The Substance Abuse and Mental Health Services Administration (SAMHSA) has recently proposed regulations that would create new Performance Partnership Grant programs to replace the existing Community Mental Health Services and Substance Abuse Prevention and Treatment Block Grants. The goal of the proposal is to change the relationship between the federal and state governments and to refocus the block grants from state expenditure reports with accountability based on documentation of compliance to reliance on evidence of performance. According to SAMHSA Administrator Charles Curie, no changes are proposed for either funding eligibility or for the formula to distribute the funds. The proposal reflects SAMHSA's collaboration with state program directors of mental health and substance abuse services.

Since this new SAMHSA initiative may be of interest to you, we wanted to give you the opportunity to provide feedback on the proposed changes. The SAMHSA request for comments, with links to the Federal Register announcements for each of the new block grants, is available on SAMHSA's Web site, http://www.samhsa.gov [Click on "Hot Topics" and then on "Comments on Performance Partnership Plan."] In addition, SAMHSA has provided an outline for providing comments, which is attached to the bottom of this note.

We, in APA's Public Policy Office, welcome your observations on the proposed changes and ask that you submit your comments directly to us. We will gather all the comments received and compose an official response from APA to SAMHSA that reflects the thoughts of our membership. Please forward your comments by February 13, 2003, to Denis Nissim-Sabat, Ph.D., Senior Policy Analyst . We will be happy to provide you with a copy of our APA response. You may also wish to submit your own letter to SAMHSA, as well.

QUESTIONS PROPOSED BY SAMHSA TO CONSIDER IN OFFERING COMMENTS

In General

1. Please comment, if you care to, in general about the benefits and challenges of converting to performance partnerships. What areas of greater flexibility are needed in the administration of the Community Mental Health Services Block Grant and what measures of accountability are needed in the performance of the program and for the overall community based system of care?

2. Please comment, if you care to, on the use of a "continuous quality improvement" model instead of a penalty structure?

Operationalization

1. Please comment, if you care to, about the continuation of the flexibility in the use of funds under the program for carrying out the mental health plan, to evaluate programs and to plan and administer the program.

2. SAMHSA is proposing new elements for the mental health plan. Please comment, if you care to, about those elements and make recommendations for their improvement.

3. SAMHSA proposes to maintain the current restrictions on the use of funds as are in current statute. Please comment, if you care to, on both the proposal and the value of the restrictions themselves.

4. SAMHSA is proposing to retain the set aside for children's services but is simplifying it to ensure that States maintain their level of support for children with serious emotional disturbance at a level equal to the average expenditures of the previous 2 years. Please comment, if you care to, on retaining the provisions and the change in the maintenance of effort requirement on children's services.

5. States would be required to submit yearly reports showing their progress in meeting their objectives under the program. SAMHSA would then use this information to create a report for Congress to demonstrate how each State is using the funds efficiently and effectively to provide access to quality care. The report to Congress would not be a comparison of States but a presentation on the programs in each State and what steps the States are taking to further improve their system of services. Please comment, if you care to, on the annual State report and the report to Congress.

6. Please comment, if you care to, on SAMHSA's proposal to continue the current maintenance of effort requirement including the exclusion from the calculation funds for one-time expenditures of a singular purpose.

Performance Measures

1. Under the proposal, 12 basic measures and 6 developmental measures are identified. Please comment, if you care to, about the benefits and challenges of using this information to describe performance by individual States and to describe the overall capacity, accountability and effectiveness of the systems of community based services for the Nation.

2. How would you improve the measures if you could? Which measures do you believe should be kept, which ones dropped, and which ones amended and how? Are there other measures that you believe should be added that do not appear?

3. This notice suggests that States will be ready to submit basic measurement data in time for their applications for FY 2005 funds. Do you believe that this timetable is realistic?

4. SAMHSA has developed a matrix of program priorities and cross cutting principles that now guides the agency's daily operations and overall program and management decisions. Programs and issues prioritized in this matrix include: co-occurring disorders; substance abuse treatment capacity; seclusion and restraint; prevention and early intervention; children and families; New Freedom Initiative (including the President's Mental Health Commission); terrorism/bio-terrorism; homelessness; aging; HIV/AIDS and Hepatitis C; and criminal justice. As we move forward in measuring the extent to which the agency has been successful in these 11 areas, we are asking the public to comment on how to begin work on ways to measure progress by the States in these and other program areas.

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