I am writing today to express my strong opposition to the proposed redesign by the Department of Medical Assistance Services (DMAS). While I understand the intent may be to improve efficiency, the result will be a harmful reduction in access to essential care — particularly for our most vulnerable populations.

This redesign will limit individuals' access to timely and consistent care, which directly decreases services that help prevent hospitalizations, mental health crises, and community destabilization. When people are unable to get the support they need, they are more likely to end up in emergency rooms, psychiatric facilities, or worse — in jail. Destabilizing those already struggling in the community doesn’t just harm individuals — it endangers public health and safety.

This is especially dangerous for those living with Serious Mental Illness (SMI). SMI cannot be cured — only managed. The better it's managed, the more likely a person is to be a healthy, stable, and contributing member of society. The redesign appears to overlook this basic reality. It will also further marginalize individuals dealing with both SMI and co-occurring substance use disorders, a population already at high risk of poor outcomes and recidivism. Denying or complicating treatment access for this group will cost the state more in the long term through increased incarceration, hospital stays, and reliance on emergency services.

Children and youth are also at risk. Programs like Therapeutic Day Treatment (TDT) and Intensive In-Home (IIH) provide vital early intervention. Removing or restricting access to these services during key developmental stages will reduce the number of young people who grow into stable, productive adults. Even more troubling, it may perpetuate cycles of trauma, especially in marginalized communities where intergenerational trauma is already prevalent.

Furthermore, the new regulations will overwhelm providers with unrealistic documentation and procedural burdens, leaving less time for meaningful, therapeutic interaction. Those of us in the helping profession need to be allowed and able to commit the time to the individual receiving services face to face in order for the benefits described above. Per the new proposed guidelines, caseloads per worker and number of hours seen per client would be limited-unreasonable and excessive documentation and further red tape to access the needed services for each individual, would further hinder what helping professionals can feasibly accomplish and contribute to higher burnout rate, further reducing access to care.

Not a single one of us is free of the impact of mental health treatment being a necessity, whether it be for ourselves or a family member, and acknowledging they need the help to begin with, as so many are resistant to admitting. Where will you turn or tell your family with only public insurance to turn when they finally seek support?

A redesign of this magnitude should be built on transparent and inclusive dialogue with all impacted stakeholders — including Medicaid recipients, providers, advocates, and community-based organizations. Unfortunately, the current process has lacked meaningful stakeholder input, particularly from those most directly affected.

There is reason to believe that the redesign could disproportionately affect marginalized communities — including low-income individuals, people with disabilities, and communities of color. Any policy shift must include a comprehensive equity impact analysis, which appears to be lacking or insufficiently disclosed.

Instead of reducing complexity, the proposed changes may increase the administrative burden on providers and case managers, leading to delays in service delivery and higher levels of provider burnout. Many agencies are already strained — adding new layers of bureaucracy may only exacerbate workforce shortages.

It remains unclear what empirical evidence DMAS is using to justify the redesign. Without transparent data showing that the proposed changes will result in measurable improvements — and not simply cost shifts or reductions — this change appears to do more harm than good.

I urge DMAS to re-evaluate the implementation of this redesign. It threatens to reverse progress made in behavioral health and community-based care. Instead invite real input from those most affected — individuals with lived experience, families, providers, and advocates. We need reforms that strengthen services, not tear down what little support is left.  

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