NEW JERSEY PSYCHIATRIC REHABILITATION ASSOCIATION
Quarterly Dialogues with NJ Department of Human Services
Issues Discussion Guide and Progress Monitor
DRAFT v.2.1
as of March 21, 2016
This document is organized by the following categories of interest to NJPRA
I.
Workforce Development
Issues relating to the recruitment, training, and development of the behavioral health workforce, including psychiatrists,
psychologists, nurses, social workers, peer providers, and direct care staff in state hospitals, private hospitals, and communitybased agencies and programs.
II.
Agency Development
Issues relating to operations of institutions and behavioral health agencies, such as business, finance, marketing,
compliance, and administration.
III.
Sector Development
Issues relating to the economics and administration of the entire behavioral health sector, such as rate setting, service
delivery standards and regulations, Medicaid expansion, ACA implementation, Medicaid State Plan waivers, and general public
policy matters.
IV.
Practice Development
Issues relating the science and practice of psychiatric rehabilitation, such as dissemination of the evidence-based and
promising mental health practices, research, education, credentialing (especially CPRP), and certification.
V.
Client/Consumer/Family Development
Issues relating to the care and concerns of individual service recipients and their families, such as financial supports, other
supports, stigma, violence, burden, confidentiality, case management, and legal matters.
VI.
Government Development
Issues relating to individual entities of the state government engaged in whatever way with mental health issues, including
health, finance, housing, programs, education, training, law, and funding.
Issue
Description
Response
Position
Priority
I. Workforce Development
A. COLA
Governor proposes 0.5% for
all non-profits for 2013.

BH workers: no COLA
increase in 6 years.[1]


PsyR workers earn less
[What is the average PsyR
1
PsyR providers deserve
at least a “living wage”.[1]
A
Progress (as of Aug. meeting)
Issue
Description
Response
than OT workers.
1. Use of statistics
DMHAS is using statistics
such as the median and not
the mean of costs of
agencies statement [Stivale].
Position
Progress
wage now in NJ?]

For most PsyR workers,

0.5% COLA is like a
bonus of only $150, or $3
per week, the cost of a
cup of coffee…[Barrett] [2]

“Livable wage”: hrly wage
or annual inc necessary to
cover basic household
needs plus all relevant
taxes while maintaining
economic independence
from publicly provided
income and housing
assistance.[3]

Living wage in NJ: 1 adult
= $11.13 per hr. Family of
4 = $21.17 per hr.[4]

Avg wage of NJ
“healthcare support” =
$12.61, BELOW a living
wage for family of 4.[4]
The process is not
transparent. The use of
median is not explained or
justified. The wide cost
variability between northern
and southern New Jersey is
not taken into account.
Priority
2013: Provide COLAs
equal to those of state BH
workers.

The Division should make
its statistical processes
more evident to the
stakeholders.

The Division should
establish regional rate
differentials rather than
2
Issue
Description
Response
Position
Priority
Progress
applying one standard to
the whole state.
B. Training
1. State hospital workers
2. PsyR Professional
Education in NJ
State hospital direct care
workers = 65% of face time
with patients. HST/HSA min.
ed. req’t in NJ = not even
high school diploma.[5]
NJ’s least educated are
caring for NJ’s most
vulnerable.
UMDNJ/Rutgers has one of
the nation’s best PsyR
education programs at all
degree levels. It is unique in
the breadth, depth, and
quality of its work.
The UMDNJ/Rutgers
program has positive and
immediate impact on PsyR
careers.[7]
Those doing clinical work are
licensed by the Dept Law &
Public Safety Div of
Consumer Affairs. Requirements [8]:
NJ has among the most
restrictive licensing
requirements for social
workers. Stringent licensing
requirements make more
difficult the recruitment and
retention of LCSWs in
Studies show that a
continuing education format
can provide portable, lowcost, and effective basic
education in psychiatric
rehabilitation to entry-level
workers.[6]

Require all state hospital
BH workers to have
CPRPs

Arrange and fund CPRP
training program for all
done by UMDNJ PsyR
Department.

NJ DMHAS should
continually lobby Rutgers
to sustain the Department
of Psychiatric
Rehabilitation.
C. Licensing
1. Social Workers

NJ does not offer
reciprocity with other
3
Issue
Description
states.
2. Peer Providers

Only LCSWs can provide
clinical services (e.g.,
clinical assessment,
clinical consultation,
psycho-therapeutic
counseling and clientcentered advocacy).

To become LCSW, must
first become LSW.

LCSWs: NJ requires 1920
clinical hours (within 3
years post MSW).

Supervision: only by a
LCSW with min. 3 yrs
licensure and 20 hrs cont.
ed. credits of post-grad
course-work related to
supervision.

Supervision: must be at
least once per week face
to face.

