Comments

Attachment D - SOR TOR Comments 12.20.18.pdf

State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection and Performance Measurement

Comments

OMB: 0930-0384

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Sally Gibson
King, Summer (SAMHSA/OPPI)
Clark, Spencer (SAMHSA/CSAT/DPT)
SOR Program Data Collections and Performance Measurement
Friday, October 19, 2018 11:52:06 AM

Summer
 
Good morning.  I wanted to send this email to give you requested feedback on Data Collections and Performance Measurement from email  dated 10-17-18. 
 
Overall comments from staff:
 
The client instrument is very long, and many elements could be pulled from the EHR or chart. It seems clunky and duplicative until you get to the questions that actually are client facing. For that section, my question would really be one of workflow. We are going to face similar challenges to what we are with ISAPs: our staff’s capacity *and* client compliance.
 
It would certainly be more cumbersome and time consuming. In order to do it, we would need more staff to handle the increased workload.
 
This is basically the same evaluation protocol for other SAMHSA grants, except we have dedicated evaluation staff for those grants, covered by those grants, to collect these data. Does this come with any financial support to cover evaluation time?  Depending on the client number/caseload, this could be at least a 0.5-1.0 FTE, especially after the case load gets established.
 
To get at some of what was asked below, for feedback, the burden of data collection is relatively significant (again, depending on the client numbers). This is in no small part due to the fact that it’s a relatively long interview (30-60 minutes), and it’s a longitudinal design, (potentially) even after discharge - and this client population isn’t known for their follow-through. Essentially, we could
(would need to?) dedicate a lot of time to tracking procedures if we wanted to ensure a higher response rate (which SAMHSA is always looking for).
 
As far as the utility of the data, I like the NOMs (overall – it’s not perfect), and I like it for monitoring outcomes, QI, etc. So, it’s pretty good data, if you can get it.
 
Ways to make this easier would include phone interviews and pulling as much info from the EHR as possible. Also, not getting the 3- and 6- month follow-ups after discharge… I think doing anything they can to reduce the data being collected would also be helpful, especially at follow-up and discharge intervals…
 
If we have to collect these, I think we’re going to need to talk about hiring additional staff, and incentives would help…
 
I think that overall, staff feel that this will add significant additional workload and will require additional staff and that some of the information is already being gathered so it is a duplication of what is already being done.  It would be nice to see if we can find a way gather the data in a more streamlined way without duplication.
 
Thanks
Sally
 
 
From: Clark, Spencer (SAMHSA/CSAT/DPT) 
Sent: Wednesday, October 17, 2018 4:44 PM
To: lauren.siembab@ct.gov; Michael.parks@maine.gov; Tom.Connors@maine.gov; Katherine.Coutu@maine.gov; Allison.bauer@state.ma.us; amy.sorensen-alawad@state.ma.us; Nicole.m.schmitt@state.ma.us; Jennifer.miller@state.ma.us; Hannah.Lipper@state.ma.us; Abby.Shockley@dhhs.nh.gov; Donald.Hunter@dhhs.nh.gov; Cynthia.Thomas@vermont.gov;
Megan.Mitchell@vermont.gov; Mariah.Ogden@vermont.gov; sgoldsby@daodas.sc.gov; dwalker@daodas.sc.gov; ckraeff@daodas.sc.gov; bpowell@daodas.sc.gov; rbraneck@daodas.sc.gov; taryn.sloss@tn.gov; linda.mccorkle@tn.gov; Anthony.jackson@tn.gov; richard.sherman@illinois.gov; terry.cook@fssa.in.gov; Rebecca.Buhner@fssa.IN.gov; Jeremy.Heyer@fssa.IN.gov;
Cassandra.Anderson2@fssa.IN.gov; Mark.Loggins@fssa.IN.gov; Kelly.Welker@fssa.IN.gov; ScottL11@michigan.gov; BullardS@michigan.gov; SmithA8@michigan.gov; dave.rompa@state.mn.us; faye.bernstein@state.mn.us; Ellen.Augspurger@mha.ohio.gov; Sanford.Starr@mha.ohio.gov; joyce.allen@wisconsin.gov; Jason.Harris@dhs.wisconsin.gov; Scott.stokes@dhs.wisconsin.gov;
tcroom@odmhsas.org; monica.wilke-brown@idph.iowa.gov; Sharon.Kearse@ks.gov; Gowdy, Rick ; rachel.winograd@mimh.edu; philip.horn@mimh.edu; tamara.gavin@nebraska.gov; Marlies.Perez@dhcs.ca.gov; tfsunia@dhss.as; herbert.sablan@gmail.com; bvictor@fsmhealth.fm; athena.duenas@gbhwc.guam.gov; temengil.ej@gmail.com
Subject: Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection and Performance Measurement—NEW
Dear STR and SOR Project Directors and Staff:
 
This is in follow-up to my correspondence to you of last week, indicating the publication of a Federal Registry Notice (FRN) containing the proposed reporting guidelines for the SOR and TOR Grant initiatives.
 
