The Honorable Caroline Menjivar Chair, Senate Health Committee 1021 O Street, Room 3310 Sacramento, CA 95814
RE: MHAC Support for SB 306 (Becker)
Dear Chair Menjivar,
Mental Health America of California (MHAC) is pleased to support Senate Bill 306 (Becker), legislation that would exempt commonly approved healthcare services from requiring prior authorization.
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.
Commonly covered mental health and substance use services include various forms of therapy or counseling and medication management. This bill ensures that health plans that approve 90% or more of prior authorization requests for a given service in the previous year must exempt that service from prior authorization for the following year. This will help streamline access to commonly utilized mental health and substance use services and ensure more timely care.
It is for these reasons MHAC supports SB 306 (Becker) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
The Honorable Caroline Menjivar Chair, Senate Health Committee 1021 O Street, Room 3310 Sacramento, CA 95814
RE: Support for Senate Bill 338 (Becker)
Dear Chair Menjivar,
Mental Health America of California (MHAC), the California Youth Empowerment Network (CAYEN) and LGBTQ+ Inclusivity, Visibility, and Empowerment (LIVE) are pleased to support Senate Bill 338 (Becker), legislation that would establish the Mobile Health for Rural Communities Pilot Program with the goal of increasing access to health services, including mental health, for rural communities.
MHAC, CAYEN, and LIVE are dedicated to advancing mental health, wellness, and equity through community-led advocacy, education, and empowerment. By centering the voices of those with lived experience, including youth, LGBTQ+ individuals, and people living with mental health and substance use challenges, we aim to reduce stigma, influence public policy, and create inclusive environments where everyone has access to vital community-based culturally responsive mental health and substance use supports and services.
Access to these services is extremely challenging for individuals in the rural communities, especially youth and the LGBTQ+ community. People often travel for hours for in-person services. Additionally, rural communities lack the appropriate internet infrastructure to support telehealth or virtual services. Senate Bill 338 (Becker) invests in mobile health, bringing services directly to communities in need, reducing barriers to access in-person and virtual health services.
It is for these reasons MHAC, CAYEN, and LIVE support SB 338 (Becker) and respectfully ask for your “Aye” vote. If you have any questions or need further assistance, please do not hesitate to contact MHAC’s Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org, CAYEN’s Public Policy Coordinator Danny Thirakul at dthirakul@mhac.org, or LIVE’s Project Manager Anthony Garibay-Mena at agaribaymena@mhac.org.
In Community,
Heidi L. Strunk President & CEO
Danny Thirakul California Youth Empowerment Network Public Policy Coordinator
Anthony Garibay-Mena LGBTQ+ Inclusivity, Visibility, and Empowerment Project Manager
The Honorable Jesse Arreguín Senate Public Safety Committee 1020 N Street, Room 545 Sacramento, CA 95814
RE: Support for Senate Bill 691 (Wahab)
Dear Chair Arreguín,
Mental Health America of California (MHAC) is pleased to support Senate Bill 691 (Wahab), legislation that would require guidance to law enforcement personnel who wear body-worn cameras to limit the recording of medical or psychological evaluations, procedures, or treatment that may cause embarrassment or humiliation to the patient. The bill would also require a procedure for emergency service personnel to request the redaction of evidentiary recordings of a patient undergoing medical or psychological evaluation, procedure, or treatment.
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. The types of services and supports individuals receive during a mental health crisis require trust, rapport with providers, and an assurance of confidentiality.
People experiencing a mental health crisis are often in an immensely vulnerable, isolating, and sometimes life-threatening situation. In the event an individual must be forced into treatment, their right to privacy must be prioritized and upheld. Furthermore, recordings and sharable videos of individuals without their consent during moments of crisis may be used to further inflame and stigmatize individuals during assessments or conservatorship investigations. These potentially singular moments of crisis should not be used to define the entirety of an individual’s journey towards wellness.
