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      • GAO 15-710: MEDICARE ADVANTAGE: Actions Needed to Enhance CMS Oversight of Provider Network Adequacy (Aug. 2015)
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Thoughts on the Mental health Task force Recommendations--
Comments due to the State Monday December 12, 2016

From One Task Force Member:

The recommendations themselves are all pretty good and I agreed to all of them. I have been really encouraged by the conversation in the room - we've seen some people really come around in terms of their understanding and recognizing the system is broken.

I'm wondering what is going to actually happen after this task force. And the one issue that is still really huge is the hospitals and the designation issue. They keep using EMTALA [Emergency Medical Treatment and Labor Act] as the reason they can't accept patients in rural hospitals with psych crisis.

So while we are saying "no more jails" - everyone is pretty clear that there aren't alternatives so that practice is not going to end right away. 
 
My bigger concerns are probably things we can't do much about:
 
1) Follow-through (how are these recommendations going to be acted upon and upheld and by whom?)

2) Funding = many of these recommendations are going to require funding and they said maybe $4 million additional in the budget ​for next year but that's not nearly enough to do what is needed.

3) The crisis system and specifically "mobile crisis" in the rural areas is really terrible and it doesn't seem like there's anyone overseeing it or doing anything to change it. And I put "mobile crisis" in quotes b/c its been explained to us that all that is - is a clinician who drives around in her own car and calls the Sheriff's Dept to accompany her to crisis calls - and she is genuinely doing everything she can but that is the rural "mobile crisis".

4) No accountability for MHCs/BHOs [Mental Health Centers/Behavioral Health Organizations] - and one Ombudsman is not going to be able to address all of the issues. 

 
I'm trying not to be negative :) but I am afraid like every other task force this issue will fade into the background. 


Orchid's Positions & Comments on the Mental Health Task Force Recommendations -- No Objections to Any of the Recommendations; Brief Comments
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CDHS
Why the Mental Health Hold Task Force was created


Gov. John Hickenlooper directed the Colorado Department of Human Services to create a task force to examine issues of concern around mental health holds in Colorado.

The request was included in the letter the governor issued in June when he vetoed Senate Bill 16-169, which addressed mental health hold practices.

In vetoing the bill, the governor issued a statement that said, in part:

“We agree that appropriate mental health facilities are not always readily available to treat persons having a mental health crisis. While well-intentioned, we are concerned that SB 16-169 does not provide adequate due process for individuals.”

​CDHS creates task force and articulates missionIn June, CDHS Executive Director Reggie Bicha called for applicants to serve on the task force, and articulated a list of issues for the task force to address. 

Specifically the Mental Health Hold Task Force was asked to meet a Jan. 1, 2017 deadline imposed by the governor to make statutory, policy, and administrative recommendations to:
  • Ensure proper mental health treatment for individuals in crisis, while satisfying individual's rights under the federal Emergency Medical Treatment and Labor Act (EMTALA) and due process standards. This should include exploring models used in other states;
  • End the practice of confining in jail persons with mental illness who have committed no crime;
  • Where appropriate, streamline and align regulatory oversight of the mental health hold process while ensuring necessary patient care requirements and protecting patient rights; 
  • Understand the need for, and overcome barriers to, providing inpatient psychiatric care to persons in mental health crisis;
  • Maximize existing state resources, including examining potential enhancements that can be made to the current crisis services and transportation systems;
  • Develop data tracking and provider communication systems to better understand the scope of the mental health hold problem in Colorado.

   https://sites.google.com/a/state.co.us/cdhs-pso-bc/ccibvi/mental-health-hold-task-force​
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Orchid:  Email

