Joint Committee on Mental Health, Substance Use and Recovery
The Massachusetts Health & Hospital Association (MHA), on behalf of its member hospitals, health systems, physician organizations and allied healthcare providers, appreciates this opportunity to offer comment on bills relating to children’s mental health, trauma, and quality of care.
MHA supports HB1736/SB1154, which establishes a Children’s Mental Health Ombudsman Program to advocate for children with behavioral health disorders. Despite an increased focus across the commonwealth on addressing barriers to access for mental health care services especially for children who are covered by MassHealth – many children continue to board in hospital emergency departments (EDs) because of a lack of appropriate and available placement options. The families of these children can also face additional challenges such as difficulty in identifying the right point of entry for the child, locating clinicians fluent in specific languages who are also in the patient’s insurer network, as well as a host of other concerns and conflicts.
The establishment of an ombudsman within the Office of the Child Advocate is key to ensuring that children and families have access to needed services, as well as assistance, support and guidance. A centralized Children’s Mental Health Ombudsman Program, in conjunction with the Massachusetts Office of the Child Advocate, would identify and help eliminate obstacles to the behavioral health needs of children across the healthcare continuum. Specifically, the program will advocate on behalf of children, identify barriers to and propose solutions for effective mental health treatment, and receive, investigate and resolve administrative actions filed by children or their legal representatives. The important protections directed by HB1736/SB1154 will help ensure the health, safety, welfare, and rights of our children.
MHA is dedicated to the delivery of quality care, but concerned about certain provisions of HB1707/HB1716. Hospitals are already held to high quality standards as established by the Centers for Medicare and Medicaid Services, the Department of Mental Health (DMH), the Department of Public Health (DPH), and other accrediting bodies. Specifically, MHA has operational concerns about language requiring admissions and discharges to take place twenty-four hours a day, seven days a week. Discharges must occur on a timely basis in order to admit patients, and many continuing care and community-based programs are not able to accept patients on nights and weekend. This provision would create patient safety issues if inpatient providers are forced to discharge patients when appropriate continuing treatment is not open and available. Twenty-four/seven admissions and discharges would also require increased staffing at times of day when psychiatric patients are frequently sleeping and fewer direct caregivers are necessary. The means necessary to staff at a level that would allow for 24/7 admissions and discharges would not be a beneficial use of the already quite limited resources for psychiatric services, as compared to other services. MHA has been a dedicated participant in the work group that has been convened by the Executive Office of Health & Human Services, DMH, MassHealth, DPH, and the Division of Insurance, and feels that this discussion is better had in that forum.
Thank you for the opportunity to offer testimony on this matter. If you have any questions regarding this testimony, or require further information, please contact Michael Sroczynski, MHA's Senior Vice President of Government Advocacy at (781) 262-6055 or msroczynski@mhalink.org