Licenses: must be
renewed every 2 years.
Response
Position
Priority
Progress
community based mental
health agencies.
[Should NJPRA take a
position on peer credentialing
and licensure?]
4
Issue
Description
Response
Position
The ACA and Medicaid
expansion is requiring
academic credentials beyond
the actual need of some
services (e.g., assessment),
which will further pressurize
the resources and budgets of
community agencies.
Within its own discretion, NJ
should assure that credential
requirements are appropriate
for particular services.
Priority
Progress
D. Credentialing
1. Academic degrees
E. Engagement and Deployment
1. Peer Providers
Peer involvement in mental
health services is a proven
means of reducing
rehospitalizations.[9]
The ACA provides many new
options for the employment
of peer providers. But NJ as
a state does not have
sufficient knowledge of who
and where are the peer
providers.

NJ DHS should do an
expeditious and thorough
census to determine the
number of actual and
potential peer providers in
NJ.

NJ DHS should maintain
a current and complete
registry of NJ peer
providers.
II. Agency Development
A. Investment Support
Under the ACA, BH agencies
will be required to invest in
expensive compliance, EMR,
training, but as non-profits
have no investment capital.
“The conversion to a fee for

service presents cash flow
poses difficulties for the small
nonprofits. Lags between
service and reimbursements
could be more than one and
a half months, meaning that
agencies need cash on hand
NJ DMHAS should adopt
a very liberal transition
financing policy that
enables BH agencies to
draw on future payment
flows to help finance their
current requirements.
5
Issue
B. Compliance: Audits
Description
“RAC” audits by CMS will be
strict, handled in NJ by
private contractor HMS for
the Division of Medicaid
Fraud of the Office of the
State Comptroller.
C. Training about Community
Support Standards (CSS)
Response
Position
equaling 15 percent of its
annual costs to survive the
transition.”[1]

NJ should create a “BH
Development Bank”, a
revolving fund with HMFA
funds to assist agency
transitions.
RAC audits seem much
stricter than the state’s
regional Medicaid auditors.
Disparity in expectations of
various auditors (Fed or
State) is creating conflicts for
compliance, as well as
significant financial risk for
the agencies.

All Medicaid auditors, be
they RAC or state, should
be coordinated, so that
agencies can know better
what to expect and thus
better and more easily to
comply
Priority
Progress
[Green] DMHAS is coordinating
with Medicaid central office. “I’m
very interested to bring them
back this feedback.: Need to
connect with Steven Tahney
(sp?).[2]
Re: the Wellness

Transformation… An LSW
may not have the PsyR
training. How to preserve and
advance PsyR? [Stivale] [2]
Finalizing a contract with SHRP
for 2 tracks: supervisors (2
regions) and direct care (3
regions). To get individuals to
learn and understand was CSS
is. “We agree with you that there
are a lot of providers who think
they are providing the service but
are really not…” [Larosiliere] [2]
III. Sector Development
A. Hagedorn Funding Reinvestment
Annual NJ Budget
Appropriation Bill constitutes
a law that supersedes NJ
Community Mental Health
and Developmental
Disabilities Investment
$41 mm of savings achieved
from H. closing. Consistent
with NJ Community Mental
Health and Developmental
Disabilities Investment Act
(“… to provide for a process
NJ must abide by the NJ
Community Mental Health
and Developmental
Disabilities Investment Act. It
must redirect all H. funding to
community mental health
A
Only $500,000 of H. funds are
being reallocated to Supported
Employment funding Beyond this,
no avoided H. operating funds
are being specifically allocated
(are have been assured) to
6
Issue
Description
Response
Act.[P. Lubitz]
by which the resources which
result from the sale of
residential facilities and/or
the reduction of
expenditures for State
inpatient resources shall be
invested in community-based
services…”[10]), all this
should be redeployed to fund
MH/DD community services.
But only $.4.4 mm going to
community services.


Position
Priority
services.
Progress
community mental health.
DMHAS however expects an
asset in FY 2014 to a request for
new budget allocations “to
grow”.[2]
B. Comprehensive Waiver
Implementation
1. Medicaid Related
a. Rate Setting
Consultant (Myers &
Stauffer, CPAs) hired.

Base year to be used:
2012.

Cost-based.

Agencies, other states to
be analyzed.
NJ Medicaid rates:
LOWEST IN THE
COUNTRY
(Medicaid/Medicare ratio:
US = 72%; NJ = 37%)
[11]

The Medicaid/Medicare
rate ratio is still low,
though improving slowly.
[11]

60% of NJ physicians will
not accept new Medicaid
patients (US avg =
30%).[12]

Delay implementation

Pick a better base year

Increase transparency

Provide for evaluation

Rates, when set, should
be flexible for
reconciliation with
evaluation
A
Myers & Stauffer will seek info
from 7 “practice groups”:







Outpatient
Partial care
Residential (incl. detox)
Methadone
Case Management
PACT
Supportive Housing
Also, specific agencies to be
visited.[2]
7
Issue
Description
b. Rate Uniformity
1) Geographic
variability of
rates
Response

Base year 2012 is worst
year of major recession.

