Community Behavioral Health Regulations - Second Informal Comment Period
The Behavioral Health Administration (BHA) is pleased to provide a second informal comment period for the review of proposed community behavioral health regulations, replacing certain chapters of COMAR 10.21 and 10.47. The proposed draft is the culmination of a multi-year process aimed at creating integrated regulations governing providers of behavioral health services, including new accreditation requirements.
When submitting comments, please include the regulation number as the format has changed significantly from the first informal comment period. Comments will be received through January 21, 2015, and can be sent to firstname.lastname@example.org
. Please contact Rachael Faulkner at 410-402-8402 with any questions.
Before submitting comments, please review responses from the first comment period during September 2014, as BHA will not be responding to questions and comments that have previously been responded to. Responses can be found on the Stakeholder Workgroup Website.
Selection of Workgroup Members
The Behavioral Health Integration Stakeholder Workgroup was created at the request of advocates through the passage of House Bill 1510 during the 2014 legislation session.
When workgroups, or other committees created through legislation, do not include a membership list, it is the responsibility of the staffing agency to create the workgroup membership. In selecting members, the Behavioral Health Administration (BHA) first identified the stakeholders that initially requested the workgroup during the hearings for HB 1510. Additional members that were invited to participate include representation from DHMH, treatment providers, and statewide consumer and advocacy organizations.
These members includes diverse perspectives, including the perspective of family members of those in recovery from a mental health or substance use disorder.
In addition to the organizations officially representing the perspective of family members, several DHMH members on the workgroup are themselves family members of persons in recovery.
A list of the organizations represented can be found here.
In addition, there has been, and continues to be, opportunities for public comment on every aspect of the proposed statute changes and regulations that have been discussed during the workgroup meetings. This includes twenty minutes at the end of each meeting, which is reserved for public comment from any person, physically present or by telephone, who wishes to speak.
Finally, there was an informal comment period from September 9th through October 3rd for the public to comment on the proposed BHA program regulations. This opportunity was widely publicized.
Update: Integration of Funding & Provider Payments
Throughout the Behavioral Health Integration Stakeholder Workgroup process, the Department of Health and Mental Hygiene has received questions that do not directly fall under the oversight of the Workgroup, including several inquiries related to the integration of funding and provider payments for behavioral health services. As DHMH works to further integrate the mental health and substance use disorder service systems, the Department must continue to refine the statutes for both systems through the workgroup process and new legislation; develop regulations to require accreditation for providers of behavioral health services; and embed behavioral health financing into the Medicaid portion of DHMH. In addition, the Department must implement a new Administrative Services Organization (ASO) contract, including moving the financing from the MCOs and data collection from the SMART system for substance use disorders to the new ASO.
These initiatives must be completed in the current fiscal year and require full attention from DHMH. Additionally, this work must be completed before DHMH can begin working on the integration of specific types of services, each of which will require a review of licensing and program requirements; a rate review and revision; a state plan amendment; approval from CMS; and may require additional funding to be identified before proceeding.
In the meantime, please be patient with DHMH as the Department works to make the changes currently underway.