The cessation of funding new cooperative agreements and the rollout of the System of Care Expansion RFA suggest that there is definite movement toward merging the CMHI program with the Substance Abuse Block Grant (SABG) and the Community Mental Health Block Grant (MHBG). The problem with mergers is that while they are promoted as combining the best of both, in most cases that is not what happens. Those who do the absorbing end up deciding on what elements stay and what elements go. Make no mistake – the CMHI program is the one being absorbed. It is critically important that over 25 years of developing and demonstrating the system of care approach and its ability to meet the needs of children, youth and families not be lost in this merger.
Please note that public comment is now closed. However, check back frequently for updates on any changes made as a result of the many letters sent in by supporters of the Children's Mental Health Network.
Listed below are some key talking points and specific recommendations, as well as a sample comment letter that was available to people wanting to comment.
Your voice really does count. Let’s not let the hard work of providers, families and youth over the past 25 years get lost in “merger mania.”
- The critical importance of focusing on the behavioral health needs of children, adolescents and young adults and their families needs much stronger emphasis.
- SAMHSA has recognized that results from the CMHI program have demonstrated the success of a System of Care approach. We know through evidence that multiple community-based services and supports working together in partnership with youth and families results in improvement in youth attendance, performance and progress in school and emotional and behavioral gains.
- Indications that the System of Care Expansion RFA is SAMHSA’s first step towards elimination of the CMHI program and merger with the Substance Abuse Block Grant (SABG) and Community Mental Health Block Grant (MHBG) programs. This will require change in legislation. We will watch with keen interest as SAMHSA clarifies the direction it will take and will stay vocal about incorporating the key elements of a System of Care approach.
- Without a clear directive from SAMHSA to continue the work of Systems of Care for children, youth and families, there is a risk that states and communities will not invest the necessary resources to continue to grow and sustain their System of Care development efforts, ultimately undermining almost two decades of hard work and accomplishments.
- Provide additional language highlighting the System of Care approach as a best practice in serving children and youth with mental health and/or substance abuse needs and their families.
- Ensure that a certain minimum percentage of MHSBG and SAPTBG dollars be allocated to children and youth with mental health and/or substance abuse needs and their families.
- Include specific requirements on service provision for children and youth with mental health and/or substance abuse needs and their families within the Unified Application, and develop a technical assistance unit with expertise on the needs of and best practice approaches to serving children and youth with behavioral health needs and their families to ensure compliance and share expertise at both state- and federal-level planning efforts.
- Strengthen requirements that states explore technical assistance needs to effectively serve the populations required to be included in the needs assessment, including children with Serious Emotional Disturbance and their families.
- Through all of SAMHSA’s grants and, in particular, the Unified Application, SAMHSA has an opportunity to model the best components of a systems of care approach for the States, through coordinated and targeted technical assistance and support that would ensure that the behavioral health needs of children, youth and families are met.
- View the Unified Application as an opportunity for collaboration, coordination, and leveraging. Without implementation of the recommendations outlined above, the Unified Application may result in the pitting of the “adult system” against the “child system,” and the wasted effort of individuals trying to identify “what works” when we know that a System of Care framework is intuitive, tested, and accessible for families, providers and communities.