Rates should fully cover
all costs of doing business
in a fee-for-service
regime.[1]

Rates should account for
regional cost differences
within the State (e.g., rural
vs. urban, north vs.
south).[1]

The broadest criteria for
determining income
eligibility should be used
esp. for those without
Medicaid.[1]
Position
Priority
Progress

Rates are to be uniformly
around the state, regardless
of location.


NJ DOL statistics suggest
extensive variability in
cost-related factors
across NJ.[13, 14]
Population density (urban
vs. rural) “definitely”
affects cost. Ex:
Bridgeway: $45 per unit in
Union; $65 per unit in
Sussex.[2]
Generally, rates will not vary by
region to account for regional cost
differences.[2]
Rates may vary between scattersite and single-site facilities.[2]
How to reckon screening cost
differences between psych
hospitals (e.g., Greystone vs.
Ancora): no clear answer
received.[2]
8
Issue
Description
2) Population
variability of
rates
Response
Position
Rates to vary according to
particular needs of
“vulnerable” populations (?)
Progress
In FFS model, core services “with
enhancements” to be purchased
differently for vulnerable
populations, e.g.: a) Medical
fragile or compromised
b) Deaf and hard of hearing, c)
Children (Provision of EBPs for
child welfare) [Green].[2]
c. Rate Parity (with
hospitals)
d. Rate Basis
Priority
Community agency rates will not
be the same as hospital rates,
even for the same services.[2]
Comprehensive Waiver
proposes to move behavioral
health to a managed care
approach—at first on an
encounter-basis fee-forservice basis.
Fee-for-service encourages
service overuse and does not
provide for care over a
continuum.[15]
When moving to managed
care, why must NJ BH
managed care be first on a
FFS basis, which seems a
step backwards?

Rates should provide for
continuum of care, not by
fee for service but by case
rates and, better yet,
capitation rates.
DMHAS believes it must first start
with smaller blocks (FFS) before
going to capitation since there isn’t
enough “encounter data”. [Green]
[2]
e. Covered Services
1) Promotion of
integrated
PH/BH
services
As NASMHPD [16]
recommends: Medicaid
should:
 Provide coverage for
health education and
prevention services
(primary prevention) that
9
Issue
Description
Response



Position
Priority
Progress
will reduce or slow the
impact of disease for
people with SMI.
Establish rates adequate
to assure access to
primary care by persons
with SMI.
Cover smoking cessation
and weight reduction
treatments.
Use community case
management to improve
engagement with and
access to preventive and
primary care.
2) Services not
covered by
Medicaid
3) Medicaid
plans: legacy
vs.
“benchmark”
Medicaid benefits after
expansion will increase…
No, they won’t… Benefits
under The ACA’s Medicaid
expansion will be fewer for
“new eligibles” to be enrolled
than for those already
covered by legacy Medicaid.
Substance abuse benefits
are particularly affected.[17]
For “new eligibles” with
psychiatric disabilities to be
enrolled in “benchmark”
plans in Medicaid expansion
with fewer benefits than for
existing beneficiaries, the
state should provide
whatever benefits not
covered by benchmark plans
but covered by legacy
Medicaid plans.
DMHAS may not understand this
point fully. Medicaid “benchmark”
plans after expansion in fact will
offer fewer benefits than legacy
Medicaid plans.[2]
[But, is State considering to
increase certain benefits on its
own?]
10
Issue
Description
f. “Medical necessity”
This CMS term, a relic of the
“medical model”, is too
narrow for proper PsyR.
g. Expansion
Currently 1.3 mm in NJ get
Medicaid. ACA expects to
increase NJ enrollment by
234,000, or ~23% (only 46%
of NJ’s currently
uninsured).[18]
1) Outreach and
recruitment
 CMS to train 3 classes of
recruiters (e.g.
Navigators, Assisters,
Certified Enrollers). See
www.healthcare.gov
a) ACA
Naviga
tors
CMS has awarded $2 mm in
grants to 5 Jersey entities:

Center for Family
Services (Camden,
southern counties)

Wendy Sykes - Orange ACA
Navigator Project (Essex)