MHAC is committed to reducing stigma and empowering individuals to seek and accept support and services for mental health challenges. A moment of crisis should not define them or prohibit their ability to establish a path towards recovery that works for them. It is for these reasons MHAC supports SB 691 (Wahab) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
The Honorable Mia Bonta Assembly Health Committee 1020 N Street, Room 390 Sacramento, CA 95814
RE: MHAC Support for Assembly 1032 (Harabedian)
Dear Chair Bonta,
Mental Health America of California (MHAC) is pleased to support AB 1032 (Harabedian), legislation that will allow health plan enrollees to be reimbursed for up to 12 visits with a behavioral health provider if they reside in a county where a state of emergency has been declared due to wildfires.
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.
During moments of crisis, especially ones brought about from natural disasters such as wildfires, access to the proper support and services can be extremely difficult. The recent Los Angeles fires have displaced hundreds of thousands of people without proper access to critical mental health and substance use supports. The American Addiction Centers notes that natural disasters often lead to increased substance use.[1] As displaced individuals attempt to access mental health and substance use supports and services, cost and insurance coverage should not prevent them from accessing care.
This bill ensures that individuals who experience a crisis due to a natural disaster, specifically wildfires, can receive critical care without the cost becoming a barrier to access. It is for these reasons MHAC supports AB 1032 (Harabedian) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
The Honorable Mike Fong Assembly Higher Education Committee 1020 N Street, Room 173 Sacramento, CA 95814
RE: MHAC Support for Assembly Bill 602 (Haney)
Dear Chair Fong,
Mental Health America of California (MHAC) is pleased to support AB 602 (Haney), legislation that would establish a harm reduction approach to supporting students who are experiencing substance use crises by protecting them from punitive academic disciplinary policies.
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. People experiencing a mental health or substance use crisis need to be able to seek help without fear of repercussions.
For youth, colleges and universities can impose various punishments on students found with drugs or involved in overdose incidents. While some CSU and UC campuses have medical amnesty policies, most only protect students in alcohol-related emergencies, not drug overdoses. Additionally, a disciplinary record can make it harder to transfer, graduate, or find a job, as many employers and professional licensing boards ask about academic misconduct.
The inconsistent implementation of these policies creates confusion and fear, leaving students afraid to call 911 in life-or-death situations. No student should have to choose between saving a life and risking their future. Without a clear, statewide policy, students fear severe consequences for seeking medical help, leading to dangerous delays in life-or-death situations. This bill will protect students involved in overdose emergencies by ensuring they are fully shielded from academic penalties.
This bill guarantees that neither the student experiencing an overdose nor bystanders who summon help will face any academic consequences. Students will no longer be punished for surviving an overdose, and the fear of severe academic penalties will no longer prevent them from seeking life-saving assistance. It is for these reasons MHAC supports AB 602 (Haney) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
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.
Attn: Stesha Hodges, Assistant Chief Counsel, Kayte Fisher, Attorney V
Health Equity and Access Office 300 Capitol Mall, Suite 1700 Sacramento, CA 95814
Via email <CDIRegulations@insurance.ca.gov>
Re: Mental Health and Substance Use Disorder Coverage Requirements, Article 15.2 (commencing with section 2652.1) of Subchapter 3 of Chapter 5 of Title 10 of the California Code of Regulations, pursuant to the authority granted by Insurance Code sections 10144.4, 10144.5, 10144.51, 10144.52, 10144.53, and 10144.57
We thank the California Department of Insurance for its ongoing progress towards finalizing its Mental Health and Substance Use Disorder Parity in Health Insurance Rulemaking (REG-2021-00008), to implement Senate Bill 855 (Wiener, Chapter 151, 2020) and Assembly Bill 988 (Bauer-Kahan, Chapter 747, 2022). We are grateful for the Department’s continued engagement with us on numerous issues related to implementation of the law and its drafted regulations. The Department’s proposed Rule lessens the possibility that disability insurers will exploit ambiguities to inappropriately limit insureds’ access to mental health and substance use disorder (MHSUD) care.