Please find attached below the proposed SOR information plans and reporting instruments that were referenced in the recent posting of the Federal Register for your review and comment.
 
I cannot emphasize too greatly how important it is for you to carefully review and comment on these reporting tools, and provide whatever recommendations that you have regarding implementation issues. 
 
I am hopeful that with your feedback we can enter into a meaningful dialogue to maximize the usefulness of this reporting, and minimize any unnecessary reporting burden.
 

Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57-B, Rockville, Maryland 20857, OR email a copy to summer.king@samhsa.hhs.gov.
 

Written comments should be received by December 3, 2018.
I would appreciate your copying me on any feedback that you provide in this process so that I can be fully prepared to participate in this dialogue.
 
Thank you and best regards,
 

Spencer Clark
 
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857 
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
 

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Burrell Behavioral Health
      

Sally Gibson

VP of Addiction Services

Sally.Gibson@burrellcenter.com
(417) 761-5405
www.burrellcenter.com

Burrell Behavioral Health • 1931 E. Cherry Street • Springfield • MO • 65802

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California Department of Health Care Services’ Public Comment on Proposed
State Opioid Response Program Data Collection and Performance Measurement
Summary
The California Department of Health Care Services (“DHCS”) is committed to providing
data necessary for the Substance Abuse and Mental Health Services Administration
(“SAMHSA”) to fulfill the Government Performance and Results Modernization Act of
2010 requirements, as well as ensuring that program goals and objectives of the State
Opioid Response (“SOR”) grant are met. The Grantee Level Tool SAMHSA has
proposed is straightforward, easy to understand, and not overly burdensome.
However, the Client-Level Data Collection Tool (“Client Tool”) that SAMHSA proposes is
exceptionally complicated and lengthy, which would create an immense burden on
providers and cause resources to be shifted away from providing direct patient care. As
a result, DHCS recommends that the Office of Management and Budget deny
SAMHSA’s current request and urge that the Client Tool be revised and abbreviated,
such that it continues to collect sufficient data on patient treatment but does not impose
excessive burdens on treatment providers.
Extensive Client Tool and Administrative Burden to DHCS
At over forty pages in length, the Client Tool is substantially more complex than the
Client Tool currently being utilized by DHCS’ subrecipients for the State Targeted
Response to the Opioid Crisis (“O-STR”) grant. DHCS has been informed by its
subrecipients that a material number of patients are unwilling to submit the information
requested by the existing Client Tool. It is anticipated that the numbers of patients
declining to provide information will increase as a result of the complexity and length of
the proposed reporting tool. This could potentially lead to the collection of less accurate
data on the sample of patients receiving services as part of the SOR, which would run
counter to the objectives of the data collection.
The constraints of the current system prevent DHCS’ subrecipients from inputting
information electronically, increasing the administrative burden on California. In the
current process, only two of DHCS’ subrecipients were selected to submit data. These
subrecipients submit electronic copies of the forms to DHCS, where DHCS personnel
enter the information into the web-based system. DHCS analysts spend approximately
fifteen minutes entering data from each respective form. California estimates data entry
for the SOR form to increase to a minimum of twenty minutes, adding to the
administrative burden.
DHCS recommends the following solutions to remedy the issue: 1) SAMHSA allow
DHCS to designate subrecipients and subrecipients of subrecipients to have their own
accounts in the SAMHSA Performance Accountability and Reporting System (SPARS)
system used to enter Client Tool data. This will create a mechanism for subrecipients to
enter data directly into the system as they conduct interviews; 2) abbreviate the form to
request slightly less detailed information, as this would reduce the time required for
subrecipients to interview patients and increase adherence of the Client Tool data
collection requirements; and 3) allow data to be collected for only a sample of the
Page 1 of 2