Urban League of Hudson
County

Public Health Solutions
(NYC, serving Hudson,
Response
[What is covered in the
“rehab” option?]
Position
Priority
Progress
 Expand NJ state definition
of “medical necessity” to
include for those with
psych-diabs all aspects of
PsyR EBPPs (esp.
Supportive Housing)
 Wherever possible, peer
providers should be hired
to recruit non-insured
New Jerseyans into
Medicaid.
DMHAS is working with Medicaid
to expand capacity for assister
training, for providers to attend
and become certified. One day
training to become a certified
application assister.[2]
CMS awards heavily target
only certain locales. What
special efforts to recruit those
with psych diabs?
11
Issue
Description
Response
Position
Priority
Progress
Essex)

h. Provider Networks
i. Community support
services (CSS)
FoodBank of Monmouth and
Ocean Counties
 60% of NJ physicians will
not accept new Medicaid
patients (US avg =
30%).[12]

Insufficient PHP
provisions to increase
providers to meet the
expansion
 ACA’s “rate bump”: only 2
years, only for PHPs. No
bump for BH
providers.[19]

BH providers reducing!
CMS approved specific
details for CMS items to be
covered by Medicaid.[20]
 Increase Medicaid rates
by [x] %
The CSS regs draft now done
internally. Needs review and
approval outside the Division
before being available for public
comment. By the end of 2013, we
hope they will be published.
Public comment will follow in 1st
qtr FY2014.[Larosiliere] [2]
In addition to training for clinical
support for CSS, DMHAS is
getting some tech assist related
to separation of housing and
services. Consultants are doing a
readiness review and a work
plan.[2]
In CSS, the rates are banded,
depending on the credential.
[Larosiliere] [2]
12
Issue
j. Appropriate
Credentialing
Requirements
2. Section 1115
Demonstration (ACOs)
Description
Response
Position
Appropriate credentialing and
licensure of professionals is
an important means for
generally assuring quality
service delivery.
The Comprehensive Waiver

requires credentialing and
licensure that is inconsistent
with the actual needs of
various PsyR practices, thus
imposing undue administrative
and regulatory burden on
agencies. For instance, the
CW now requires licensed
masters’ level credentials of
staff to do routine intakes and
assessments. By forcing
agencies to find and employ
staff more qualified than
necessary, agencies will be
less able to afford to offer
several PsyR services such
as supported housing and
ICMS.
Camden Coalition (Brenner)
and others are making great
strides to reduce cost of
care.[21] Successful pilot
could be a model for all NJ,
including for BH..

All the focus of the pilots
is on primary care first,
perhaps to the detriment
of those who need BH
first.

Psych-diab health needs
are highly problematic,
integrated with BH.

State needs BH ACOs
Priority
Progress
After consulting further
with stakeholders about
their specific operating
needs, DMHAS and
DMHAS should seek
subsequent amendments
to the Comprehensive
Waiver to specify more
appropriate credentialing
and licensure
requirements of particular
staff doing particular
functions.
 Include some BH
agencies (GTBHC, BW) in
Section 1115 R&D ACO
projects
13
Issue
Description
Response
Position
Priority
Progress
also.
a. Behavioral Health
Homes
BHHs should be developed.
DMHAS will do a “learning
community” first, then an RFP.
This will reset the clock. But once
SPA approved on the 90/10.
Each SPA will reset the clock.
[Kovich]
When? Must submit with DCF,
which won’t be ready until
January 2014. So DMHAS will
submit then.[2]
3. Section 1915b Managed
Care (ASO)
NJ to move all BH to “fee for
service” managed care under
an ASO.
4. Care Integration (PH & BH)
C. Outcomes and measures

ASO needs flexibility to
work with agencies and
sector. ASO should have
some rate setting
discretion.

