Occupational Therapy in Mental Health: SAMHSA Listening Session and Comments (November 12-26, 2014)

AOTA and SAMHSA

In case you didn’t know, occupational therapists currently play an important role in helping people with mental health problems and psychiatric disabilities. They work in community-based, outpatient, inpatient, and other settings to help people living with mental health concerns learn how to best complete the activities they need and want to do.

Although there are some occupational therapists helping some people with mental health issues, there is not nearly enough supply to meet the demand. In the past, OT has not really been recognized as a profession that is equipped to meet the needs of clients with mental health problems, but this could all change in the very near future!

On November 12, 2014, there is going to be a listening session to Support Occupational Therapy’s Inclusion in New Community Mental Health Services. It is vital that as many occupational therapy students, practitioners, assistants and supporters as possible get involved and comment on the session in order to show their support and advocate for occupational therapy services that could be of great benefit to people who access mental health services in the United States. Part of being a successful therapist is being an advocate for the profession, and what better way to promote OT than participating in this crucial political event!

Here is the background on the event, straight from AOTA’s website:

In April, Congress passed the Protecting Access to Medicare Act (H.R. 4302), which established a “Demonstration Program to Improve Community Mental Health Services.” This demonstration program will expand access to quality mental and behavioral health services by establishing federally certified community behavioral health clinics (CBHCs). The demonstration will initially establish CBHCs in eight states through a competitive process, but could eventually CBHCs could be in all 50 states.

This fall, the Department of Health and Human Services (HHS) and the Substance Abuse Mental Health Services Administration (SAMHSA) will be writing the rules that define what mental health services and supports will be provided by these federally supported CBHCs. SAMHSA will be holding a listening session to help them establish the criteria for staffing, services, payment and coordination of care at the CBHCs.

For those not able to attend and comment in person, there is also the opportunity to provide comments in writing. Written comments will be considered just as important as verbal comments during the listening session.

We have been told by SAMHSA that it is important to have a strong demonstration of support for the inclusion of occupational therapy through comments and at this listening session. The development of these criteria is a watershed moment for occupational therapy’s inclusion in quality, community-based mental health services.

And according to SAMHSA:

By September 1, 2015, criteria will be published for state certification of participating clinics and guidance issued for participating states’ establishment of a demonstration Prospective Payment System for services. SAMHSA has the overall lead for the program and is responsible for the establishment of the criteria for the behavioral health clinics.

It is currently too late to register to attend or provide verbal commentary, but listeners and contributors will have until November 26 to submit written commentary, which will be considered just as important as the spoken comments listeners make. Unfortunately, I will be working for half of the day during the session, but I plan to wake up early and catch as much of it as I can before I have to leave!

 

At this point in history, occupational therapy has a chance to be included in landmark federal legislation that will have a great impact on American people living with mental health problems. It is absolutely crucial that we make our voices heard and take the time to support AOTA and the future of the profession in this endeavor, and I want to be sure I do my part!

AOTA has links to several resources that will prepare you to leave a well-written, OT-endorsing comment that will be reviewed by the SAMHSA team. Although the main (and most important) comment-writing document is for “members only,” there are still other helpful links here.

In case you don’t have time to click around and want to get straight to writing, I have compiled a brief list of tips and information from the AOTA and SAMHSA websites in order to streamline the process and hopefully make it that much easier for you to participate! (No excuses!)

Writing Comments

If you are an AOTA member, you can login and view their page of comment-writing tips here: http://www.aota.org/advocacy-policy/congressional-affairs/legislative-issues-update/2014/guidance-samhsa-comments.aspx.

In case you are not an AOTA member, I have included several of their most relevant and important points here to help you write commentary for the SAMHSA session. All information below is from the AOTA.

  • SAMHSA has provided “guiding questions” in a worksheet format to help structure your comments. Consider using the SAMHSA-provided worksheet, or write a letter using the worksheet as your guide.
  • Consider submitting comments on behalf of a larger group of occupational therapy practitioners. One letter could be sent from a facility, state association, or simply have a list of signatures from interested practitioners. The comments will count as if submitted by each individual, and this will make less work for SAMHSA. If submitting on behalf of a facility or association, be sure to mention how many practitioners or clients it represents. Get signatures from non-occupational therapy practitioners if relevant and possible.
  • Comment on as many of the guiding questions that you think are relevant, or on those of which you have expertise.
  • Instead of synthesizing your overall thoughts, comment on each question individually, even if this means repeating something you have already written. Comments will be collated separately for each section.

If you do write a comment, according to AOTA the most important thing to include is the following: Skilled occupational therapy should be a service available to clients on-site in CBHCs and occupational therapy practitioners (with their unique skill set that you will describe in your letter) should be a part of the staffing requirements.

Sending Comments

Each submission must include the Agency name (SAMHSA) and the docket number (2014-25822) for this notice.

Comments are due by 5 PM Eastern Time on Wednesday, November 26, 2014.

  • Email is probably easiest. Send your comments to section223feedback@samhsa.hhs.gov
  • If you would like to send comments by mail, hand delivery or fax, here’s how:
    • Mail: The Substance Abuse and Mental Health Services Administration, 1 Choke Cherry Road, Rockville, MD 20857, Room 6-1019. Attn: Certified Community Behavioral Health Clinic Comments
    • Hand Delivery or Courier: 1 Choke Cherry Road, Rockville, MD 20857, Room 6-1019 between 9 a.m. and 5 p.m., ET, Monday through Friday, except federal holidays.
    • Fax: 1-240-276-1930 Attn: Certified Community Behavioral Health Clinic Comments

Please help make a positive difference in the future of Americans living with mental health concerns and write a comment for SAMHSA by November 26! And please comment and let me know if you do!

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3 thoughts on “Occupational Therapy in Mental Health: SAMHSA Listening Session and Comments (November 12-26, 2014)

  1. Laura Collins November 12, 2014 at 3:24 pm Reply

    Hi, I apologize for commenting again–perhaps the last one didn’t go through? This is a great summary of the SAMHSA information, but the image we purchased for use on the AOTA website has a limited license. We don’t own the copyright, so we can’t allow additional uses. SAMHSA may have a royalty free image you can use, or you can probably do a search to find one online that’s also free. In the meantime, the one from AOTA’s website should be removed from here. Thank you! Laura Collins, AOTA communications director.

    • lej1123 November 12, 2014 at 7:54 pm Reply

      Thank you for letting me know! I changed the photo.

  2. […] in November, I wrote about occupational therapy’s role in mental health, specifically the profession’s advocacy for occupational therapy’s inclusion in the Substance […]

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