NJAMHAA Statement on Proposed Move of DMHAS to DOH

July 11, 2017

On June 29, Governor Christie sent the New Jersey Legislature a Reorganization Plan (Plan) that would transfer the Division of Mental Health and Addiction Services (DMHAS), in its entirety, from the Department of Human Services (DHS) to the Department of Health (DOH). The rationale in the Plan points to the "substantial body of research" supporting integrated care, argues that there could be cost-savings, and asserts that "only through… a public health approach can we overcome the stigma that for too long has characterized efforts to treat addiction". The Plan states that "DOH is best positioned to identify risk factors for addiction and mental health problems…, increase awareness about prevention and treatment, remove the stigma associated with receiving behavioral health treatment, address health disparities, and improve access to mental health and addiction services for all persons".

The New Jersey Association of Mental Health and Addiction Agencies (NJAMHAA) has long supported, and worked toward, integrated care. The physical comorbidities that plague the population served by our members and have left them with a 25 to 37 year shorter life expectancy demands it. NJAMHAA has also held that "mental health is health", and participated in anti-stigma campaigns throughout its history. The rationale presented in the Plan matches these positions. However, serious concerns about the Plan cannot be ignored.

Last week, Legislative Counsel reached out to NJAMHAA for feedback on the proposed plan (which we were directed not to share at the time). NJAMHAA expressed both its support for integrated care and concerns about the proposed Plan, which were reiterated by NJAMHAA President and CEO Debra L. Wentz, Ph.D. in interviews on July 10 with both NJ Advance Media and NJ Spotlight and on July 11 with radio station WBGO . On Monday, Dr. Wentz also restated those concerns in a conversation with DOH Commissioner Cathleen Bennett. The Commissioner was both very positive and very open to hearing more about NJAMHAA's concerns. NJAMHAA is currently working to schedule a meeting with her.

The two equally most disconcerting aspects of the Plan are the timing of the move and the disconnect from the Division of Medical Assistance and Health Services (Medicaid). The community based behavioral system is just now transitioning to fee-for-service. Staff have been laid off, psychiatric time has been reduced, and changes have been made to business models - yet many agencies are still facing deficits for the current year. Undertaking another major systemic change while there is already such uncertainty and difficulty could be a significant disruption to addressing ongoing transition issues. We are concerned that the staff disruption caused by physical and administrative moves, potential layoffs, job-shifting, etc. cannot be afforded at this critical juncture.

Moving DMHAS without moving Medicaid would be a serious setback. Medicaid is an integral component of the community based system of care and the major player and payor in the current transition to fee-for-service. Our members' programs are, for the most part, licensed by DMHAS, but they also hold Medicaid licenses (in order to be able to bill Medicaid) and must adhere to Medicaid regulations throughout their programs. Because of the full involvement of both Divisions in mental health and substance use treatment programs, the majority of meetings that NJAMHAA holds with DMHAS include senior staff from Medicaid. DHS also established a number of new positions for senior staff to serve as a bridge between Medicaid and DMHAS. These strong collaborations, overlapping experiences and historical knowledge are vital to seeing the community based system of care maintained, especially during these early stages of transition.

There are other concerns, as well. True integrated care happens at the consumer level. For instance, NJAMHAA has been advocating for several years for changes to regulations that would allow agencies to more easily bring primary care services to their clients. Breaking down barriers to that would have a much more immediate impact on those served. While a move such as is proposed could be logical, it should be done in a planful manner with extensive input from all stakeholders, legislators and the public.

The Plan should appear in the New Jersey Register on July 17 at which time NJAMHAA will share information on how comments can be submitted during the 60 day comment period. The Legislature has the same 60 days to consider the plan and stop it with a Joint Resolution, should they so desire. If no such Resolution is passed, the plan will go into effect immediately. Legislative hearings are expected to be scheduled and NJAMHAA will keep you apprised of those dates, once known, and continue to provide updates on the Plan and reaction to it.

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