Postpone Medicaid final
Medicaid rate setting until
after ASO is appointed.
Unless “dual eligible”, those
with psych-diabs will still
have two systems, one for
PH and one for BH.
Thought leaders in
behavioral health agree that
the development of outcomes
measurement is essential for
the sector [22-26]. Yet
experience to date
nationwide and in NJ
suggests that behavioral
health still lags far behind
Better outcomes
measurement is needed
further to substantiate the
results and benefits
(individual and society) of
PsyR. To date, research
funding is disproportionately
allocated to short term (e.g.,
6 months)
 A reasonable percentage
of the Hagedorn savings
should be deployed to
foster better outcomes
measurement in the
sector.
14
Issue
D. Coverage and payment for
services to non Medicaid
consumers
Description
Response
Position
other sectors in this important
management aspect.[27]
psychopharmacological
research. More research is
needed for longer-term
psychosocial modalities.
Many agencies currently
provide services to non
Medicaid covered
consumers. Sometimes
these services are
reimbursed by the state
under current contractual
arrangements. Often they are
not and must be written off.
Under the ACA’s Medicaid
expansion, consumers with
incomes above 138% of FPL
will not qualify for Medicaid.
Like others above 138% of
FPL, these consumers will be
directed to the Health
Insurance Exchange to
purchase coverage on their
own (with subsidies from the
federal government if they
qualify). Exchange plans will
not likely cover services that
many non Medicaid
consumers now receive.
Without payments from such
coverages, agencies will be
forced to deny services to
such consumers in the future.
 To ensure service
continuity and quality for
non Medicaid covered
consumers, the State
must “fund the gap” to
ensure full payment
coverage to agencies for
existing services that
coverages from Health
Insurance Exchanges
may not cover in the
future.
CPRP is the only designation
that advances
transdisciplinary practice of
PsyR, which is the crux of the
2006 Transformation
 Good start, but not
enough. NJ should follow
the lead of other states
like PA, ID which now
require certain percentage
 NJ officially to recognize
CPRP.
Priority
Progress
IV. Practice Development
A. General
1. CPRP
 Within 5 years, NJ to
require 25% of all BH
15
Issue
Description
Response
Statement. [28] DMHAS
agreed to state CPRP as a
“preference” in RFPs.
of workforce to have
CPRPs, especially direct
care workers.
Position
Priority
Progress
workers in all levels to
have CPRP.
 Funding to train
Supported Housing
providers to become
CPRPs should included in
the NJ DHS budget.[1]
B. Specific PsyR EBPPs
1. Assertive Community
Treatment
a. Cognitive Behavioral
Therapy Training
CBT is an effective treatment
additive for those with psychdisabs, esp. for improving
medications compliance,
reducing service costs,
etc.[29] CBT techniques are
readily learnable by providers
with BA degrees.[30]
.
 All NJ PACT providers
should be trained in basic
CBT techniques.
Additional sufficient
funding should be
allocated for this.
2. Integrated Dual Disorder
Treatment (IDDT)
DMHAS supports the
evidence-based practice of
IDDT.[31]
Many state-licensed facilities
(e.g., Carrier, Summit Oaks)
still separate treatment by
either psychosis or addiction.
DMHAS should establish a
true IDDT facility for NJ.
3. Supported Employment
To be “carved out” of FFS
Medicaid…

Evidence continues to
show that SuppEmpl
succeeds to advance
psychiatric rehabilitation.
[33]
 The NJ DHS budget
should include sufficient
funding for this
modality.[1] [What is
sufficient?]

The Dartmouth “IPS”
 The program needs better
FY 2013-14 budget: 2,371
clients served for $5,308,712.
[32]
$500,000 of Hagedorn funds are
being reallocated to Supported
Employment funding Beyond this,
no avoided Hagedorn operating
funds are being specifically
allocated (are have been
assured) to community mental
16
Issue
Description
Response
Position
model is considered the
model for SuppEmpl.
4. Illness Management and
Recovery
5. Supportive Housing
a. Rental Subsidies
(SRAPS)

23 funded SuppEmpl
programs now funded.in
NJ (one for each county).

Takes 3 months to get a
SuppEmpl appointment…
[Roberts]

Outcomes “not great”:
1307 people in SuppEmpl
program now. 11,746
referrals, but only 3390
“closed out” (completed).
[Roberts]
tracking and better
outcomes.
Priority
Progress
health. DMHAS however expects
an asset in FY 2014 to a request
for new budget allocations “to
grow”.[2]
IMR is an important PsyR
program especially for those
with psych diabs in state and
county hospitals who can
most benefit from this selfmanagement modality.
FY2013-14 Budget: 5,858
clients served; $82.3 mm.[32]

Expand NJ state definition
of “medical necessity” to
include for those with
psych-diabs all aspects of
PsyR EBPPs (esp.
Supportive Housing)
The State Rental Assistance
Program is tenant-based and
project-based, comparable to
17
Issue
Description
Response
Position
Priority
Progress
the Federal Housing Choice
Voucher Program,
terminated upon award of a
Federal subsidy to the same
individual or household. Run
by Dept Comm Affairs.
FY2014 Budget: $18.5 mm
recommended.[32]
b. Other housing
supports
Other DCA programs include
housing support, housing
production, energy
assistance, community
services, and neighborhood
programs.
c. Separation of
services from
facilities
Feds pushing for separation
of housing and services…
So many SH providers doing
this EBP provide both
services and facilities. They
don’t completely separate per
se, but separate into discrete
costs, even when offered by
one entity. Will this continue?
[Stivale] [2]
Family Psychoeducation,
offered in NJ by the
pioneering IFSS, is a
confirmed PsyR EBP. IFSS
has been found to be an
effective service.[34]
Multifamily Group FP[35],
now in only 3 locations, is a
IFSS provides invaluable
service to families, with
evidence that proves rehab
and cost effectiveness.
6. Family Psychoeducation
“All those things are under
consideration”. HMFA is part of
this process. But, CMS and DOJ
Olmstead and HUD Olmstead,
consumers need a meaningful
choice of services regardless of
housing. [Larosiliere] [2]

Maintain funding for
IFSS’s current programs.

