April 25th, 2025
Department of Health Care Services
Behavioral Health Transformation
1501 Capitol Ave
Sacramento, CA 95814
RE: Behavioral Health Services Act County Policy Manual Module 3
To Whom It May Concern,
Mental Health America of California (MHAC) is a peer-run organization leading the state in behavioral health public policy and advocacy since 1957. The mission of MHAC is to assist and encourage communities, families and individuals to experience hope, wellness and recovery from mental health and substance use disorder issues through voluntary services that are delivered in their local community with compassion and respect for everyone’s dignity and autonomy. Below are MHAC’s recommendations regarding the proposed Behavioral Health Services Act County Policy Manual Module 3.
Section E.2.1 IP Requirements
Recommendation #1: Add language encouraging meaningful stakeholder engagement in annual updates.
Reasoning: Although the Behavioral Health Services Act (BHSA) does not require a full stakeholder process for annual updates, language in the Act implies ongoing involvement of stakeholders. For instance, Welfare & Institutions Code Section 5892 (e) (1) (A-C) requires counties to include funding for annual planning costs to fund stakeholder participation:
(e) (1) (A) Notwithstanding subdivision (a) of Section 5891, the allocations pursuant to subdivision (a) shall include funding for annual planning costs pursuant to Sections 5963.02 and 5963.03.
(B) The total of these costs shall not exceed 5 percent of the total of annual revenues received for the Local Behavioral Health Services Fund.
(C) The planning costs shall include funds for county mental health and substance use disorder programs to pay for the costs of consumers, family members, and other stakeholders to participate in the planning process.
Additionally, Welfare & Institutions Code Section 5963.03 (a)(2)(A)(i) retains original MHSA language which states:
(2) (A) (i) A county shall demonstrate a partnership with constituents and stakeholders throughout the process that includes meaningful stakeholder involvement on mental health and substance use disorder policy, program planning, and implementation, monitoring, workforce, quality improvement, health equity, evaluation, and budget allocations.
Meaningful stakeholder involvement in processes such as program planning, implementation, quality improvement and evaluation are not one-time processes that can occur once every three years, these are ongoing processes that must be implemented throughout a 3-year period as programs are rolled out and eventually evaluated.
Recommendation #2: Strengthen the language in this section to clearly state that the local agency must “provide an annual report of written explanations to the local governing body and the department for substantive recommendations made by the local behavioral health board that are not included in the final integrated plan or update.”[1]
Reasoning: This is a key section of the BHSA which ensures that Behavioral Health Board (BHB) recommendations are carefully considered. Behavioral Health Board meetings are an open and transparent forum for stakeholder involvement and their impact in the planning process should be maintained.
Section E3.4 Exemption Approval
Recommendation # 3: The manual should state that DHCS will provide counties with specific feedback on why exemption requests are denied.
Reasoning: Exemptions will allow counties to more effectively plan for services that meet local needs. Clarity in how to obtain these exemptions is vital.
Section E4.2 DHCS Review Standards
Recommendation #4: Require BHB review of revised IPs that are found to inadequately address local needs.
Reasoning: The Draft Module 3 states that DHCS may require counties to revise their IP if it fails to address local needs, including prevalence of mental health and substance use disorder and unmet need for mental health and substance use disorder treatment in the county, among others. Revisions to an IP for reasons as substantive as failing to address local needs should be subject to some form of stakeholder review. The input of stakeholders who are intricately involved in the system is vital to ensuring the appropriate use of funds to address local needs and BHB review would provide the opportunity for stakeholder input into revised IPs without unduly burdening the local agency.
E.5.3 Approval Process for Joint Integrated Plans
See recommendation #2
We ask these recommendations be included in the final version of the Behavioral Health Services Act County Policy Manual Module 3. If you have any questions, or if MHAC can provide any assistance regarding the implementation of the Behavioral Health Services Act please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
In Community,
Heidi L. Strunk
President & CEO
[1] WIC Section 5963.03 (b)
