Comment - Deal

COMMONWEALTHof VIRGINIA
DEPARTMENTOF
MENTAL HEALTH, MENTAL RETARDATIONAND SWSTANCE ABUSESERWCES
Pos Office Box 1797
JAMES S. REIN}IARD, M.D
COMMISS]OI.IER

Richmso4 wgllJa

23218-1797

TelePhore (804) 786-3921
Voicer'TDD (804.) 37 | _9977
WWw.dmhmeqSt5te.ya-us

June23,2006
SummerKing
SAMHSA Reports ClearanceOfiicer
Room 1-1044
One Choke Cherry Road
Rockville, MD 20857
Re: ProposedCo-occurring Infrastructure Measuresfor COSIG (as referencedin the
FederalRegister,volume 71, number86, pp. 26382-3,datedMay 4,2006)

Dear Ms. King:
I am writing in support of commentssubmittedby Doctors Kenneth Minkoffand
Christie Cline on the above initiative, to the effect that:
l.

The processof data collection is definedoutside the partnershipbetweenthe
statesand SAMHS{ and outside the emergingpartnershipsbetweenthe states
and their own systems,not just programs,but the intermediaryentities that
coordinate behavioralhealth servicesin many states(e.g., community services
boards in Virginia).

2.

The data collected is basedon an incorrect or misleadingmodel for what the
majority of COSIG statesare doing with regard to ffiastructure development.

3.

The definitions that are used to describethe different functions are not fully
consistentwith what is happeningin the field, and not fully alignedwith
definitions that have been alreadydevelopedand articulatedby COCE, and

4.

The specific dataelementsrequestedare not consistentwith either assessingthe
state's actual infrastructure development,does not acknowledgethe needto
collect the information through countiesor community serviceboards, and
requestsinformation at the progr,iln level that is beyond the core universal
developmentalactivities that COSIG is designedto promote in state
infrastructure.

'

June23,2006
Letter to SummerKing
Page2

Our providers' information systemsdo not collect this information. We are currently in
the processof improving our capacityto collect data and a reporting requirementof this
scopewould not be feasiblefor sometime. Our concernis that implementingreporting
requirementsas defmedhere would reduce the momentumwe have built toward
infrastructure development. I would suggestany decisionson reporting requirementsbe
deferred until there has been time to reflect on the results of the evaluation efforts
underway this summer and that considerationbe given to an approachusing the systemlevel questionsput forward by Drs. Minkoffand Cline. Thank you for the opportunity to
comment.

SterlingDeal, Ph.D.

Virginia COSIGProjectDirector