California Department of Health Care Services’ Public Comment on Proposed
State Opioid Response Program Data Collection and Performance Measurement
programs and sites to be funded through the grant. These proposed recommendations
fulfill SAMHSA’s performance objectives, while also easing administrative burdens and
efforts needed by providers to collect relevant data.
Treatment Services Definition
DHCS is concerned that use of the phrase treatment services is not adequately defined
in the draft regulations and is likely to cause data to be collected inconsistently by
subrecipients. DHCS recommends that a full, specific, and well-defined explanation of
treatment services be provided, so that programs may be consistent in the data that
they are collecting. This is necessary for meaningful comparisons to be performed
between programs and grantees.
Supporting Statement regarding Confidentiality of Client Data
The supporting statement provided does not provide sufficient assurance that SAMHSA
will protect patient data from unauthorized access or release. The specific statement
that “SAMHSA cannot ensure complete confidentiality of client data” provided on page
four of the document is unlikely to remedy existing client attitudes about providing
extensive data that may be received by malicious parties. Many patients may simply
choose to decline to provide the information, impacting the veracity of the data.
Follow-up Requirements
The estimation of patients required to submit follow-up information, even after
discharging from the program, is unreasonable. This requirement adds to existing
burdens on programs and would require programs to shift resources away from direct
patient care. DHCS recommends that the 80% follow-up requirement be reduced to an
attainable percentage.
Conclusion
DHCS has determined that if the Client Tool is not significantly redesigned, it will create
an added burden on treatment providers and is likely to result in information being
collected inconsistently among programs and patients. DHCS recommends that
SAMHSA consider the simplicity and ease of use of the Grantee Level Tool when
revising the Client Tool and consider using the abbreviated tool currently being used for
the O-STR projects. Lastly, DHCS requests that any subsequent divisions to either of
the reporting tools be resubmitted for further public comment.

Page 2 of 2

From:
To:
Cc:
Subject:
Date:

Fred Rottnek
King, Summer (SAMHSA/OPPI)
Fred Rottnek
Comments on proposed reporting guidelines for the SOR and TOR Grant initiatives
Friday, October 19, 2018 4:42:01 PM

Thank you for allowing us the opportunity to comment on proposed reporting guidelines.
In addition to my information below, I am very involved with the current STR and future SOR
programs through a few avenues:
1. I contract with the Missouri STR team for training, in-services, and resource development.
(30% of my time)
2. I contract with ARCA as medical director. (another 30% of my time) At ARCA, we provide onsite and telehealth addiction medicine and co-occurring disorder services to 19 agencies at 37
sites around the state. We are on-track to see over 36,000 unduplicated patients in 2018.
 
When I reviewed these guidelines, a few things jumped out at me.
1. The questions are incredibly relevant to the population we are serving.
2. The reporting requirements as drafted seem to turn a primary service grant (STR being 76% in
treatment and recovery support) into some type of hybrid service and research grant.
3. The reporting requirements as drafted would be so onerous to our staff and patients, that
they would functional serve as a barrier to treatment.
 
While I am no expert in research design, I propose a way to gather a statistically significant number
of the proposed questions which minimizing reporting data for the bulk of clients treated.
For example, could the full reporting drafted here be mandated for a fraction of patients treated?
Say 10-25% of total patients.
The patients who provide the full reporting information could be randomized for each site, by
SAMHSA (or contracted entity) or by the agency, so that the bulk of clients experience expedited
enrollment, i.e., questions related to the most salient questions.
With this approach, significant data could be collected on a minority of patients. While this would be
additional work compared to the current process, it would not be as onerous as the reporting
structure proposed.
 
Thank you for your consideration,
 
Fred Rottnek, MD, MAHCM 
Professor
Director of Community Medicine, Department of Family and Community Medicine 
Board-certified in Family Medicine and Addiction Medicine
Medical Director, Physician Assistant Program
Saint Louis University School of Medicine 
1402 South Grand Boulevard
St. Louis, MO 63104
 
Campus Office: 2nd Floor O'Donnell Hall, 1320 South Grand Boulevard
(P) 314-977-8489 (F) 314-977-5268 rottnekf@slu.edu

 

STATE OF CONNECTICUT
DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES
A Healthcare Service Agency

DANNEL P. MALLOY
GOVERNOR

MIRIAM E. DELPHIN-RITTMON, PH.D.
COMMISSIONER

Agency Information Collection Activities: Proposed Collection
COMMENT REQUEST
To:
Submitted by:

