Report 2020-103 Recommendation 1 Responses

Report 2020-103: California Department of Corrections and Rehabilitation: It Has Poorly Administered the Integrated Services for Mentally Ill Parolees Program, and With Current Funding Cuts, It Must Find Ways to Transition Parolees to County Services (Release Date: August 2020)

Recommendation #1 To: Corrections and Rehabilitation, Department of

To increase public safety and reduce the likelihood of recidivism, Corrections should establish a separate category in the appropriate data system to track the individuals who would have qualified for the integrated services program. It should also ensure that staff in the institutions, including mental health clinicians and staff involved in prerelease planning, coordinate with parole to assign these individuals to parole agents with specialized caseloads who have the training and experience to serve this population. Corrections should focus its efforts on at least the eight counties that are losing the integrated services program and complete the steps noted in this recommendation by February 2021.

Annual Follow-Up Agency Response From October 2023

The Department has already implemented parts of the CalAIM initiative through its enrollment of parolees into Medi-Cal benefits and assessments for mental health needs during the pre-release process. Based on their mental health needs, parolees are administered services through DAPO's Behavioral Health Reintegration. With the CalAIM initiative, DAPO or CCHCS will work with the counties to transition parolees to county mental health services. However, it should be noted that CalAIM may not apply to all releasing parolees since not all parolees may be eligible for Medi-Cal benefits and Medi-Cal eligibility is a pre-requisite to receiving CalAIM services. Medi-Cal benefits are voluntary as are CalAIM access services.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2022

2022 Update: Date of completion, pending federal approval. Since the issuance of the CSA 2020-103 audit, the Department of Health Care Services (DHCS) received federal approval for, and began implementing as of January 1, 2022, the California Advancing and Innovating Medi-Cal (CalAIM) and 1115 demonstration and 1915(b) waivers, the former of which will include 90-day pre-release from incarceration Medi-Cal services, targeted to be implemented on July 1, 2023, upon federal approval. After transitioning to the community, and once enrolled into a Medi-Cal Managed Care Plan, CDCR parolees will then have access to the new CalAIM Enhanced Care Management (ECM) and Community Supports (CS) benefits under the CalAIM Individuals Transitioning from Incarceration Population of Focus, also implementing on July 1, 2023, which provides an array of services that include and extend beyond those that would have been available in the past to ISMIP participants (e.g., primary care, Specialty Mental Health, Drug Medi-Cal, dental, and an array of community services and supports that address social determinants of health)). Given that all individuals releasing from CDCR who have mental health and/or substance use disorder conditions will have access to these CalAIM services, there is no longer a need to separately track ISMIP-like individuals. Accordingly, this audit item will be complete once the 90-day pre-release services, ECM and CS benefits for the Individuals Transitioning from Incarceration Population of Focus are implemented. Note: DHCS also revised/broadened the specialty mental health services criteria to increase access.

Supporting documentation will be submitted per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: Post Release Mental Health Needs Identifiers have been determined. Information technology requirement gathering has been initiated, with an implementation goal for the first quarter of 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

Develop an algorithm to identify qualifying diagnostic data in the appropriate data system, and include community functioning level scores currently assessed pre-release by institution mental health staff, and "at risk of homelessness" upon release. The algorithm will trigger an identifying code as an indicator of releasing inmates that would have qualified for the Integrated Services for Mentally Ill Parolees (ISMIP) program.

Evaluate the feasibility of establishing specialized caseloads for parole agents providing supervision to parolees that would have qualified for the ISMIP program. This evaluation will include anticipated parole population and related parole agent staffing reductions, resulting from new parole term caps that took effect 7/1/2020.

1-Year CAP Update: Post Release Mental Health Needs Identifiers have been determined. Information technology requirement gathering has been initiated, with an implementation goal for the first quarter of 2022.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

After further review of the Medi-Cal specialty mental health services medical necessity criteria, it has been determined that it is not broad enough to include all potential ISMIP participants. As such, CDCR has shifted efforts toward analyzing the deleted Penal Code 2985.2(c), which outlined the ISMIP program participant requirements that existed prior to the elimination of the program, in order to operationalize and develop a method to identify and electronically track individuals who would have been in the ISMIP program had it continued. As part of this effort, CDCR will engage with internal and external stakeholders, as needed.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Develop an algorithm to identify qualifying diagnostic data in the appropriate data system, and include community functioning level scores currently assessed pre-release by institution mental health staff, and "at risk of homelessness" upon release. The algorithm will trigger an identifying code as an indicator of releasing inmates that would have qualified for the Integrated Services for Mentally Ill Parolees (ISMIP) program.Evaluate the feasibility of establishing specialized caseloads for parole agents providing supervision to parolees that would have qualified for the ISMIP program. This evaluation will include anticipated parole population and related parole agent staffing reductions, resulting from new parole term caps that took effect 7/1/2020.

Specialty mental health services criteria requested and received via email from the Medi-Cal Behavioral Health Division with the California Department Health Care Services, to assist in identifying eligible candidates and establishing algorithm.Refined eligibility criteria requested from the eight counties via the California Behavioral Health Director's Association.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2020-103

Agency responses received are posted verbatim.