NAMI Virginia’s members consistently rank a lack of supportive housing as the number one problem facing people with mental illness in Virginia. Lack of appropriate, supportive housing is a significant barrier to maintaining stability, long-term recovery, and living successfully in the community. Recent legislative initiatives to expand supportive housing have helped address this long-standing problem. We would like to thank lawmakers and state agencies for their support of HB 675 in the 2016 General Assembly Session, which is helping Virginia move closer towards a model of integrated, community-based supportive housing.

Upon review of the draft regulations and guidelines developed by the Department of Behavioral Health and Developmental Services (DBHDS) and Auxiliary Grant in Supportive Housing (AGSH) Advisory Workgroup, NAMI Virginia submits the following comments on the emergency draft regulations and guidelines:

We support the application of auxiliary grant program standards to DBHDS licensed supportive housing providers and including licensed community based mental health supports services in the AGSH rate.  Requiring that individuals in the AGSH receive an equivalent level of service to those in assisted living, in conjunction with the Housing First principles adopted by the AGSH Advisory Workgroup, demonstrates effort to adopt best practices and support recovery.

The regulations provide that the Universal Assessment Instrument will determine eligibility for AGSH, and “[e]ligible individuals shall be notified of the SH setting option and the availability of approved SH providers at the time of their annual level of care assessment.” Under this process, AGSH is offered to qualified individuals at the time of annual assessment.  The regulations appear to restrict this process to individuals currently residing in assisted living facilities. 

There is no reason to limit access to the AGSH only to those qualified individuals who reside in ALFs. The Uniform Assessment Instrument has been adopted for use by all publicly funded long-term care services, according to the official User’s Manual for the UAI. Therefore, the regulations should recognize a process for the identification of supportive housing in the UAI while an individual is residing in a state mental health facility prior to discharge. This process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment.  

We are truly grateful for all of the effort that state agencies and other stakeholders are making in launching this important program. We ask that you please consider our comments as you finalize the changes to 22VAC30-80 and refine the program guidelines. Thank you.

As the Virginia affiliate of Mental Health America, with 80 years of advocacy for the least restrictive community supports for people living with mental health conditions, we urge flexibility in supportive housing options. The draft regulations seem to unneccesarily limit eligibility for an Auxillary Grant in Supportive Housing to qualified individuals residing in assisted living facilities. 

The disAbility Law Center of Virginia has offered suggestions that regulations should recognize a process for identifying supportive housing in the Uniform Assessment Instrument while an individual is residing in a state mental health facility prior to discharge. As they have noted, this process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment.  We agree with this analysis, and encourage its adoption. 

Thank you for the opportunity to provide comment.

Bruce N. Cruser, Executive Director

Mental Health America of Virginia

The Virginia Association of Community Services Boards (VACSB) appreciates the opportunity to comment on these regulations.  VACSB has actively supportive of the ability for individuals with serious mental illness receiving the Auxiliary Grant to have greater flexibility and independence in their choice of living arrangements.  We are thrilled that 60 individuals finally have that chance.

VACSB would like to call your attention to one provision; however, that seems unnecessary given the pathway to qualifying for the Auxiliary Grant in Supportive Housing program.  

The regulations provide that the Universal Assessment Instrument will determine eligibility for AGSH, and “[e]ligible individuals shall be notified of the SH setting option and the availability of approved SH providers at the time of their annual level of care assessment.” Under this process, AGSH is offered to qualified individuals at the time of annual assessment.  The regulations appear to restrict this process to individuals currently residing in assisted living facilities. 

There is no reason to limit access to the AGSH only to those qualified individuals who reside in ALFs. The Uniform Assessment Instrument has been adopted for use by all publicly funded long-term care services, according to the official User’s Manual for the UAI. Therefore, the regulations should recognize a process for the identification of supportive housing in the UAI while an individual is residing in a state mental health facility prior to discharge. This process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment.

Thank you for your consideration.

As a person with lived mental health experience, and as a person who has worked extensively with people in the mental heatlh system, I believe in integrated community-based services and housing. I believe that the vast majority of problems society associates with people with mental illness could be avoided if appropriate and timely mental health services were readily available. Adequate community services keep people out of jails and hospitals which is ultimately a win for not only our peers but our communities. Delegate Farrell made the comment that we need to accept that some people need more help than others. I hope that help will come in the form of community supports as opposed to increased hospitalization. 

In regards to auxiliary grants in supportive housing, I share the concerns voiced by our friends at the disAbility Law Center:

The regulations provide that the Universal Assessment Instrument will determine eligibility for AGSH, and “[e]ligible individuals shall be notified of the SH setting option and the availability of approved SH providers at the time of their annual level of care assessment.” Under this process, AGSH is offered to qualified individuals at the time of annual assessment. The regulations appear to restrict this process to individuals currently residing in assisted living facilities. 
 
There is no reason to limit access to the AGSH only to those qualified individuals who reside in ALFs.  The Uniform Assessment Instrument has been adopted for use by all publicly funded long-term care services, according to the official User’s Manual for the UAI. Therefore, the regulations should recognize a process for the identification of supportive housing in the UAI while an individual is residing in a state mental health facility prior to discharge. This process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment." 

Thank you for your efforts and attention.

Malaina Poore