Summer.king@samhsa.hhs.gov
Lauren Siembab, SOR grant Project Director

a. Whether the proposed collections of information are necessary for the proposer performance of
the functions of the agency, including whether the information shall have practical utility.
Assuming that the “agency” is the SSA, the collection of client level data via the GPRA is not necessary
since this SSA already has a mechanism for collecting client level data for SAMHSA funded treatment
projects, as we do for TEDS reporting. We are able to evaluate “connect to care” and “re-admission to
treatment” rates with this same data. However, the GPRA interviews do provide richer data from the
participant perspective, and could be measures that are of specific value for SOR beyond the generally
available treatment data the SSA usually gets. Unfortunately, SAMHSA does not allow adequately for the
cost of administering 3-4 GPRA interviews per client, particularly if these are conducted by the preferred
“neutral” third party rather than the service provider(s).
The version of the GPRA given to the SOR sites to review is markedly different from the version
currently in use for most of the CSAT projects. Although there certainly can be value in modifying the
instrument so that there are items of specific interest for a particular project, keeping the majority of the
items the same (or similar) in content and format would enhance ease of training and administration, as
well as the ability to compare results across projects. If additional components are added, it seems that
MAT-specific questions would be useful.
b. The accuracy of the agency’s estimate of the burden of the proposed collection of information.
Overall, the estimate of burden is for GPRA interviews time is correct for the current version in use.
However, the proposed version is longer and more confusing and will likely take longer to administer.
What is not taken into account in the “burden estimate” is the amount of time expended trying to locate
the individuals to conduct the follow-up interview(s), which in some cases is substantial.
c. Ways to enhance the quality, utility and clarity of the information to be collected.
1. Stick to one version of GPRA for the long-haul
2. Reduce the number of questions and pages SUBSTANTIALLY.
3. Remove the requirement for the 6 month follow-up or provide adequate funding for tracking and
administration.
d. Ways to minimize the burden of the collection of information on respondents, including
through the use of automated collection techniques or other forms of information technology.
Consider separate “frameworks”/formats for States to use for reporting treatment, prevention, recovery
support, training and TA, and naloxone purchases; minimal detail beyond #’s served.

From:
To:
Subject:
Date:

Noble Shaver
King, Summer (SAMHSA/OPPI)
Reporting requirements for SOR
Thursday, October 18, 2018 1:47:00 PM

The GPRA for STR is a long tool, it adds a 3 month reporting time ( not required with STR), so if the
benchmark is 80% compliance in reporting like STR, this will add a layer of time for something  that for us
that is already very labor intensive in tracking , locating and administering. I fear we might lose potential

consumer's wanting treatment because of the lengthy requirements to receive services. The
Medication First model works well because it eliminates red tape and puts the consumer in
front of a physician quickly. I fear if we start to add new requirements now the ability to act
quickly and efficiently could fade. I believe that the collaboration taking place in Missouri
between providers, Department of Behavioral Health, and Missouri Institute for Mental Health
requiring the GPRA is a duplication of data collection. 
Thank you for your time
Noble Shaver Jr., MA, LPC, CRADC, NCC
Chief Clinical Officer Substance Use Disorders, Housing, & Outreach Services 573-888-5925 ext.
1501
Kennett, MO. 63857
nobles@fccinc.org

Person-Centered Recovery & Wellness
FCC is an equal opportunity provider and employer
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From:
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Cc:
Subject:
Date:
Attachments:

Moody-Geissler, Stephanie
King, Summer (SAMHSA/OPPI); Bankhead, Jamal (SAMHSA)
Gazioch, Ute
60-Day FRN for State Opioid Response Grant (Short Title: SOR) Data Collection Tool
Monday, December 3, 2018 12:16:47 PM
Attachment A - SOR TOR Client Instrument_EDITS.docx

Dear Summer King,
 
Thank you for the opportunity to comment on the on the State Opioid Response Grant (Short Title:
SOR) Data Collection Tool. Please find attached comments and edits I would like to put forth for the
tool.
 
Please feel free to contact me if you have any questions concerning this document, edits, or
comments.
 
Thank you,
Stephanie Moody-Geissler
 
Stephanie M. Moody-Geissler, MPH
Lead Epidemiologist
Overdose Prevention
Office of Substance Abuse and Mental Health
Florida Department of Children and Families
1317 Winewood Blvd., Bldg. 6, Room 272
Tallahassee, FL  32399
Office: (850) 717-4329
Stephanie.Moodygeissler@myflfamilies.com
 

From:
To:
Subject:
Date:
Attachments:

Kyle Mead
King, Summer (SAMHSA/OPPI)
Re: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement—NEW
Thursday, October 25, 2018 1:16:36 PM
Outlook-v5lto2o0.png
Outlook-cid_image0.png

