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FY 2019-20 MHSA Update Feedback

Last updated on May 10, 2021

This is the public-comment feedback I submitted regarding the MHSA FY 2019-20 Annual Update [DRAFT] the San Diego County BHS department is required to submit to the MHSOAC:

What made the report:
Here’s the summary of my letter making the report.

“Online 9/1/19 A public comment letter addressed multiple points.
Comments included reference to the outcomes data in the report and a desire for more detailed and immediate outcome reporting, show a linear relationship to funding, and more comprehensive cost‐per‐client description. Suggestions included a desire for more detailed measurement of services for diverse communities. The letter recommended better online access to the report, earlier access for BHAB to the report and to the Community Engagement report, and access to draft, discuss, and edit content. The letter also requests details about the Innovation process and access to data from other counties for comparison.

And the reply:
Noted. Options will be explored for enhanced access to online reports within the County structure. Innovation projects will be discussed at upcoming public forums in October and November. The State MHSOAC has a transparency tool to compare programs across counties at

Original letter:
“My name is Jerry Hall. These are my public comments and I only represent myself in the following. I previously served for several years on the Alcohol and Other Drug (ADAB) which then merged with the existing Behavioral Health Advisory Board (BHAB), a group I have served since it’s formation in 2015.

Regarding this Annual Update, I have concerns which are outlined here and which I will describe as I am able over the next year on my site at We are in a process of change and change is never easy, including hearing critical feedback. My hope is that MHSOAC also hear these comments as they likely apply to many county BHAB’s throughout the state.

  1. This report is generated after the current Fiscal Year’s budget has been approved and spending has begun. Yet, we use this update to report outcome-data from two fiscal years ago. Wouldn’t it make more sense to citizens and clients to use the most recent year’s outcome data to justify why we decided to spend more or less this next year?

  2. It is disheartening to look into details of the report expecting outcomes data, and seeing most pages describing the programs themselves, then only a few metrics describing only a few generalized outcomes. Shouldn’t we use this annual update to discuss the program goals, outcomes, budget and how we adapt year-to-year to address challenges we face from market demand and program shortcomings? 

  3. A cursory search of this 372 page document revealed the word ‘diversity’ used six times, only once in actual outcomes-reporting context, and the word ‘inclusion’ was used three times. Throughout this report, it does not seem like we have a consistent measure on how this MHSA Plan and Updates address, track and report on the unique needs of our diverse population. The County has its own Strategic Plan for Diversity & Inclusion FY2015-2020 generally addressing the county’s hiring practices. Perhaps we should focus in a more concerted way how we will address, track and report on the various dimensions of our clients so that we can identify and address gaps?

  4. With an extremely high number of citizens in the county having Internet access, it seems it would be beneficial to publish this report on the internet versus only via a 22mb PDF document. There are many opportunities to receive more informed feedback from stakeholders, especially existing and potential clients, but we seem to make it more difficult than necessary to get that feedback.  

  5. Where is the critical discussion of our work? We have a wide range of reporting metrics used throughout this document but, little to no discussion of challenges, and how we are adapting to overcome those challenges. When seemingly more obvious shortcomings are reported, there is no discussion why that shortcoming exists. It is difficult for any stakeholder to read, absorb, understand, then opine on a document that is generally so inconsistent.   

  6. Several of the ‘Costs Per Client’ reported amounts are extraordinary with little to no description of rationale. Not having more uniform metrics to describe outcomes shown make it even more difficult to understand.

  7. It appears that several existing Innovation (INN) programs are generally having funding continued for the next year, and that no new Innovation programs will be started? Where is the process for the Innovation Fund program described in detail? How are these projects selected? Who selects these projects? Who makes the decision to continue, adapt, or discontinue these programs? Wouldn’t it make sense to have a calendar of the various INN programs and related milestones so that stakeholders could follow the progress?

  8. One of the items reported in this Annual Update is the results from the Fall 2018 Community Forums. These forums are used to hear directly from a diverse population of stakeholders. One item not clear is the number of participants who work for any BHS-related network provider. Since these people are intimately involved and aware of opportunities and challenges in our work, wouldn’t it be helpful to provide data as to what their experiences and feedback were?

    Also, even though the BHAB is tasked with many responsibilities regarding how our BHS serves our stakeholders, this is the first time we have seen this report. This has been a consistent missed-opportunity and literally keeps the volunteers who are doing the most they can to help our system improve, literally in the dark until over nine months after the report was drafted, revised, and delivered to BHS.

  9. It has been difficult to measure elements in this document against other California county annual updates. Wouldn’t it make sense to develop a common standard for all counties insofar as to how we create these reports, what elements we include, what outcome measures we will track, and how we will deliver this report both in print and online?

    How do we as individual counties learn from each other’s often costly mistakes, seize opportunities to deploy best practices, and share information on our methodologies – all with one goal in mind – to reduce the amount of suffering our clients, their loved ones, and our communities across the state experience?

  10. Finally, I believe BHAB should help create this document through a draft and review process, rather than simply get the opportunity to view it at the same time the public has the opportunity. Why isn’t BHAB exercising it’s responsibility to ensure citizen participation is optimal, including being informed, and having opportunities to contribute?”

    Thank you!


Original Source Document:

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