We encourage this comprehensive Rulemaking to be finalized as soon as possible and offer support for the Department’s April 3, 2025 additions to its drafted Rulemaking dated May 24, 2024. Specifically, we are supportive of the following key additions, as currently drafted:
Network adequacy monitoring. We support the Department’s added clarity as to what an insurer needs to do once someone has requested assistance identifying a health care provider including by adding that if an insurer cannot identify more than three in-network providers, that it must refer the person to those three and notify the Department of the service requested, type of provider, and location. This is an important mechanism for ensuring the Department has proactive insight into possible weakening parts of networks that could lead to or show existing network inadequacies. We applaud the Department for this forward-thinking change which we believe will protect insureds.
Defining coordinated specialty care. Providing a definition of Coordinated Specialty Care makes it much harder for insurers to deny or partially deny medically necessary services for individuals experiencing first and early episodes of psychosis. We applaud the Department’s further defining of these life-saving but seldom reimbursed services.
We encourage the swift promulgation of comprehensive regulations. Once promulgated, we encourage the Department to issue notices, bulletins, and/or general opinion letters regarding particular areas of enforcement concern. Our organizations stand ready to assist you in the identification of MH/SUD access issues and comprehensive implementation of the Rule in any way we can.
If you have any questions, please contact Lauren Finke (lauren@thekennedyforum.org). For matters requiring physical or printed communication, please send to 1121 L Street, Sacramento, California 95814 suite #300.
Sincerely,
Adrienne Shilton California Alliance of Child and Family Services
Robb Layne California Association of Alcohol and Drug Program Executives, Inc
Joy Alafia California Association of Marriage and Family Therapists
Chad Costello California Association of Social Rehabilitation Agencies
Carli Stelzer California Behavioral Health Association
Tyler Rinde California Psychological Association
Paul Yoder California State Association of Psychiatrists
Danny Thirakul California Youth Empowerment Network
The Honorable Caroline Menjivar Senate Health Committee 1021 O Street, Room 3310 Sacramento , CA 95814
RE: OPPOSE Senate Bill 367 (Allen)
Dear Chair Menjivar,
Mental Health America of California (MHAC) respectfully opposes Senate Bill 367 (Allen), which would expand Lanterman Petris Short (LPS) Act involuntary commitment and conservatorship statutes by: 1) Requiring information about the historical course of a person’s medical, psychological, educational, social, financial, and legal conditions to be included in the assessment for an involuntary hold; 2) Authorizing conservatorships for people who have accepted voluntary care; and 3) Expanding the list of individuals or entities that can recommend conservatorship. These expansions of current law will risk infringing on peoples’ civil rights by inappropriately increasing conservatorships.
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. In accordance with our mission, MHAC supports increasing the availability of voluntary, accessible, culturally responsive, community-based services.
MHAC is opposed to SB 367 for the following reasons:
Requiring information about the historical course of a person’s medical, psychological, educational, social, financial, and legal conditions to be included in the assessment for an involuntary hold is an egregious and inappropriate expansion of involuntary commitment statute. Current law requires information on the historical course of a person’s mental disorder be considered only if it is determined that the information has a “reasonable bearing” on whether the individual meets criteria for involuntary treatment. Furthermore, current statute specifies limited sources of the historical information.[1] In contrast, SB 367 requires information on the historical course of a broad range of factors that are not relevant to an immediate mental health crisis, including educational, social, financial, and legal. We struggle to understand how the historical course of an individual’s education, for example, bears on their potential status as currently gravely disabled. Requiring this information in assessments risks wrongful involuntary commitments based on bias and prejudice rather than immediate mental health needs, and threatens the privacy of the individual. Furthermore, by not limiting or specifying the sources of this information, the bill would create excessive burdens on evaluation staff who are now required to collect this historical information.
Allowing conservatorships for individuals who have “demonstrated an inability to follow through with stated plans of self-care” is untenably broad and will likely result in wrongful conservatorships. Self-care is a term that can encompass a wide range of activities, including simple things like getting outside, getting enough sleep, meditating, etc.. Moreover, “stated plans” is a vague term that implies an unwritten expression of self-care goals.