I would like to reiterate what so many of my colleagues have already stated. The
implementation of an electronic health record should have made data collection and sharing
much easier and it has internally. However, external sharing is incredibly complicated already
and as a small non-profit the time spent on staff dedicated to redundant data entry into
multiple electronic systems is becoming overwhelming.
The human factor of errors as a result of repetitively entering the same information into
multiple systems is neither efficient nor effective. We are already burdened with fixing this
errors that are inevitable with redundancies such as we already experience. 
There simply must be a better way than adding this to our already stretched resources. We
already gather so much of this information and have to enter it into at least 2 systems and often
as many as 4 systems dependent upon the payer and referent. Integration with the state CIMOR
system here in Missouri would be more logical than passing this burden down to the providers
who should be using their resources to provide consumer care. 
Kyle Mead
Vice President of Behavioral Health Services
Heartland Center for Behavioral Change
816 421-6670 ext. 1296
kmead@heartlandcbc.org

From: shauntay McCollough 
Sent: Tuesday, October 23, 2018 11:05:21 AM
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'Moore, Jonathan'; 'Salvation Army - TSA Midland Contracts'; 'Turning Point - Gary Stoner'; 'Turning
Point - John Pruett'; 'Turning Point - Virginia Frese'; 'Westend Clinic - Pamela Byes'; 'Miller, Oval';
'Carter, Hardy'; 'CMHC - Cindy Brannan'; 'CMHC - Jerry Morris'; 'Swinfard, Tim'; 'Comprehensive Jenny Miller'; 'Pigg, Margo'; 'Family Guidance - Garry Hammond'; 'Jackson, Derek'; 'Brown, Joshua';

'FCC - Ken Tombley'; 'FCC - Misty Brazel'; 'FCC - Noble Shaver'; 'Parrigon, Mary'; 'Gibson Center - John
Gary'; 'Payden, Vernon'; 'Gibson Recovery - Ryan Essex'; 'Gibson Recovery - Sherry Eakers'; 'Camp,
Timothy'; 'Preferred - Pam Leyhe'; 'Brawner, Paula'; 'Queen of Peace - Clara Stevenson'; 'Tri-County
MHS - Jan Pool'; 'Truman Medical - Douglas Burgess'; 'Carter, Wardell'
Cc: 'Brent McGinty'; ''Emily Conde''; 'Rembecki, Mark'; 'Cook, Natalie'; 'Turner, Rhonda'; 'Rudder,
Timothy'; 'Smyser, Melissa'; 'Blume, Susan'
Subject: RE: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement
—NEW

 
I hope and pray that this is not something that will be implemented here in Missouri.  Our facility along
with others are doing a greater job than just a year ago with the tools that we have now and adding
additional data request will only cause the loss of consumer participation along with loss of billing due
to a non reimbursable additional questionnaire.  I understand the need for the data but, this seems to
be more about numbers and data instead of the actual service to the consumer.  Thank you for your
time and I hope the response’s from myself and others will make a direct impact on the decisions
being made.

Shauntay McCollough B.S.
Chief Executive Officer
New Beginnings C-STAR Inc.
1027 S. Vandeventer, Floor 3
St. Louis, MO  63110
PH: (314) 367-8989 Ext. 254
FX: (314) 367-2188
EM: shauntay@newbeginningscstar.org
CN: (314) 757-0106
Mathew 20:16 

-----Original Message----From: Bock, Nora [mailto:Nora.Bock@dmh.mo.gov]
Sent: Thursday, October 18, 2018 1:04 PM
To: Gardine, Cheryl; Menzies, Suneal; Johnson, Clif; Cori Putz (cmoore@pfh.org); Geoff Moeller;
lmccallister@placesforpeople.org; NCADA - St. Louis - Nichole Dawsey; NCADA St Louis - Jenny
Armbruster; New Beginnings - Freda Theus; McCollough, Shauntay; Cheung, Chi; New Horizons - Laura
Porting; New Horizons - Shanna Behrens; New Horizons - Stacy Doggett; North Central MO - DeAnna
Savage; Irvine, Lori; North Central MO - Tammy Floyd; Francis, Lisa; Mieseler, Vicky; Ozarks Medical
Center - Curtis Cook; Ozarks Medical Center - Joy Anderson; Pathways - Amy Blake; Pathways - Becky
Camden; Pathways - Elisabeth Brockman-Knight; Pathways - Gloria Miller; Pathways - Julia Bozarth;
Yach, Kristen; Pathways - Linda Grgurich; Pathways - Mel Fetter; Pathways - Shannon CrowleyEinsphar; Pathways - Todd Martensen; Foster, Tonie; Greening, Andrew; PFH - Andrew Schwend;
Hutton, Ann; Putz, Cori; PFH - Darlene Harrell; PFH - Jason Hinckley; PFH - Lorinda Meyer; PFH Marilyn Nolan; PFH - Nancy Atwater; PFH - Rhonda Ferguson; PFH - Una Bennett ; Phoenix - Laura
Cameron; Phoenix - Rhiannon Ross; Phoenix - Teresa Goslin; Phoenix Health Programs - Tracy

