There are several concerns with these proposed changes. While this plan may be intended to enhance service quality and accountability, the speedy rollout of such a complex system will not have the intended results. Ultimately, the limitations on these services will result in many individuals losing services that help keep them stable in the community. Making these significant changes within the proposed time frame will leave many individuals without an option when their services are limited or pulled away due to these new requirements. 

For example, the proposed changes to psychosocial rehabilitation will result in many people who currently attend this program having no place to go during the day. The CPST rates and limits for psychosocial rehabilitation are not remotely feasible for the level of need that is out there. While the Clubhouse Model is suggested as an alternative, (although the rates are still abysmal), this takes time to develop, and there is only one currently operating in the State which took years to get off the ground. As CSBs are working to support more and more individuals with mental illness who are unhoused or who lack natural supports, I fear that changing this program will further add to this challenge. There was no requirement in the budget language to change psychosocial rehabilitation. This needs to be reconsidered as it will have deeply detrimental effects to the people who are served. In the meantime, we should be allowed to continue serving those who need this service as it provides stability and support to many people who have little or no natural support. As we have enhanced our crisis system, limiting access to programs like this which help keep people stable and out of crisis can negatively impact the work that has been done to build a more robust crisis response system. It takes all of these programs to provide our citizens with the best possible care. 

The requirement for licensed and license-eligible staff is a significant concern in a system that is already taxed to meet the current need. The requirement for accreditation will likely impact private providers, further limiting the availability of services. This will create a higher demand for CSBs as some of the private providers will be unable to sustain in this new environment. Furthermore, a two-year timeline to attain accreditation is probably not realistic. Any proposed changes to services should be based on what is going on in the current environment, as much of what is being proposed appears to be based on an ideal system in which there is adequate staffing and predictable timelines for processes such as accreditation.

While we understand and respect the need for accountability, to make significant changes across multiple services in a compressed timeframe will not result in the quality of services that is intended and will likely have the opposite effect. It will likely result in people losing services and businesses not being able to withstand. The environment has also shifted over the past year with the upcoming changes to Medicaid requirements which will further compound these issues. I fear that making all of these changes in a short window of time will upend the system that is intended to meet the needs of our most vulnerable citizens. I hope that this can be approached in a more strategic manner with changes occurring over an adequate length of time and with clear plans that do not harm those who depend on us to make the best decisions about their care.