The North Carolina Coalition on Mental Health, Developmental Disabilities and Substance Use Services submitted the following comments regarding the North Carolina Draft Olmstead Plan on November 8, 2021: The Coalition Olmstead Plan public comments FINAL

The following is public comment regarding the Draft Olmstead Plan released by the North Carolina Department of Health and Human Service (NCDHHS) on October 12, 2021. Many members of The Coalition served as Olmstead Plan Stakeholder Advisory Members from the Consumer, Family and Advocacy Group Representatives.
The Coalition supports all eleven priority areas in the Draft Olmstead Plan. These priorities are critical in order for all people with disabilities to choose a life that is fully included in the community.
The Coalition respectfully submits the following comments:
● The Coalition appreciates the inclusion of community stakeholder voices in the 18-month planning process as members of the Olmstead Plan Stakeholder Advisory Committee. However, there was a significant lack of stakeholder input and recommendations that made it to the Draft Plan.
● The Coalition has concerns the Draft Plan is a “living document”. It is reasonable for a plan to be adjusted as circumstances change but the draft plan does not project a result where service system can support people in the community. The Draft Plan is a reactive plan instead of proactive roadmap for success that lacks structured tasks and activities that lead to meaningful change. As stated by TAC: “A plan to plan is not a plan.”
● The Draft Plan lacks an overall roadmap for shifting funding from institutional to community-based services including the reallocation of spending.
● The Draft Plan does not address the specific funding that The Coalition has included in our submitted budget recommendations to the North Carolina General Assembly and the NCDHHS for a number of years. See Attachment 1.
● In order for North Carolina to successfully serve individuals with disabilities, a robust provider network is essential. The Draft Plan does not address network adequacy nor outline a strategy for developing and sustaining a strong network of providers to treat and support those with complex needs.
● The Draft Plan does not include whole person care. Given that North Carolina has just transitioned to Medicaid Managed Care and will begin the Tailored Plans in January 2022, integrated health services should be included in this plan.
● The Draft Plan does not address currently incarcerated individuals. There continues to be a large number of persons incarcerated in the NC prison system who need behavioral health services. Mentally ill patients are disproportionately housed in segregation cells, for behavior related to their mental illness, not the intent of such units. Segregation exacerbates mental illness and increases cost to the state-higher cost per inmate and longer sentences.
● The draft plan has too little emphasis on proactive diversion strategies. There are many but a few would include:
● Critical Time Intervention (CTI) for individuals accessing psychiatric crisis services two or more times in a three month period.
● Transitional Crisis Homes with provider daily involvement Monday – Friday with root cause assessment, treatment planning and intervention.
● Community Assessment and Response to Expedite Services (CARES). Staff with licensed mental health professional to reduce barriers to care in order to assist with linking youth and families quickly to clinically appropriate services following a crisis event by offering community-based after-hours assessments and referral
and successful linkage to services. Program to assess the individual and family needs from a whole person perspective.
● Co-responder mental health professionals working closely with EMS and Police Officers.
● CAHOOTS Model – Social Worker, Nurse/EMT response alternative to police response.
● Expansion of PATH services for the homeless.
● Broader consideration in how we address Social Determinants of health; including $15 minimum wage, affordable housing and Medicaid expansion.

Individual Coalition Member Organizations will also be submitting public comment.