More Bricks-And-Mortar is Not The Answer to Kentucky's Mental Health Needs
MORE BRICKS-AND-MORTAR IS NOT
THE ANSWER TO KENTUCKY'S MENTAL HEALTH NEEDS
Kentucky Protection and Advocacy protects and promotes the rights of children and adults with disabilities. Many of the families we serve can’t find community supports for their children with mental illness and intellectual disabilities because those supports don’t exist. Many of these children – over 200 last year, in fact – have been sent out of state for long-term psychiatric care.
Everyone one wants to bring Kentucky’s children and youth back home. KVC Behavioral Healthcare, Inc. proposes to do just that by building a new 50-bed psychiatric hospital. But Kentucky already has 163 empty inpatient psychiatric beds for children on any one given day. Adding more beds won’t help.
Kentucky’s parents need intensive, community wraparound supports to help their children remain in their own communities or to come home from out of state. Wraparound supports may include crisis supports, crisis stabilization, respite, and intensive case management. Let’s invest our time and money building an intensive support system for Kentucky’s children, rather than just more bricks and mortar.
The issue:
The Office of Health Policy within the Cabinet for Health and Family Services has amended 900 KAR 6:075, one of its proposed regulations, to allow for up to eight 50-bed specialty psychiatric hospitals for children and adolescents to be established by going through the Certificate of Need (CON) non-substantive review process. The hospitals would serve individuals age four to twenty-one with a mental health diagnosis and documented evidence of mental retardation or a developmental disability, physical aggression, or inappropriate sexual behavior.
State officials say that these new 50-bed facilities will allow the over 200 Kentucky children and youth to return from out-of-state placement and save the state $17 million dollars per year. They also assert that they have been working on these issues for a number of months and now is the time to act, giving the issue an urgent or emergency status.
KVC Behavioral Healthcare, Inc. has filed a CON Application for non-substantive review that proposes to build a 50-bed specialty psychiatric hospital in the old Mt. Sterling High School Building located in Mt. Sterling, Montgomery County.
This type of facility should be required to go through the formal review process:
• The purpose of the CON process is “to improve the quality and increase access to health-care facilities, services, and providers, and to create a cost-efficient health-care delivery system for the citizens of the Commonwealth.” KRS 216B.010
• Allowing KVC to use non-substantive review takes it out of the State Health Plan which currently requires any new psychiatric hospital beds for children or adolescent to focus on short-term (under 30 days) crisis stabilization.
• Unlike non-substantive review which presumes the facility is needed, formal review would require the Cabinet to determine if a proposal to build a 50-bed specialty psychiatric hospital would achieve comprehensive care, be a proper utilization of services, and lead to the efficient functioning of the health care system. The Cabinet would also consider if there was a more effective and economical way of meeting the need identified in the geographical area. KRS 216B.040
Kentucky already has sufficient psychiatric hospital bed capacity:
• There are currently 712 licensed psychiatric beds for children and adolescents with an average daily census of 549 per the 2008 Annual Hospital Utilization and Service Report. Thus, there are 163 empty beds on any given day.
• Information cited by the Kentucky Hospitals Association (KHA) states the average length of stay for a child or youth in an acute psychiatric hospital is 18.2 days; in a Psychiatric Residential Treatment Facility (PRTF), approximately 6 to 8 months; and in an out-of-state residential treatment center, 425 days. (The 2008 Annual Kentucky Hospital Utilization and Service Report lists the average length of stay in a psychiatric hospital at 25.23 days.)
• KHA and others argue that no new acute psychiatric beds are needed, but a new longer-term psychiatric treatment level of care, including a reimbursement rate, need to be created to serve this population.
• If longer term institutional treatment is truly necessary, the State Health Plan can and should be amended.
This will not necessarily return kids home:
• It is unknown exactly what type of or duration of treatment KVC plans to provide at the new facility and whether it will allow Kentucky kids to return to Kentucky
• Its application says it will be a "short-term program providing brief-intensive treatment to help stabilize youth and identify community based aftercare services for children and families"
• It would be licensed as an acute psychiatric hospital which would normally restrict the lengths of stay to such acuteness, and seemingly run afoul of its avowed “no reject, no eject” admissions criteria
Can we save money by spending twice as much?:
• KVC’s CON application suggests it will receive $655 per day per bed.
Other daily rates: Level V Private
Child Care Residential $210
Psychiatric Residential
Treatment Facility $256
Out of State Facility $350
Psychiatric Hospital $394
This is not a new problem, but it is a complex one that requires careful planning to solve:
• Placement, both in-state and out-of-state, for more difficult to serve children and youth has been discussed for a number of years. Some time in 2002 or 2003 then Secretary for Family and Children Viola Miller issued a Request for Proposal to create two pilot programs to serve such children and youth. In addition, in 2005 the legislature charged the Cabinet for Health and Family Services to “investigate the need for children's psychiatric residential treatment services for specialized populations including, but not limited to, sexual offenders, children with physical and developmental disabilities, and children with dual diagnoses.” KRS 216B.455(7). The report concluded that in addition to the core services currently offered by PRTFs, additional services would be needed for each of the populations with accompanying additional reimbursement rates.
The answer is in the community:
• Many experts and their professional literature have concluded that intensive, home-based services are effective and superior treatment for children and youth with serious emotional disturbances (SED).
• US Congress recognized this and charged Substance Abuse and Mental Health Services Administration (SAMHSA) in the Department of Health and Human Services with creating the Comprehensive Community Mental Health Services Program for Children and Their Families in 1992. The program provides grants for improving and expanding community-based systems of care for the estimated nationwide 4.5-6.3 million children with SED and their families.
• One of the goals of former President George W. Bush’s New Freedom Commission’s on Mental Health was “to recommend improvements to enable adults with serious mental illness and children with serious emotional disturbances to live, work, learn, and participate fully in their communities.”
• President Obama believes that more can be done to show federal leadership toward ending the institutional bias and more rigorously enforcing the Supreme Court’s Olmstead decision which requires persons to be served in the most integrated setting. http://www.whitehouse.gov/issues/disabilities/
• Per a report by Leslie Schwalbe, MPA, entitled “Promoting Mental Health Transformations: Development and Implementation of Financing Strategies for Kentucky's Mental Health System”, Kentucky spends significantly more than the national average on psychiatric hospital inpatient care (57% vs. 28%) and significantly less on community mental health services (43% vs. 69%). Building more institutions will further tilt this backward-looking approach to mental health care.
• Kentucky Protection and Advocacy believes that children and youth with SED can and should be served in their communities with intensive, wrap-around services; psychiatric hospitalization should only be used for short-term crisis stabilization. This includes children and youth placed in foster care and those currently placed out-of-state.