Increase pilot programs
for Multifamily Group
modality

Extend MFG programs to
all counties.
18
Issue
Description
Response
Position
Priority
Progress
highly effective modality.[36]
7. Family Education (NAMI
Family to Family Education
Program)
Family Education about
mental illness is proven
effective in reducing
hospitalizations and
improving prospects for
rehabilitation and
recovery.[36, 37]
NAMI NJ provides a longestablished 10 week
educational program on
mental illness (“Family to
Family “) free to all who wish
to take it.
 NJ DHS should maintain
its funding support for
NAMI NJ Family to Family
education program.
8. Family Consultation (IFSS)
Family Consultation is
offered to NJ families with
loved ones with psych-disabs
by IFSS.
Families need nontherapeutic consultative
support to navigate the
mental health system, so
better to serve the psychiatric
rehabilitations and recoveries
of their loved ones.[34]
 The NJ DHS budget must
continue to fund the
activities of IFSS.
9. Supported Education
 The NJ DHS budget
should include funding for
this modality.[1]
C. Other Processes

1. Intensive Case
Management
Services(ICMS)
FY 2013-14 Budget: 10,725
served for $20,363,530. [32]

2. Projects for Assistance in
Transition from
Homelessness (PATH)
FY 2013-14 Budget: 3,165
served for $2,290,501.[32]

3. Program of Assertive
Community Treatment
(PACT)
FY 2013-14: 2,443 served
for $15,199,865.[32]

19
Issue
Description
Response
Position
4. Justice involved services
FY 2013-14 Budget: 1,569
served for $3,839,815.[32]

5. Self-help Centers
FY 2013-14 Budget: 6,240
served for $5,995,140. [32]

6. Vocational Rehabilitation
FY 2013-14 Budget:
$39,322,000.

Priority
Progress
V. Client/Consumer/Family Development
A. Supplemental Support Income
(SSI)
SSI is a Federal cash
entitlement program for those
who qualify because of
indigence, as generally
results from a psych disab.
NJ supplements SSI
payments for all Jersey
recipients.
FY2013-14 Budget: Avg
monthly recipients: 194,977
for $45,648,015 [NJ
portion].[32]
B. Olmstead
The Home to Recovery
(2008) plan governs the
implementation of Olmstead
remedies.[38]
FY 2013-14: $353.8 m, up
increase of $3.4 million to
develop 334 new communitybased placements (234 for
dischargees from State psych
20
Issue
Description
Response
Position
Priority
Progress
hospitals; 100 for those at risk
of institutionalization).[39]
1. Available housing stock
2. Placements in boarding
homes, rooming houses,
residential health care
facilities, and homeless
shelters
The Olmstead decision
continues to move state
institutions to deemed ready
for discharge.
According to DCA, New
Jersey has:




200 boarding homes
800 rooming houses
100 RHCFs
120 homeless shelters[40]
Subsequent suitable housing
for such dischargees
continues to be problematic,
however. To fulfill their
Olmstead obligations,
hospitals are discharging
patients to boarding homes
without adequate support
services, effectively
constituting a kind of
reinstitutionalization with yet
lesser service support.
Advocates have long voiced
concerns about many
problems for consumers in
boarding homes, including:
poor environments, lack of
privacy, inadequate supports,
poor nutrition, stigma,
arbitrary rules, fund
management problems,
crime, segregation, limited
medical care, and high psych
hospital recidivism
associated with boarding
houses.[41]
a. Oversight
DCA oversees boarding
Sometimes PACT and ICMS
NJPRA supports:



Verifiable offers of a
continuum of housing as
part of discharge planning
at state psychiatric
hospitals
Set-aside funding to
assist those with psych
diabs in distressful
housing to move
Vouchers to subsidize
rents
PACT and ICMS teams must
21
Issue
Description
homes (re: facilities).
Counties also do (re: social
services like meals, etc.).
Response
teams are denied access to
boarding homes, requiring
them to meet their clients
outside the boarding home.
Boarding home operators too
often violate regulations.
Position
Priority
Progress
be better trained in DCA
codes and regs.
PACT and ICMS workers
must be more proactive in
reporting violations and
protecting clients in their
charge.
DCA must enforce its
regulations more rigorously.
b. Partial care
programs operated
by boarding home
operators
Partial care programs are
regulated by DMHAS (Office
of Mental Health Licensing)
3. Community integration
preparation
Fifty five percent of all
boarding home operators in
NJ are also operating partial
care programs [Bucher],
which creates significant
conflicts of interest and
difficulties for psych rehab.
State hospitals: candidates in
CEPP not receiving enough
skills training for outside
living [Cook].
C. Stigma
1. Association with Violence
2. National Reporting and
Registration

In the wake of Newtown,
legislatures around the
country have passed laws
requiring reporting and
registration of those with
psych-disabs, presuming a
Studies consistently show far
less association of violence
and mental illness than
people suppose.[42-45]
Those with psych-diabs are
far more likely to be victims,

Oppose all legislation
requiring any reporting or
registration into a national
data base of those with
psych-disabs.

