Attachment C Comment

HAWAII DISABILITY RIGHTS CENTER
1132 Bishop Street, Suite 2102
Honolulu, Hawaii 96813
PhonelTTY: (808) 949-2922 Fax: (808) 949-2928 Toll Free: 1-800-882-1057
E mail: info@hawaiidisabilityrights.org
Website: www.hawaildisabilityrights .org
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April 11, 2011
Summer King, SAMHSA Reports Clearance Officer
Room 8-1099
1 Choke Cherry Road
Rockville, MD 20857
Re: Proposed Revision of PAIMI PPR (OMB No. 0930-0169)
76 FR 9032 (Feb. 16, 2011)
We offer the following comments for revising the annual program performance
report form for the PAIMI Program:
1. PPR Section 3.A.4 — Delete or clarify the following: "[include individuals who
received other services such as information and referral in-lieu]."
Information and referral services reported in PPR Section 6.A are distinct from
the number of individuals who were not served either due to insufficient
PAI1VII funding or non-priority issues. The language quoted above confuses
the two subjects and leads some P&As to report I&Rs in Section 3.A.4 as well
as in 6.A, while others do not include any I&Rs in Section 3.A.4.
2. ACR Section B.1 — Revise item B.1.m to read as follows: "Number of PAC
members who are either R/FR of MH services or family members of these
individuals (count each member only once but include both primary and
secondary IDs).
It is unclear from the present form whether the 60% requirement includes all
members in the specified categories or just the primary IDs. The proposed
change would clarify that all should be counted.
Very ti,ty yours,

iohn P. Dellera
Executive Director
041101.11

HAWAII'S PROTECTION AND ADVOCACY Sysrea FOR PEOPLE WITH DISABILITIES
HAWAII'S CUENT ASSISTANCE PROGRAM

CAP