November 26, 2025
Quality and Equity Advisory Committee (QEAC)
California Department of Health Care Services
1501 Capitol Ave #6001
Sacramento, CA 95814
Re: Feedback on Performance Measures
To Whom It May Concern,
Mental Health America of California (MHAC) provides the following feedback on the Behavioral Health Transformation (BHT) Performance Measures:
Improving Access to Care, Reducing Untreated Behavioral Health Conditions, and Improving Care Experience:
Improving Care Experience
In addition to the listed performance measures, we recommend that performance measures also include the collection of data on the rates of providers and staff completing various cultural competency trainings related to race, religion, ethnicity, or sexual orientation, etc. The data should not just reflect what individuals experience but what providers and staff are doing to improve care experience.
Intervention Measures
BH-12 should be separated into 2 different measures: one for adults and one for adolescents. Parents or guardians are more likely to ensure care for their dependents than an adult is to care for themselves. The combination of the age groups has the potential skew the data.
Reducing Justice Involvement
Goal Measures
We recommend that the performance measures listed be expanded to separately measure adults and youth who are justice-involved. Justice involved youth have higher recidivism rates than adults. By separating performance measures on youth, long term behavioral healthcare strategies can be developed to reduce justice involvement at the earliest possible instance, significantly reducing recidivism as youth age into adulthood.
If you have any questions, or if MHAC can provide any assistance, please do not hesitate to contact me at kvicari@mhac.org or our Public Policy Coordinator, Danny Thirakul, at dthirakul@mhac.org.
In Community,
Karen Vicari
Director of Public Policy
Mental Health America of California
