As of October 1, 2015, the Washtenaw Community Health Organization (WCHO) ceased to exist as the county's community mental health agency. Washtenaw County Community Support and Treatment Services (CSTS) has become the new Washtenaw County Community Mental Health (WCCMH). The agency is now under the control of the Washtenaw County Board of Commissioners, although the agency may seek to become an independent mental health authority in future years.
WCCMH provides mental health services to adults with a severe
and persistent mental illness, children with a severe emotional
disturbance, and individuals with a developmental disability, residing
in the county.
This is the list of current WCCMH Board members with contact information. The Board meets on the third Friday of the month from 9:30 to 11:30 a.m. at the Learning Resource Center at 4135 Washtenaw Avenue in Ann Arbor. This is a link to a schedule of Board and committee meetings. The new Board is learning about the intricacies of the State and local CMH system - this is a good time for families and local organizations to attend Board meetings, introduce yourself to the Board, and learn more about how the service delivery system works in Washtenaw County.
Links to WCCMH information:
The Prepaid Inpatient Health Plan (PIHP) is now the Community Mental Health Partnership of Southeast Michigan (CMHPSM). The PIHP, one of ten in the state, is a regional administrative entity that distributes Medicaid funds to its local partners, the Community Mental Health agencies for Washtenaw, Lenawee, Livingsston, and Monroe Counties. The reorganization of PIHPs and the reduction in number of PIHPs from 18 to 10 has been a somewhat easier transition for our region because the same counties participate in the PIHP as did under the old system.
These are links to information about the CMHPSM and some of the services it provides:
The Ann Arbor News featured a long article about the decrease in funding for Community Mental Heatlh (CMH) services in Washtenaw County: "Analysis: Where has all the money gone? Washtenaw County's mental health mess" by Ben Freed, 11/15/15.
Kudos to Ben Freed for figuring this out and analyzing a mess similar to the results of Humpty Dumpty falling off the wall in the nursery rhyme. Freed has unscrambled the egg and now I am trying to understand and translate his analysis, so that us ordinary people dealing with the mental health system can at least have a clue as to what happened.
The CMH system provides services primarily to people with developmental disabilities, mental illness, and drug abuse problems. For individuals who are eligible for Medicaid and are developmentally disabled, Washtenaw County CMH still has a responsibility to provide them with all services that are deemed medically-necessary through a person-centered planning process that results in an Individual Plan of Services (IPOS). Most people with developmental disabilities fall under this category. This has not changed, but many other people who were previously covered by CMH who do not fit that category, have found themselves with greatly reduced services or none at all. This is bound to affect the entire system.
What Happened?
Washtenaw County's mental health services budget was $80 million in fiscal year 2012 and has fallen to $66.7 million in Fiscal Year 2016.
Where has the $14.3 million gone? Freed breaks it down into several categories to account for the lost funds.
$3.86 Million: The WCHO deficit
The Washtenaw Community Health Organization was formed in 2000 in partnership with the University of Michigan and was designated the Prepaid Inpatient Health Plan (PIHP) for a four county area as well as the CMHSP (or what had previously been called the CMH ) for the County. The PIHP is a regional administrative agency that distributes Medicaid funding to the counties belonging to its affiliation and the CMHSP provides the services.
Within the WCHO, Medicaid funding and the number of people served would fluctuate over the course of a year and deficits in one county, usually Washtenaw, would be plugged by surpluses in other counties. This practice was not hidden and it was the accepted way of balancing the budget. Sometimes infusions of state funding would also fill the gaps.
By 2014, it became clear that the gap had reached unmanageable proportions and a Washtenaw County Behavioral Task Force recommended dissolution of the WCHO and a takeover by Washtenaw County government to provide better oversight and monitoring of CMH. There were also changes in state funding and the PIHPs that eventually led to substantial changes:
“A new organization, the Community Mental Health Partnership of Southeast Michigan, was formed to take over PIHP duties from the Washtenaw Community Health Organization, which was eventually phased out as an entity in 2015. Its county functions were absorbed by the CSTS [Community Supports and Treatment Services], which took on the name Washtenaw County Community Mental Health.”
Cuts in services to offset the deficit have been the source of controversy and have led to devastating results for some County residents.
$8.5 million: Medicaid and carry over
Medicaid funding accounts for 80% of the Washtenaw CMH budget. Medicaid funds can only be used for certain services for Medicaid-eligible individuals and cannot be used for other services or for those who do not qualify.