Strictly limit requirements
22
Issue
Description
link between violence and
mental illness.
Response
Position
not perpetrators, of violence.
Such reporting and
registration requirements
discourage help-seeking and
compromise the providerconsumer therapeutic
relationship.
Priority
Progress
of providers to report
status of their patients to
law enforcement.
D. Confidentiality/HIPAA
1. Admissions
2. Emergencies
HIPAA restrictions are more
lenient in emergency
situations. All providers in
emergency situations should
be made aware of these
distinctions and encouraged
to interact with families more
freely in such situations.
Emergency situations should
be clarified to include: ER
visits, Crisis Screening
interventions, involuntary 72
hr evaluation commitments.

NJDHMAS should
encourage all providers
managing client
admissions always to
encourage clients to sign
releases in favor of their
families.

AG to issue legal
clarification on application
on HIPAA in emergency
situations

NJ DMHAS to declare
that emergencies in BH
include: ER visits, Crisis
Screening hospital visits,
72 hour evaluation
commitments.
E. Case Management
23
Issue
1. “Transfers and Transitions”
Description
Response
Because of the siloed nature
of institutional care, a client’s
transfer from one institutional
unit to another, even within
the same hospital, always
results in a complete change
in treatment teams and
regimens. This leads to
disruption in care continuum
and even interruption of
services.
Better communication and
coordination among
providers of different
institutions and even units
will improve care and reduce
expense.
Position

All patients being
transferred from one NJ
institution to another (e.g.,
hospital to outpatient or
PACT) should retain the
services of the
discharging social worker
for 72 hours after
discharge.

