-run organizations in objective 2.2.
- In objective 2.3 – Using national training with objective standards is excellent.
- Include family-run organizations in objective 2.4.
If you have feedback about our comments, please let us know. You can contact Joy Hogge at 601-355-0915 or jhogge@faams.org.