Here is where you have to watch the bouncing ball to understand what is going on with Medicaid:
If the economy improves, as it has in the last couple of years, fewer people qualify for Medicaid and funding to CMH goes down:
“As of June 2015, there were 3,333 fewer total Washtenaw County residents on Medicaid than the previous June—that number includes all Medicaid enrollees, not just mental health patients. In FY 2015, Washtenaw County received about $1.4 million less than was budgeted for that year and in the coming year the county's Medicaid payout will be down by $2.5 million.”
In previous years, any Medicaid money that was not used up could be rolled over into the next year’s budget:
In 2012, the WCHO had $8milliion to carry over to its next fiscal year. “By FY 2014 the carry forward had shrunk to $6 million and four months into the following fiscal year, it was gone. This year there is no carry forward money to help supplement the Medicaid dollars. At the same time, community living support costs grew from $10.4 million in FY 2010 to more than $22 million by FY 2014. Core provider costs had grown from $25.8 million to nearly $30 million over the same time period.”
Also, “Three of the four counties in Washtenaw County's PIHP region did not receive enough Medicaid dollars to fully fund their programs in FY 2014 and the $1 million surplus from Lenawee was distributed to help the other three support their deficits.”
$2.2 Million: The State of Michigan
Although the State Budget Office tells us that the state's total mental health budget - including the Healthy Michigan Plan (Medicaid expansion) - grew by 9 percent to a total of $2.8 billion in 2015, local CMH agencies are struggling with financial problems not addressed by the state or exacerbated by state funding decisions.
Michigan introduced its Healthy Michigan Plan (Medicaid expansion), in 2014, and more than 600,000 people signed up who had previously not had Medicaid coverage:
“Because enrollment was higher than expected, the state had less money to pay per patient than they had previously estimated. Approximately 15,000 people enrolled in the program in Washtenaw County, but the per-patient rate was adjusted down by $10 per month mid-year by the state.” This resulted in $1million less revenue than expected for Healthy Michigan Plan CMH consumers that will carry over into 2016.
Then, “with the new federal funding coming into mental health services, the state also took the opportunity to cut general fund allocations to county mental health agencies across the state.” Because this money had been used to fill in gaps for County residents who did not qualify for Medicaid or were on the borderline of qualifying, services that were once provided with general fund money, are the most adversely affected by the state’s decision.
As a result, “’You're starting to see those people in the ER, you're going to start seeing them in the justice system, people who had been under our care,’ Cortes said. ‘These are people we've been serving for more than a decade.’”
“…Washtenaw County's general fund allocation for FY 2012 was $8.36 million. In FY 2016 it is $2.8 million, but the state is also taking on about $1.9 million payments to state hospitals that previously came from the general fund allocations.”
What happens next?
There are state-level discussions going on to request an increase in general fund dollars for county CMH agencies. Washtenaw County Board of Commissioners has stepped up to continue funding of the county’s vocational training program. The County has also added a “structural $400,000 allocation to mental health from its general fund that will be paid for through the anticipated increases in taxable value in the county.”
“…St. Joseph Mercy Hospital and University of Michigan Health System have each pledged more than $100,000 to Community Mental Health and the Washtenaw County Health Plan is adding an additional $150,000. Those funds will all go toward direct services for people not covered by Medicaid.”
In addition, “The county is also in negotiations with the unions about maintaining staffing and pay levels for county employees”.
The article also covers the programs that are likely to be most affected by the changes in Washtenaw County and the services that will likely be dropped.
Read the full article here...
Another article, "What the mental health funding cuts mean for one woman's struggles" by Ben Freed, 11/15/15, follows the day-to-day changes in the life of a woman with severe mental illness whose services have been reduced or eliminated.
These are my recommended additions and changes to the Michigan Protection and Advocacy Service (MPAS) Priorities and Objectives for FY2016 that will ensure the rights of people with developmental disabilities to appropriate services based on their individual needs and preferences. (Added language is in all CAPS.)
Priority #2: Increase the protection of individual rights, independence and self-determination
- Objective 2A: Individuals with disabilities will not be deprived of their rights and will be able to engage in self advocacy TO THE EXTENT APPROPRIATE BASED ON THEIR NEEDS AND CAPABILITIES AS DETERMINED THROUGH A PERSON-CENTERED PLANNING PROCESS.
- Objective 2B: ASSURE THAT “SELF-DETERMINATION” AS A METHOD OF DETERMINING AND DELIVERING SERVICES WILL BE OFFERED AS AN OPTION TO MORE TRADITIONAL FORMS OF SERVICE DELIVERY.