Conservatorships remove individuals’ rights, autonomy and self-determination and should only be used when absolutely necessary and only after significant evaluation of the individual’s mental health. SB 326 expands authority to recommend conservatorships to a judicial officer, a treating physician or an emergency physician. These individuals are not likely to have sufficient knowledge of an individual’s mental health history to make an accurate conservatorship recommendation, which runs the risk of inappropriately increasing unnecessary conservatorships.
It is for these reasons MHAC is opposed to SB 326 (Allen). If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
The Honorable Caroline Menjivar Chair, Senate Health Committee 1021 O Street, Room 3310 Sacramento, CA 95814
RE: Support for Senate Bill 418 (Menjivar)
Dear Chair,
Mental Health America of California (MHAC) is pleased to support Senate Bill 418 (Menjivar), a bill that would prohibit discrimination or a denial of benefits from a health plan or insurer based on race, color, national origin, age, disability, or sex with specific protections for the LGBTQ+ community.
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.
As healthcare institutions face increasing scrutiny from the federal administration for providing gender-affirming care, denials of such care are expected to rise unless specific protections are established. These denials include limiting access to essential services and adopting policies that restrict or exclude the LGBTQ+ community from receiving gender-affirming care.
This bill strengthens protections for the LGBTQ+ population by explicitly defining discrimination based on sex to include sex characteristics, pregnancy and related conditions, sexual orientation, gender identity, and sex stereotypes. Ensuring access to gender-affirming care is critical for the well-being of transgender individuals, as it provides access to necessary medical, mental health, and substance use services and supports. According to The Trevor Project, there has been a 72% increase in suicide attempts among transgender youth due to the rise in anti-transgender laws.[1] These laws attempt to erase the existence of the transgender community by denying access to direct services and critical care.
Everyone deserves access to essential services and support. It is for these reasons MHAC supports Senate Bill 418 (Menjivar) and asks for your “Aye” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me at hstrunk@mhac.org or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
The Honorable Caroline Menjivar Senate Health Committee 1021 O Street, Room 3310 Sacramento, CA 95814
Re: MHAC Opposition to Senate Bill 823 (Stern)
Dear Chair,
Mental Health America of California is writing to oppose SB 823 (Stern), legislation that would add Bipolar I Disorder to the criteria for a person to be petitioned into CARE Court and forced into involuntary treatment. CARE Court represents an ineffective approach to mental healthcare in California. It fails to address the systemic barriers individuals face and, in some cases, comes at the cost of their civil liberties.
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.
The primary barriers to accessing mental health services include a shortage of providers, stigma, and lack of voluntary services and supports. Investing in the behavioral health workforce, reducing stigma through community engagement, and voluntary community-based services has proven to prevent mental health crisis, reduce hospitalizations, institutionalization, and incarceration.[1] In contrast, CARE Court fails to address the provider shortage, inadvertently increases stigma due to its court-based setting, and provides no additional funding to increase mental health services and supports beyond what’s currently available.
The ineffectiveness of CARE Court is demonstrated in the enrollment numbers. When San Francisco rolled out CARE Court in 2023, city officials projected approximately 2,000 eligible individuals, but only 11 referrals were made.[2] The Department of Health Care Services also released its Early Implementation Report in November of 2024 which recorded a total of 100 Care Court participants, yet state officials estimated 7,000 to 12,000 people would be eligible.[3][4] One of the primary reasons for the low enrollment is due to the many respondents who are receiving care voluntarily or receiving supports and services in a different way other than CARE Court. This further supports the idea that when voluntary supports and services are available, people will accept them.
The state’s failure to meet expectations shows an inherent flaw in the system that won’t be solved by expanding the criteria of who can be forced into treatment via a court order. For these reasons MHAC opposes SB 823 (Stern) and asks for your “No” vote. If you have any questions, or if MHAC can provide any assistance on this bill or any behavioral health legislation, please do not hesitate to contact me or our Director of Public Policy, Karen Vicari, at kvicari@mhaofca.org.
