The CSA's are an interesting component of the proposed Rose D remedy; they have some questions about them as well:
1. Do you have any comments or suggestions about the number or configuration of Service Areas?
Combining South Central Worcester County and the Blackstone Valley is a mistake; the distance from Wales to Bellingham is about 40 miles, over 2 lane roads, without public transportation. The large area includes 3 community hospitals, one of which is quite small, and only one local agency capable of performing the tasks requested in the settlement. Several aspects of service delivery, including rapid response team and home based therapy, will be very difficult to deliver over such a wide service area. We would recommend that the CSA be split into two separate regions.
2. Do you have any comments or suggestions about the proposed scope of CSA services?
The scope of services for the CSA is a little confusing; by specifying that the services be provided by an subcontractor, but delivered within the MCE (and subject to review by the MCE), it seems to me that you are setting up barrier to care. The CSA really needs to be empowered to authorize levels of service for this to work quickly, at least within MassHealth. For example:
A new patient (Rosie C) is found eligible for services for bipolar disorder. Her mental health provider MCE-A refers her to their subcontractor CSA-A, who works with the family and determines that her needs include family and individual therapy, therapeutic day-school, respite care and psychopharm services. The CSA-A sends this plan to the MCE-A for review, and convenes the team meeting. The school disagrees with their part of the plan, DMH has trouble with the respite portion of the plan, noone can find a child psychiatrist in plan and all beg the pediatrician to keep prescribing the meds while they sort this all out. The CSA-A then asks the MCE-A to go out of plan to find a psychopharmocologist. After 2 months of meetings, none of the needed services are authorized or running.
Unfortunately, the CSA can't have control over DMH or DOE resources; the least we can do is give them some authority over the MassHealth portion of the package. Otherwise, we are are just adding another layer of bureaucracy.