Crisis Services in Colorado, the US & Around the World

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  • Home
    • About Orchid >
      • Why Orchid?
      • ORCHID'S SYSTEMIC FOCUS & "ROOT CAUSE" ANALYSIS APPROACH TO PROBLEM SOLVING WITH A COMMITMENT TO CREATIVITY & INNOVATION
      • Disclaimers, Limitations and An Invitation
      • Orchid Board
      • Orchid Book Club
      • Conjecture, Science & Translational Research & Medicine
      • Orchid Themes & Symbols
      • The Tipping Point
      • Orchid's Website Advertising Policy
      • Statement for Potential Website Contributors
      • Contact
  • Blogs
    • Val's Blog
    • Val's Blog 2
    • ​TRANSLATIONAL/ ​TRANSITIONAL JUSTICE MONDAY
    • NEURO-DIVERSITY Wednesday
    • Olmstead Law & Order Thursday
    • Translational Medicine Friday
    • Translational Love, Relationships & Neuro-Diversity Saturday
  • Orchid's A-Z Index
    • Crisis Services in CO, the US & Around the World
    • Assertive Community Treatment & Flexible ACT Index
    • Housing & Homelessness Index
    • Criminal Justice
    • Innovation Index
    • For More: See the Main Orchid Index Page
  • US Federal
    • THE IMD RULE & ADMIN. ENFORCEMENT OF DISABILITY CIVIL RIGHTS LAWS
    • Medicaid & Supportive Housing & Housing-Related Services
    • CMS' FAILURE TO COVER HOUSING FOR LTC & THE IMD RULE: WHAT THEY HAVE IN COMMON IS DISCRIMINATION
    • National Take
  • Immunology & Mental Health
    • Alcoholism & the Immune System & Mental Health
    • Brain Injury, the Immune System & Mental Health
    • Celiac Disease & Sensitivities, the Immune System & Mental Illness
    • Mental Illness & The Immune System
    • Racial Discrimination & the Immune System & Mental Health
    • Trauma & the Immune System & Mental Health
    • ***Physical Health Issues, the Immune System & Mental Health Index
  • University of Chicago: Institute of Translational Medicine
  • Hot Topics
    • What We Want --- SAMHSA Grant Opportunities Due Jan. 22, 2019
    • Anti-Social Personality Disorder >
      • DECONSTRUCTING ANTISOCIAL PERSONALITY DISORDER AND PSYCHOPATHY: A GUIDELINES-BASED APPROACH TO PREJUDICIAL PSYCHIATRIC LABELS [Hofstra Law Review 2013]
      • Personality Disorders -- Unscientific & Vague -- Must Be Reformed
    • Executive Functioning & "Prison Brain" >
      • Job Accommodation Network on Executive Functioning Deficits
    • Medicaid & Medicare Network Adequacy >
      • OIG: STATE STANDARDS FOR ACCESS TO CARE IN MEDICAID MANAGED CARE (Sept. 2014)
      • OIG: ACCESS TO CARE: PROVIDER AVAILABILITY IN MEDICAID MANAGED CARE (Dec. 2014)
      • GAO 15-710: MEDICARE ADVANTAGE: Actions Needed to Enhance CMS Oversight of Provider Network Adequacy (Aug. 2015)
      • CMS: Promoting Access in Medicaid and CHIP Managed Care: A Toolkit for Ensuring Provider Network Adequacy and Service Availability (April 2017)
    • Medicaid Mental Health & Substance Use Disorder Parity >
      • CMS Parity Compliance Toolkit Applying Mental Health and Substance Use Disorder Parity Requirements to Medicaid and Children’s Health Insurance Programs [Jan. 17, 2017]
      • Frequently Asked Questions: Mental Health and Substance Use Disorder Parity Final Rule for Medicaid and CHIP [CMS October 11, 2017]
    • Olmstead Disability Rights >
      • Statement of the Department of Justice on Enforcement of the Integration Mandate of Title II of the Americans with Disabilities Act and Olmstead v. L.C. (2011)
      • Comprehensive Olmstead Planning
      • the Logical Long Term Consequences of our failure to provide Intensive Community MH Treatment
      • Olmstead Nation ---State Pages: How Far to Comply with Olmstead?
  • Take A Walk Around Orchid's Resource Block
  • Colorado Abuse & Neglect Scandals Involving People with Disabilities
  • Mental Health By The Numbers
  • New Science Is Amazing AND It Has HUGE Moral Implications for Our Society: NOW
  • Olmstead & Homelessness
  • Double V
  • " 'Defund the Police" Means 'Invest in the Resources Our Communities Need' " or Don't Cost Shift to the Police
  • VAGUE OLMSTEAD PLANS, EXPENSIVE LITIGATION
  • Updating & Reforming our Understanding & Treatment of "Anti-Social Personality Disorder" Blog
  • Reform of " Anti-Social Personality Disorder" in Criminal Justice
  • CO HB22-1278
  • New Understandings Matter
  • Mental Health, Ethics & Law
  • CO Olmstead Disability Homeless Law & Policy Project
  • Inflammation, the Immune System, Neuro-Developmental Disorders, Psychiatric Disorders, Substance Use Issues & Chronic Disease
  • Microglia and the Brain's Immune System
  • Substance Issues & the Immune System