NJPRA supports full
funding and
implementation of a
statewide CIT program
Priority
Progress
F. Law enforcement
1. Crisis Intervention Training
Funded by DHS and the
Attorney Genl’s office, NJ
CIT programs are local
initiatives designed to
improve the way law
enforcement and the
community respond to people
experiencing mental health
crises.
2. Pre-trial intervention (jail
diversion)
NJ has a pre-trial intervention
program that can benefit
those with psych disabs who
encounter legal problems.
3. Mental Health Courts
Mental health courts continue
to evolve as a meaningful
alternative means for
processing those with psych
disabs in the legal
Hudson Vicinage is the only
NJ vicinage that has a
dedicated mental health unit.
24
Issue
Description
Response
Position
Priority
Progress
system.[46], providing
assessments on defendants
suffering from mental
illnesses.
4. Solitary confinement
Solitary confinement of
prisoners with psych diabs
poses significant restrictions
on mental health care and
raises significant ethical
issues.[47]
G. Involuntary Outpatient Treatment
In 2009, NJ passed its IOC
law. About 400 high-risk
patients out of 400,000
mental health patients
statewide would be
affected.[48] Funding for full
implementation has been
delayed.
P.L.2009, c.112
Initially funded with $2.0
mm for 6 counties. FY
2013-14 added $2.4
mm.[39]
H. ACA’s Consequences
1. Access
a. Medicaid benefits
ACA Medicaid expansion
“benchmark” plans will offer
fewer benefits to “new
eligibles” cf legacy Medicaid
Differences in benefits within
Medicaid will create a)
coverage gaps for “new
eligibles”, b) administration
DMHAS understanding of ACA
“benchmark” coverage provisions
seems incomplete or incorrect.[2]
25
Issue
Description
Response
plans to enrollees and “old
eligibles”. SA services
26articularly affected.
burdens for agencies.[17]
Medicaid: NJ has the
nation’s lowest % of
accepting providers, both
primary care and
specialists.[49]
Increasing “access” to, and
thus the enrollments in,
government insurance
programs does little good if
the number of providers is
shrinking. Those with
psychiatric disabilities are
particularly badly affected.
Position
Priority
Progress
2. Availability
a. Participating
providers
Medicare: NJ has the lowest
% of doctors accepting new
Medicare patients. Nationally,
the number of doctors
refusing Medicare last year
(9,539) tripled from 3 years
earlier. [50]
Medicaid: NJ should set rates
that will incent more doctors
to participate.
3. Quality
4. Cost
5. Innovation
VI. Government Development
A. Executive Branch
1. Department of Banking
and Insurance
Health insurance exchanges
and regulations…
2. Department of Children
and Families
Youth mental health…
a. Division of
Children’s System of
26
Issue
Description
Response
Position
Priority
Progress
Caredss
3. Department of Community
Affairs
Rental vouchers
Housing matters
Boarding home licensing
Affordable Housing Trust
Fund
a. Division of Codes
and Standards
1) Bureau of
Rooming
House and
Boarding
House
Standards
Regulates all a) boarding and
rooming houses, b) homeless
shelters, and c) residential
health care facilities in NJ, in
many of which live those with
psych diabs.
“Provides for the health,
safety, and welfare of all
those who reside in rooming
and boarding houses...
ensures all State agencies
work in unison for the
protection and care of the
residents of rooming houses,
boarding houses, and
residential care facilities” [32]
b. Division of
Community
Resources
Provides certain financial
supports for the indigent,
including a) home energy
assistance, b) Universal
27
Issue
Description
Response
Position
Priority
Progress
Service Fund (for utilities), c)
c. Division of Housing
Funds various cash and
grant assistance for housing,
including a) SRAPs.
SRAP FY 13/14
appropriation: $18.5 mm.[51]
d. Housing and
Mortgage Finance
Agency
4. Department of Corrections
Prison mental health
5. Department of Health and
Human Services
Licensure and credentialing
Hospitals
Hospital based:
Screening/Emergency
Centers for children
Hospital based: Children’s
Crisis Intervention Services
Intermediate Inpatient
Treatment Units
a. Division of Health
Facilities Evaluation
and Licensing
Regulates Residential Health
Care Facilities, psychiatric
hospitals, some day
programs, and some
outpatient settings.
6. Department of Human
Services
28
Issue
Description
a. Division of Mental
Health and Addiction
Services
Response
Position
Priority
Progress
Community based agencies
State psychiatric hospitals
Housing
Olmstead
Workforce Development
1) NJ Mental
Health
Planning
Council
b. Division of Medical
Assistance and
Health Services
1) Medical
Assistance
Advisory
Council
(MAAC)
c. Division of Disability
Services
Community Mental Health
Block Grants
Medicaid
Advises the Director of
DMHAS on medical care
and health services, for those
whom the program is
designed to serve, and to
foster communication with
the public.
Oversees Medicaid home
and community-based waiver
programs.[32]
d. Division of
Developmental
Disabilities
e. Division of Family
Development
Manages NJ’s SSI program.
29
Issue
Description
Response
Position
Priority
Progress
FY2013-14 Budget: Avg
monthly recipients: 194,977
for $45,648,015.[32]
f. Office of Program
Integrity and
Accountability
(OPIA) (DHS)
1) Office of
Licensing
Licenses partial care
programs for adults
a) Unit of
Mental
Health
Licensi
ng
7. Department of Labor and
Workforce Development
Employment programs
a. Division of
Vocational and
Rehabilitation
Services (DVRS)
b. Division of Disability
Determinations
Fully funded by federal
sources, DivDisDeterm
adjudicates LT disability
claims.
FY2013-14 Budget: 103,412
cases adjudicated.[32]
8. Department of Law and
Public Safety
Attorney General’s office.
30
Issue
Description
Response
Position
Priority
Progress
a. Division of Civil
Rights
b. Division of
Consumer Affairs
Credentialing and Licensure:










Alcohol and Drug
Counselors
Home Health Aides
Marriage and Family
Therapy
Medical Examiners
Nursing
Occupational Therapy
Professional Counselors
Psychoanalysts
Psychologists
Social Workers
c. Division of Criminal
Justice
9. Office of the Governor
10. Office of State Comptroller
Independent office. Audits
government finances,
reviews the performance of
government programs and
examines government
contracts.
a. Division of Medicaid
Fraud
Oversight of Medicaid funds
Supervisor of RAC services
provided by HMS
31
Issue
1) Recovery and
Contractor
Audits (RAC)
Description
Response
The Affordable Care Act
(ACA) requires Medicaid
agencies to contract with
Recovery Audit Contractors
(RACs) to identify and recover
overpayments and to identify
underpayments. States must
also develop processes for
entities to appeal RAC
determinations, and
coordinate RAC efforts with
other Federal and state law
enforcement agencies.
According to
http://www.medicaidrac.com/, NJ is not seeking
any exemptions from RAC
audit scope The state has
designated HMS as its RAC
contractor through an
existing contract (April 2011)
In April 2013, the state
issued an RFP for Medicaid
RAC services with proposals
due May 29, 2013. [What is
the status of this?]
Position
Priority
Progress
CMS has issued a “Frequently
Asked Questions” whitepaper
about RACs.[52]
B. Legislative Branch
1. Office of Legislative
Services
Non-partisan office does
excellent analysis of
Governor’s budgets
C. Judiciary Branch
References
1.
2.
3.
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45.
46.
47.
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35