Priority 3: Eliminate employment barriers and protect rights
- Objective 3A: Improve access and rights to services within vocational rehabilitation and centers for independent living
- Objective 3B: Individuals with disabilities will assert their employment rights under the ADA and/or Section 504, as well as other employment laws, e.g. Fair Labor Standards Act, and will have employment options in the competitive and integrated workforce.
- Objective 3C: Individuals with disabilities will have access to social security work incentives. Objective 3D: Beneficiaries with disabilities will be free from exploitation, abuse, and neglect by their representative payee.
- OBJECTIVE 3E: ENSURE THE AVAILABILITY OF CENTER-BASED VOCATIONAL PROGRAMS AND OTHER EMPLOYMENT OPTIONS THAT TAKE INTO CONSIDERATION INDIVIDUAL NEEDS AND PREFERENCES AS DETERMINED THROUGH A PERSON-CENTER PLANNING PROCESS FOR INDIVIDUALS WHO MAY NOT BE ABLE TO PARTICIPATE SUCCESSFULLY IN COMPETITIVE, INTEGRATED EMPLOYMENT.
Priority 4: Improve access to services
- Objective 4A: Individuals with disabilities will be assured services, including housing, transportation and assistive technology, identified to support them IN THE HOME AND COMMUNITY OF THEIR PREFERRED CHOICE AS EXPLORED AND DOCUMENTED IN THEIR PERSON CENTERED PLANNING PROCESS.
- Objective 4B: Governmental entities and providers of critical services will be accessible and provide needed accommodations.
- Objective 4C: Individuals with disabilities will have access to services, including assistive technology, which supports THEIR RETENTION OF OR TRANSITION TO A HOME AND COMMUNITY OF THEIR PREFERRED CHOICE AS EXPLORED AND DOCUMENTED IN THEIR PERSON CENTERED PLANNING PROCESS.
See also suggested comments from AACORN Farm, a farm-based vocational program for adults with autism.
The following are excerpts from public comments by Jill Escher, President of the Autism Society San Francisco Bay Area, to the California HCBS advisory group on 10/27/15:
"In spite of the staggering numbers of young ASD [Autism Spectrum Disorder] adults with significant and complex support needs, California has failed to develop any plan for expanding housing to serve them. And, though ludicrous and ruinous, some disability advocates are vying for a narrow reading of HCBS, essentially attempting to sharply limit choice and erect high barriers to new disability-friendly developments, even for the most severely disabled who cannot thrive in generic apartment environments, and indeed would be vulnerable to the abuse, neglect, and isolation."
..."Consistent with common sense, civil rights laws, and fair housing laws, the menu of options available to the severely autistic must be at least as broad as those available to the non-disabled, and should include congregate settings (agricultural projects, farms, disability-friendly group environments, and so-called "gated communities" included) and amenity-rich developments designed to meet the unique needs of our disabled individuals."
"... 'heightened scrutiny' should be employed solely to ensure that any residential choice (even and especially a disability-centered choice) is in fact the result of a choice on the part of the consumer and/or his/her conservators, and not the result of coercion or restraint on the part of government or governmental agency."
Read the complete statement on the SFAutism Blog.
Contact information:
info@sfautismsociety.org.
(650) 637-7772
Autism Society San Francisco Bay Area
PO Box 249, San Mateo, CA 94401
Thomas Renwick, the Director of the Michigan Bureau of Community Based Services, has sent a warning to agencies that fund and provide services to people with developmental and other disabilities: Assessment tools that are inappropriately and arbitrarily used to restrict needed services, supplant Medicaid “medical necessity” criteria, and to achieve budget reductions are not allowable by the Michigan Behavioral Health and Developmental Disabilities Administration (BHDDA).
“Please be advised that any assessment or screening tool, including those required by the Department, cannot be utilized…as an arbitrary means for identifying the amount, scope or duration of services that an individual will receive. While such assessments can certainly help inform the person-centered planning process, it is the person-centered planning process and medical necessity criteria that determine the amount, scope and duration of services. With regards to determining medical necessity, I am not aware that any of the assessments or tools in use or proposed for use have any normed or research supported basis for determining an individual’s medical necessity for services and supports. [emphasis added.] It also bears reminding that the PIHP [the regional agency that administers funding of CMH services] is obligated to ensure that medically necessary supports, services or treatment are sufficient in amount, scope and duration to reasonably achieve their purpose.”
Provider networks must also ensure that individuals are provided proper notice of their rights if they are not satisfied with the outcome of their person-centered planning process.
See also Michigan guidance on the use of the Supports Intensity Scale, an assessment tool that the BHHDD encourages with the consent of the individual but advises that it should not be tied to medical necessity criteria and the authorization of services.