McIntyre; Places for People - Diane Maguire; Places for People - Nicole Stewart; Bayliff, Scott; Places
for People - Tiffany Lacy Clark; Spruell, Sharon; Flory, Alan; ReDiscover - Elizabeth Deason; ReDiscover Jennifer Craig; ReDiscover - John Dean; ReDiscover - Lauren Moyer; ReDiscover - Marsha Page; Busiek,
Gary; Beck, Kimberly; SAMHSA Regional Administrator Region VII - Kimberly Nelson; Angela Toman,
CRPS; Brenda Felkerson; Cathy Schroer BS; Dan Adams MBA; Jason W. Gilliam MBA MHA AICP; Storey,
Janice; Swope Health - Kortney Carr; Swope Health - Mark Miller; Holm, Christy; Tri-County - JoAnn
Werner; Tri-County - Talina Nelson; Tri-County - Tom Petrizzo; Truman Medical Center - Barbara
Warner; Zaiger, Bethany; Truman Medical Center - Jodi Gusman; Truman Medical Center - Mark
VanMeter; Truman Medical Center - Sharon Freese; Turning Point - Catie Franklin; Turning Point Heather Higgins; Allyson Ashley; Fred Rottnek; Menzies, Percy; Arthur Center - Kristin Fishback; Arthur
Center - Rachel Ward; BASIC - Keturah Ibrahim; BASIC - Kirby Anderson-El; Johnson, Lola; BASIC Michael Batchman; BASIC - Robin Smith; Singleton, Yulonda; BHR Worldwide - Angela Tate; BHR
Worldwide - Bart Andrews; BJC - Karen Miller; Bootheel Counseling - David Terrell; Kassinger, Micaela;
Brandon, Teresa; Bridgeway - Craig Miner; Bridgeway - Jack Barnett; Morrison, Mike; Burch, Mitzi;
Burell - CJ Davis; Burrell - Cristin Martinez; Burrell Center - Adam Andreassen; Burrell Center - Austin
Burdine; Burrell Center - Bethany Silliman; Burrell Center - Brent Sugg; Burrell Center - Christopher
Orr; Burrell Center - Denise Mills; Burrell Center - Gina Burroughs; Burrell Center - Hunter Houston;
Burrell Center - Lauren Pratt; Burrell Center - Leslie Corbiere; Gass, Mathew; Burrell Center - Megan
Steen; Burrell Center - Sally Gibson; Burrell Center - Shae Hitchock; Burrell Center - Stephanie MarchHopkins; Burrell Center - Stephen Koch; Burrell Center - Wes Starlin; Camp, Timothy; CCC - Brenda
Robertson; CCC - Lonnie Lusk; Ridenour, Brad; Clark CMHC - Debbie Schoon; Beatie, Laura; Clark
Mental Health - Christy Henley; CMHC - Jenny Wright; Anderson, Carl; CMHS - Jenny Duncan; CMHS Julie Pratt; CMHS - Tara Yardley; CommCARE - Erica Immenschuh; Compass Health / McCambridge Angela Allphin; COMTREA - Agnes Jos; COMTREA - Andrea Cuneio; COMTREA - Jonathan Cochran;
COMTREA - Rachael Bersdale; Susan Curfman; Crider - Carrie Rigdon; Crider - Laura Heebner; Crider Nancy Gongaware; Crider - Victoria Walker; Family Guidance - Elizabeth Sprung; Family Guidance Kristina Hannon; Family Guidance - Rachel Evans; Family Guidance - Raven Hutchison; Family Guidance
- Rebekah Quillin; Family Guidance - Robin Reynozo; Family Self Help - Alison Malinowski Sunday;
Family Self Help - Gwen Ewing; FCC - Ashley Singleton; FCC - Kelley Wilbanks; FCC - Melissa
Weatherwax; FCC - Randy Ray; FCC - Shawn Sando; First Call - Susan Whitmore; Freeman Health Melissa Moore; Freeman Health - Spencer Ellis; Feaman, Kimberly; Doherty, Steve; Hannibal Council
dba Turning Point - Jennifer Wilson; Hannibal Council dba Turning Point - Kettisha Hodges; Heartland
Center - Carolyn Ross; Heartland Center - Kyle Mead; Hinton, Tineen; Hopewell Center - Barbara
Tucker; Butler, Dwayne; Hopewell Center - Lynette Jones; Franklin, Wil; Higginbotham, Jennifer;
Independence Center - Jocelyn Hertich; Independence Center - Paul Schoenig; Karl, Barbara; Lafayette
House - Teddy Brown; Mark Twain; McMahon, Cory; Midwest Assessment - Catie Platt; Mineral Area
CPRC - Karen Ferrell; Mineral Area CPRC - Vicky Winick; Terry Trafton (ttrafton@CommCARE1.org);
Beck, Kimberly; Busiek, Gary; eydie caughron; CMHC - Jerry Morris; CMHC - Kate Hogsett; CMHC - Nate
Gulliford; CMHC - Terri Morris; Lafayette House - Deb Allman; Lafayette House - Teddy Brown; Moore,
Jonathan; Salvation Army - TSA Midland Contracts; Turning Point - Gary Stoner; Turning Point - John
Pruett; Turning Point - Virginia Frese; Westend Clinic - Pamela Byes; Miller, Oval; Carter, Hardy; CMHC
- Cindy Brannan (cmhc.nmh.cbrannan@gmail.com); CMHC - Jerry Morris (cmhcjerry@sbcglobal.net);
Swinfard, Tim; Comprehensive - Jenny Miller (jemil@thecmhs.com); Pigg, Margo; Family Guidance Garry Hammond (ghammond@FGCnow.org); Jackson, Derek; Brown, Joshua; FCC - Ken Tombley
(ken.tombley@fccinc.org); FCC - Misty Brazel (mistyb@fccinc.org); 'FCC - Noble Shaver'; Parrigon,
Mary; Gibson Center - John Gary (garyj@gibsonrecovery.org); Payden, Vernon; Gibson Recovery - Ryan

Essex (essexr@gibsonrecovery.org); Gibson Recovery - Sherry Eakers (eakerss@gibsonrecovery.org);
McCollough, Shauntay; Camp, Timothy; Preferred - Pam Leyhe (pleyhe@pfh.org); Brawner, Paula;
Queen of Peace - Clara Stevenson; Tri-County MHS - Jan Pool (janp@tri-countymhs.org); Truman
Medical - Douglas Burgess (douglas.burgess@tmcmed.org); Carter, Wardell
Cc: 'Brent McGinty'; 'Emily Conde' (econde@mocoalition.org); Rembecki, Mark; Cook, Natalie; Turner,
Rhonda; Rudder, Timothy; Smyser, Melissa; Blume, Susan
Subject: RE: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement
—NEW
Thanks, Cheryl.
Everyone: Again, please respond formally via the process outlined in the e-mail – SAMHSA needs to
hear from you!

From: cheryl gardine 
Sent: Thursday, October 18, 2018 1:02 PM
To: Menzies, Suneal ; Johnson, Clif ;
Bock, Nora ; Cori Putz (cmoore@pfh.org) ; Geoff
Moeller ; lmccallister@placesforpeople.org; NCADA - St. Louis - Nichole
Dawsey ; NCADA St Louis - Jenny Armbruster ;
New Beginnings - Freda Theus ; McCollough, Shauntay
; Cheung, Chi ; New Horizons Laura Porting ; New Horizons - Shanna Behrens ; New Horizons - Stacy Doggett ; North Central
MO - DeAnna Savage ; Irvine, Lori ; North Central MO Tammy Floyd ; Francis, Lisa ; Mieseler, Vicky
; Ozarks Medical Center - Curtis Cook
; Ozarks Medical Center - Joy Anderson
; Pathways - Amy Blake ;
Pathways - Becky Camden ; Pathways - Elisabeth Brockman-Knight
; Pathways - Gloria Miller ; Pathways - Julia
Bozarth ; Yach, Kristen ; Pathways - Linda
Grgurich ; Pathways - Mel Fetter ; Pathways Shannon Crowley-Einsphar ; Pathways - Todd Martensen
; Foster, Tonie ; Greening, Andrew
; PFH - Andrew Schwend ; Hutton, Ann
; Putz, Cori ; PFH - Darlene Harrell ; PFH Jason Hinckley ; PFH - Lorinda Meyer ; PFH - Marilyn Nolan
; PFH - Nancy Atwater ; PFH - Rhonda Ferguson
; PFH - Una Bennett ; Phoenix - Laura Cameron
; Phoenix - Rhiannon Ross
; Phoenix - Teresa Goslin
; Phoenix Health Programs - Tracy McIntyre
; Places for People - Diane Maguire
; Places for People - Nicole Stewart

; Bayliff, Scott ; Places for People Tiffany Lacy Clark ; Spruell, Sharon ; Flory, Alan
; ReDiscover - Elizabeth Deason ;
ReDiscover - Jennifer Craig ; ReDiscover - John Dean
; ReDiscover - Lauren Moyer ; ReDiscover Marsha Page ; Busiek, Gary ; Beck,
Kimberly ; SAMHSA Regional Administrator Region VII Kimberly Nelson ; Angela Toman, CRPS ;
Brenda Felkerson ; Cathy Schroer BS ; Dan Adams
MBA ; Jason W. Gilliam MBA MHA AICP ; Storey, Janice
; Swope Health - Kortney Carr ; Swope Health
- Mark Miller ; Holm, Christy ; Tri-County JoAnn Werner ; Tri-County - Talina Nelson ;
Tri-County - Tom Petrizzo ; Truman Medical Center - Barbara Warner
; Zaiger, Bethany ; Truman Medical
Center - Jodi Gusman ; Truman Medical Center - Mark VanMeter
; Truman Medical Center - Sharon Freese
; Turning Point - Catie Franklin ; Turning
Point - Heather Higgins ; Allyson Ashley ;
Fred Rottnek ; Menzies, Percy ;
Arthur Center - Kristin Fishback ; Arthur Center - Rachel Ward
; BASIC - Keturah Ibrahim ; BASIC - Kirby AndersonEl ; Johnson, Lola ; BASIC - Michael Batchman
; BASIC - Robin Smith ; Singleton, Yulonda
; BHR Worldwide - Angela Tate ; BHR Worldwide
- Bart Andrews ; BJC - Karen Miller ; Bootheel
Counseling - David Terrell ; Kassinger, Micaela
; Brandon, Teresa ; Bridgeway Craig Miner ; Bridgeway - Jack Barnett ;
Morrison, Mike ; Burch, Mitzi ;
Burell - CJ Davis ; Burrell - Cristin Martinez
; Burrell Center - Adam Andreassen
; Burrell Center - Austin Burdine
; Burrell Center - Bethany Silliman
; Burrell Center - Brent Sugg ;
Burrell Center - Christopher Orr ; Burrell Center - Denise Mills
; Burrell Center - Gina Burroughs
; Burrell Center - Hunter Houston
; Burrell Center - Lauren Pratt
; Burrell Center - Leslie Corbiere
; Gass, Mathew ; Burrell
Center - Megan Steen ; Burrell Center - Sally Gibson
; Burrell Center - Shae Hitchock
; Burrell Center - Stephanie March-Hopkins ; Burrell Center - Stephen Koch ;
Burrell Center - Wes Starlin ; Camp, Timothy

; CCC - Brenda Robertson ; CCC - Lonnie
Lusk ; Ridenour, Brad ; Clark CMHC - Debbie
Schoon ; Beatie, Laura ; Clark
Mental Health - Christy Henley ; CMHC - Jenny Wright
; Anderson, Carl ; CMHS - Jenny Duncan
; CMHS - Julie Pratt ; CMHS - Tara Yardley
; CommCARE - Erica Immenschuh ;
Compass Health / McCambridge - Angela Allphin ; COMTREA - Agnes Jos
; COMTREA - Andrea Cuneio ; COMTREA - Jonathan
Cochran ; COMTREA - Rachael Bersdale ; Susan
Curfman ; Crider - Carrie Rigdon ; Crider - Laura
Heebner ; Crider - Nancy Gongaware ;
Crider - Victoria Walker ; Family Guidance - Elizabeth Sprung
; Family Guidance - Kristina Hannon ; Family
Guidance - Rachel Evans ; Family Guidance - Raven Hutchison
; Family Guidance - Rebekah Quillin ; Family
Guidance - Robin Reynozo ; Family Self Help - Alison Malinowski Sunday
; Family Self Help - Gwen Ewing ; FCC Ashley Singleton ; FCC - Kelley Wilbanks ; FCC - Melissa
Weatherwax ; FCC - Randy Ray ; FCC - Shawn Sando
; First Call - Susan Whitmore ; Freeman Health Melissa Moore ; Freeman Health - Spencer Ellis
; Feaman, Kimberly ; Doherty, Steve
; Hannibal Council dba Turning Point - Jennifer Wilson
; Hannibal Council dba Turning Point - Kettisha Hodges
; Heartland Center - Carolyn Ross ; Heartland
Center - Kyle Mead ; Hinton, Tineen ; Hopewell
Center - Barbara Tucker ; Butler, Dwayne ;
Hopewell Center - Lynette Jones ; Franklin, Wil
; Higginbotham, