CBHA POLICY PLATFORM 2022

CBHA is a statewide association of mental health and substance use disorder non-profit community agencies. We believe that Californians deserve a comprehensive, community-based behavioral health system that is adequately funded. We value outcome based, data driven, and culturally responsive approaches to service provision. We work strategically and collaboratively to pursue public policy initiatives that create system change for communities across our state. We support the integration of behavioral health, physical health, housing, education and vocational rehabilitation services for children, youth, adults and older adults. Our Policy Platform provides a snapshot of policy areas that impact the operations of our eclectic member agencies.

POLICY AREAS:

● Behavioral Health Workforce

Developing the behavioral health workforce, which includes recruiting, training, and retaining staff, is a top priority for CBHA. Due to the pandemic, there has been an unprecedented need for services in both the mental health and substance use disorder (SUD) fields. CBHA members statewide constantly struggle to fill open positions at all levels, but it is especially difficult recruiting licensed clinicians and psychiatrists. A major contributor to the workforce crisis is basic payment rates for behavioral health providers. Current payment rates do not allow providers to offer competitive pay and, therefore leading to attrition and recruiting challenges.

Additionally, there is a lack of diversity within the state’s behavioral health workforce. According to the 2010 US Census, nearly 40 percent of Californians are of Hispanic/Latinx origin, and 15 percent are Asian American. California’s mental health and SUD workforce remains predominantly white, English-only speakers. This lack of workforce diversity poses a barrier for racially and ethnically diverse communities, including those who identify as Lesbian, Gay, Bisexual, Transgender, Queer, Intersex, Asexual, Two-Spirit (LGBTQIA2+) or are part of a refugee or immigrant community, to receive care and discourages individuals representing these communities from entering the workforce.

In recognition of the challenges of cultivating an adequate workforce, CBHA supports efforts (paperwork reduction, telehealth services, payment reform, etc.) to bolster the behavioral health workforce. CBHA continues to play a central role in crafting language for Proposition 63 which set aside 10 years of funding for Workforce, Education, and Training (WET) programs throughout the state. CBHA sponsored a 2019 budget request to continue the WET program funding for an 11th year, which resulted in 10 million dollars being allocated for this purpose. In 2020, CBHA partnered with the California Behavioral Health Planning Council and the California Association of Marriage and Family Therapists to request 70 million dollars to fund the new 5-Year Plan drafted by the Office of Statewide Health Planning and Development (OSHPD). This resulted in approximately $100 million being allocated for workforce efforts in CA.

We also support strengthening the behavioral health pipeline by providing education and training opportunities at the primary school, high school, and college levels. CBHA supports the expansion of roles for peers and other allied health professionals such as psychiatric nurse practitioners, certified community health workers, and peer counselors. In addition, we support efforts that ensure reimbursement parity for all licensed behavioral health professionals e.g., the ability for all clinicians to bill Medicare. We also encourage the state to examine loosening restrictions and barriers that prevent license reciprocity. Lastly, we promote an integrated team approach to healthcare including psychiatric mental health nurse practitioners, mental health clinicians, psychologists, psychiatrists, SUD counselors, and primary care providers. This team approach is a critical component of providing patients with whole-person care.

● Race & Social Equity Efforts

CBHA recognizes the impact of health disparities on the communities they serve. In particular, racial and ethnically diverse communities continue to suffer from behavioral health conditions at disproportionate rates when compared to their white counterparts yet receive a lower standard of care. In addition, these communities also suffer from decades of historical & racial trauma, as well as transgenerational trauma, which exacerbates stigma that in turn impacts their willingness to participate in treatment. CBHA is exploring ways to address these disparities through its innovative projects spearheaded by its Race and Social Equity Task Force (RSET). In addition to policy changes, CBHA supports further transparency around funding for black and Indigenous people of color (BIPOC) community-based organizations (CBOs) and encourages the state to create a statewide dashboard to measure meaningful financial investments.

● Waiver Implementation

Pending CMS approval on the 1115 extension, this year marks the expiration of two important waivers: 1) The Medicaid Section 1115 Waiver and 2) the 1915(b) Medi-Cal Specialty Mental Health Services Waiver. The renewal of these waivers creates opportunities for CBHA, in collaboration with other partners in the behavioral health community, to work with the Administration to shape the policies included in California Advancing and Innovating Medi-Cal (CalAIM) proposal.

● Technology & Telehealth

CBHA recognizes that technology is an essential tool for addressing barriers to accessing care. This may include telehealth to expedite service provision and address workforce issues, and applications to track data and treatment outcomes. Two years into the COVID-19 pandemic, telehealth has become an integral part of our healthcare system. CBHA is dedicated to working with the Administration and key stakeholders to ensure that the temporary telehealth expansion provided in Executive Order N-16-21 becomes permanent. While telehealth has proven to be reliable and cost-effective, CBHA recognizes the digital inequities that exist in the communities we serve. CBHA is committed to bridging the digital divide and addressing the challenges of digital literacy to expand healthcare access throughout California.

