It appears Ottawa County taxpayers and the Ottawa County Community Mental Health (CMH) board have been misled. Through the Mental Health Millage Specialized Residential Financial Assistance Program, seven participating organizations received $1,754,152 of funding. The board and taxpayers were told that this Mental Health Millage money was needed to ‘cover gaps in the system’ for a few of the largest adult foster care (AFC) providers. In reality, it is more likely the money is being used to meet the requirements and support the creation of infrastructure, required to transition to the Certified Community Behavioral Health Clinics (CCBHC) model of socialized health care.
CMHOC produced a video associated with the Mental Health Millage labeled Specialized Residential Stabilization Programs. The video tugs at the heartstrings. It shows specialized intellectual and developmentally disabled (IDD) residents receiving routine care from community living supports (CLS) providers. This is strange because this type of care is covered with Medicaid funding, and it is against the law to supplement Medicaid services.
In both 2022 and 2023, Mental Health Millage money was allocated for specialized residential services.
Specialized residential is a broad term that covers several different types of living situations where people are given “specialized” living assistance. Specialized residential refers to care that lasts longer than one night, but includes both temporary and permanent situations. Some examples of specialized residential housing include housing for:
Elderly people who can no longer live independently.
Intellectually and Developmentally Disabled (IDD) people who need assistance with daily activities.
People with chronic health conditions at risk for developing additional conditions.
People struggling with severe mental illness.
People struggling with addiction.
People going through crisis situations.
The last four items on the list above also meet the definition for a Health Home. Health Homes are defined under the Affordable Care Act Section 2703. Health Homes are for states to provide comprehensive care coordination for Medicaid beneficiaries. According to the Primary Care Collaborator, Michigan has three different types of health home models.
Severe Mental Illness (SMI) health homes created in 2014
Chronic Conditions health home created in 2016
Opioid treatment health home created in 2018
Health Homes were mentioned in connection with CCBHCs in the April 25, 2016 CMHOC board meeting minutes.
One Ottawa County resident referred to Health Homes during the July 24, 2023 Community Mental Health board meeting public comment.
(45:48) “So are the crisis homes the same as the specialized residential stabilization programs that are funded by the millage? That is where the money is repeatedly given; to the largest non-profit corporations. So, way back in the board notes in 2016, it said that the CCBHC initiative was about health homes. So, I Googled what a health home was. Health homes are behavioral health homes or opioid homes. So, I was wondering, is that what the specialized residential programs have been all along? Are these behavioral health homes and opioid homes?
And then I looked at one of the specialized residential websites for specialized residential, and they listed behavioral health homes as low, moderate, and high. So, I really urge, that the CMH board take a deep dive into the adult foster care system, and see which homes are millage homes, and which homes are protected by the home and community-based waivers. Because if these specialized residential homes are under the millage, who's regulating these? Is Brianna regulating these homes as if they're under the Medicaid rule, or is this under the CMH board?”
There are different types of people who provide care to others in specialized residential living facilities known as direct care workers (DCW). Although sometimes care is given by a family member, sometimes these same types of care givers provide assistance to people living in private residences. Examples of different types of direct care workers include:
Respite – Respite care workers are like babysitters. They provide temporary breaks for regular care givers.
Community Living Supports (CLS) – These workers help people live as normally as possible within the community. There are three main categories covered by CLS. The first includes assistance with routine daily activities such as bathing, meal preparation and laundry. The second includes assistance with less routine activities such as money management and participation in community social events (movies, concerts, etc). The third includes assistance with special health and safety needs of individuals. CLS workers are commonly paid for by Medicaid when it is determined medically necessary, and helps an individual to live inclusively within the community.
Crisis – Crisis workers are specially trained to deal with breakdown situations.
Individuals who receive Medicaid are covered by a variety of different plans. Depending on an individual’s needs and the plan that they are enrolled in, they may be entitled to receive the supports described above regardless of whether or not they are in an institutional setting. In most cases care given by CLS workers is covered by Medicaid plans, but Medicaid is not likely to cover crisis services. Crisis services are however, an integral component of CCBHCs. CMHOC has been working towards establishing a CCBHC model of socialized health care since 2016 as referenced above in the board minutes.
One requirement of CCBHCs is inpatient services such as psychiatric treatment, detoxification, and crisis care for consumers. It appears these payments were not intended to supplement Medicaid services, but rather to fund CCBHC services such as the crisis residence. There is a lot of evidence that suggests taxpayers and the CMH board have been misled to believe the payments from the mental health millage to the group home providers were improving existing programs for IDD consumers, when they are likely being used to support the establishment of the infrastructure necessary for CCBHC service model certification.
This leads to so many questions.
What specific ‘gaps in the system’ is this funding covering?
Are the crisis homes the same as health homes, and the same as the specialized residential stabilization programs?
Does the CCBHC model encourage an increase in dual diagnosis patients?
Is the mental health millage funding the creation of a socialized system of care?