According to the National Core Indicators (NCI) website,
“NCI is a voluntary effort by public developmental disabilities agencies to measure and track their own performance.
“The core indicators are standard measures used across states to assess the outcomes of services provided to individuals and families. Indicators address key areas of concern including employment, rights, service planning, community inclusion, choice, and health and safety.”
The degree of loneliness that a person with a developmental disability experiences is one of those indicators. Here is a chart showing the overall proportion of people with DD who do or do not experience loneliness:
This is a chart generated using data on the website showing the settings in which people live who sometimes or often feel lonely:
This seems to contradict the conventional wisdom that people in larger more structured settings are generally isolated from other people and feel more lonely than people living in their own apartment, for instance. On the other hand, the type of setting where one lives may not be an important factor in terms of how often they feel lonely. Perhaps the appropriateness of the setting to the needs of the individual is more important.
The use of data of this type can be tricky and it is hard for people without a background in statistics to evaluate what it is really telling us. Unfortunately, generalizations about the subjective experiences of people with disabilities are used to promote policies that may not apply to a substantial number of people with DD or may be harmful to people who do not fit the generalization.
Check out the website and see how it applies to you and your family member with a disability.
Michigan Protection & Advocacy Service, Inc. (MPAS) is the
independent, private, nonprofit organization designated by the governor
of the State of Michigan to advocate and protect the legal rights of
people with developmental disabilities in Michigan. MPAS services include information
and referral, short-term assistance, selected individual and legal
representation, systemic advocacy, monitoring, and training. The MPAS receives funds primarily through the federal Developmental Disabilities Assistance and Bill of Rights Act of 2000 (a.k.a The DD Act).
The MPAS also provides federally-funded services to other disability groups. Here is a list of their programs.
MPAS seeks your input on their 2016 advocacy priorities and objectives.
Comments will be accepted through November 16, 2015 and should be sent via email to asteffen@mpas.org.
Here is a link to the Priorities and Objectives in different formats - Word document, PDF, and Text file. These are the same as the priorities listed below.
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MPAS Board approved Priorities available for public comment:
Priority #1: Eliminate abuse and neglect
- Objective 1A: Individuals with disabilities will not be subjected to restraint or seclusion.
- Objective 1C: Individuals with disabilities will not be subjected to abuse or neglect, including inappropriate or coercive treatments.
Priority #2: Increase the protection of individual rights, independence and self-determination
- Objective 2A: Individuals with disabilities will not be deprived of their rights and will be able to engage in self advocacy.
Priority 3: Eliminate employment barriers and protect rights
- Objective 3A: Improve access and rights to services within vocational rehabilitation and centers for independent living
- Objective 3B: Individuals with disabilities will assert their employment rights under the ADA and/or Section 504, as well as other employment laws, e.g. Fair Labor Standards Act, and will have employment options in the competitive and integrated workforce.
- Objective 3C: Individuals with disabilities will have access to social security work incentives. Objective 3D: Beneficiaries with disabilities will be free from exploitation, abuse, and neglect by their representative payee.
Priority 4: Improve access to services
- Objective 4A: Individuals with disabilities will be assured services, including housing, transportation and assistive technology, identified to support them in the community and prevent institutionalization or segregation.
- Objective 4B: Governmental entities and providers of critical services will be accessible and provide needed accommodations.
- Objective 4C: Individuals with disabilities will have access to services, including assistive technology, which supports them in institutional/facility/service provider settings in order to promote discharge and community inclusion.
Priority 5: Ensure the right to a high quality education
- Objective 5A: Students with disability-related behavior will be identified and evaluated for special education.
- Objective 5B: Eligible students at risk of discipline or push-out due to disability-related behavior will remain in school.
- Objective 5C: Transition needs from post education to community living will be identified and addressed.
[More information on Protection and Advocacy and the DD Act coming soon!]
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Update: Suggestions from the Coalition for Community Choice
Priority 4: Improve access to services
Objective 4A: Individuals with disabilities will be assured services, including housing, transportation and assistive technology, identified to support them in the HOME AND COMMUNITY OF THEIR PREFERRED CHOICE AS EXPLORED AND DOCUMENTED IN THEIR PERSON CENTERED PLANNING PROCESS.
Objective 4B: Governmental entities and providers of critical services will be accessible and provide needed accommodations.
Objective 4C: Individuals with disabilities will have access to services, including assistive technology, which supports THEIR RETENTION OR TRANSITION TO A HOME AND COMMUNITY OF THEIR PREFERRED CHOICE AS EXPLORED AND DOCUMENTED IN THEIR PERSON CENTERED PLANNING PROCESS.