We also advocate for better interoperability between electronic health record systems due to competing county medical models and historically siloed systems. CBHA will provide feedback to the state as a stakeholder to the California Health & Human Services Agency (CalHHS) Data Exchange Framework Stakeholder Advisory Group, California Institute for Behavioral Health Solutions (CIBHS) Behavioral Health Technology Conference Steering Committee, and as a planning member for the CIBHS Technology and Equity convening in 2022.

● 988 Implementation

On July 16, 2022, the new three-digit dialing code (9-8-8) National Suicide Prevention Lifeline will become active. While the national requirements supersede state direction, sustainable funding and expanding capacity of the call centers’ operations are still being negotiated and finalized in each state. California’s system of nationally accredited suicide prevention call centers intends on leading the way for this critical nationwide policy shift. CBHA will continue to advocate for funding for these high-quality telehealth services and data to drive this life-saving service (call, chat, and text) and support our members, who are industry leaders, through strategic legislation and budget requests. Our goal for this new healthcare initiative includes a robust funding model that includes full reimbursement for Medi-Cal services, private grants, and state funding that allow for a data-driven telehealth system that can serve as a model for our nation.

● Payment Reform

Through the CalAIM proposal, states, health plans, and providers are developing value-based models to pay for Medi-Cal behavioral health care services. CBHA has led a payment reform learning collaborative project and will continue partnering with other stakeholders to explore payment models that reward high-quality and cost-effective care, reform the payment system to reflect clinical performance and other outcome-based metrics, and advocate for these changes to state agencies. CBHA will continue to assist member agencies by advocating for appropriate county reimbursement rates for services and equitable contracts as it pursues advocacy for greater payment reform efforts.

● School-Based Mental Health

Prevention and early intervention (PEI) is a key tenet of best practice in the delivery of behavioral health care services. CBHA advocates for flexibility in how various funding streams a student is eligible for can work in concert to provide whole-person care regardless of insurance type. CBHA is committed to working with the California Department of Education (CDE), Department of Health Care Services (DHCS), Mental Health Services Oversight and Accountability Commission, and other education advocates to pursue partnerships that will enable community-based organizations to contract with the CDE or local educational agencies to provide needed behavioral health services and support the training of school personnel to recognize behavioral health needs for school-aged youth. These services should also include a focus on providing treatment for substance use disorders. Our members understand that school-based services are offered as part of a comprehensive array of services. School-based services should be offered on campus or outside of the school setting throughout the calendar year since students have mental health crises and needs outside of traditional school hours and the school year. CBHA will also advocate for direct payments from the state to providers in an effort to reduce administrative costs and provide timely patient care without having to rely on a lengthy approval process.

● Paperwork Reduction

In 2016, CBHA commissioned a study of documentation requirements in the state and compared the requirements to other states. Varying county-mandated documentation requirements result in California having an average of 20 minutes needed to document each therapy/treatment visit, which is four times the average of other states included in the study. Not only does this reduce the amount of time for professionals to provide services, but the frustration associated with excessive documentation also results in trained and licensed staff pursuing jobs outside of publicly funded mental health settings. As a member of the Behavioral Health Documentation Redesign Stakeholder Workgroup, CBHA will continue to advocate for statewide standards to increase treatment capacity and retain a qualified workforce by ensuring that there is parity in behavioral health and physical health requirements across the healthcare system.

● Youth SUD System

The Adult Use of Marijuana Act (AUMA) approved by voters on November 2016 mandates and earmarks specific funds for youth SUD treatment and prevention. There is no comprehensive system of care for children, youth, and young adults who need help dealing with alcohol and drug problems. CBHA and our partners in this effort believe this mandate is an unprecedented opportunity to invest in our state’s youth and fill longstanding and persistent gaps in youth SUD care by creating that system of treatment. CBHA, in collaboration with the California Consortium of Addiction Programs and Professionals (CCAPP) and California Association of Alcohol and Drug Program Executives (CbAADPE), has developed a series of recommendations supporting the use of the funds to assist with the provision of SUD treatment services.

● Older Adults

Older adults are losing their jobs at a higher rate than younger adults for the first time in modern history in California. The likelihood of regaining pre-pandemic employment levels may be unlikely due to age discrimination. Moreover, older adults are becoming homeless at alarming rates. CBHA will support member agencies in addressing behavioral health needs unique to older adults and advocate to ensure that community living is a priority. CBHA will continue its work to educate the community about the unique behavioral health of older adults as a member of the Governor’s Master Plan for Aging Stakeholder Advisory Committee.

● Housing, Homelessness and Behavioral Health

California is experiencing a homelessness epidemic where one in four people are homeless. People of color represent a disproportionate percentage of those experiencing homelessness in our state. While just 6.5 percent of Californians identify as Black or African American, nearly 40 percent of California’s homeless population is Black or African American. In Los Angeles County, adult Latinos are experiencing higher rates of new homelessness than other ethnic and racial groups. This crisis has been exacerbated by the pandemic that has had a debilitating impact on the high-risk homeless population in California. With shelter populations increasing, and capacity decreasing, social distancing is difficult. The state-funded Project Roomkey has benefited communities by paying for homeless families and high-risk COVID positive individuals to move into hotels temporarily, but support is not permanent.

As the homelessness epidemic is correlated to poor behavioral health, and frequent use of emergency psychiatric services, CBHA will monitor the progress of the Governor’s Homelessness Task Force. CBHA will advocate for state funding to continue to fund needed shelter during the pandemic. CBHA will also identify ways that professionals across sectors including case managers, social workers, community outreach specialists, housing authorities, developers, law enforcement professionals, healthcare, and mental health practitioners, can identify challenges and consider the next steps in tackling homelessness across California, helping people maintain their housing (including renters' protections), and protecting and building affordable housing.

● System of Care Disparities

CBHA will continue to encourage the State of California and the behavioral health community to further address the disparity of mental health and SUD services in the suburban and rural areas of our state. Strategies include highlighting the issues SUD providers face. CBHA will also advocate that a comprehensive and integrated system of care be created where SUD and mental health treatment are combined (e.g., integration of funding siloes). CBHA will continue to monitor and advise policymakers and enforcers about the implementation of SB 855 (Wiener), which updates, strengthens, and enforces parity regulations.

● Family First Prevention Services Act (FFPSA) Implementation

CBHA staff continues to work with partners to address the behavioral health needs of children within the foster care and juvenile justice systems including participating as key stakeholders in various work groups convened by state agencies. DSS and other children advocates are focused on addressing barriers to Continuum of Care Reform implementation, offering technical assistance to community-based organizations and counties, and increasing the number of qualified resource families so that more children will achieve permanency in a community-based setting.

While much of the focus has been on foster youth, more attention needs to be placed on cross-system youth or referrals from probation departments who have acute behaviors and needs and may not be well suited for Short- Term Residential Therapeutic Program settings.

CBHA will continue to monitor the impact of the Family First Prevention Services Act (FFPSA), which aims to provide enhanced support to children and families and prevent foster care placements by changing the way that Title IV-E funds are spent, reimbursement for group care placements, and regulations for qualified residential treatment programs. In addition, CBHA will monitor the use of Title IV-E and IV-B funds for prevention activities such as in-home support services that could be contracted out to CBOs.

● Youth & Young Adults (YYA)

Transition-age youth or Youth and Young Adults (YYA) are included in the MHSA because they are a distinct population from children and adults. Recent studies show YYA identify employment, education, and housing as equal to their behavioral health needs during the pandemic. The development of personal relationships and independent living skills has been impacted as many young people move back home to shelter-in-place and support their families. Listening to YYA voices is important for developing services tailored to their needs. CBHA will encourage member agencies to continue to support young adult development.

● Opioid Epidemic

Opioid abuse and addiction to opioids have significantly impacted patients and the healthcare delivery system nationwide. In 2017, the United States Health and Human Services Agency declared the opioid crisis a public health emergency. The COVID-19 pandemic has only worsened these conditions, leading to increased incidences of anxiety, depression, and higher rates of substance use – with more than 93,000 people losing their lives to drug overdoses in 2020, a 30 percent increase from 2019 according to the Centers for Disease Control and Prevention (CDC). Additionally, the opioid epidemic continues to have devastating social and behavioral health consequences for children and adolescents. CBHA will continue to position itself to assist in combating the epidemic by supporting clinical best practices and advocating for policy reform at the state and federal levels that will assist in decreasing abuse and addiction.

● Poverty & Social Safety Net

Social safety nets are designed to distribute resources and services to those who are in poverty or at risk of poverty. In California, more than one-third of state residents are living in or near poverty. Issues like loss of employment, lack of food security, consistent health care, housing, and lack of access to healthcare to address physical and behavioral health conditions significantly impact clients’ ability to live a happy and self-determined life. CBHA will continue to support policies and legislation that provide better equity for the safety net population to alleviate the pressure of unfunded services and poor access to safety net services.

● Re-entry & Transition Into Community Post Incarceration

Incarcerated and formerly incarcerated populations experience unique challenges that impact their behavioral health. With the Governor’s recommended dissolution of the Department of Juvenile Justice, youth and young adults will need assistance with re-entry back to local communities. CBHA will partner with stakeholders to promote all incarcerated individuals’ transition into the community by promoting access to behavioral healthcare, including medically assisted treatment, prior to and after release. CBHA will also work to educate families of these individuals and communities about resources that will prepare the community to offer assistance to those who are formerly incarcerated and are suffering from a behavioral health issue or disorder.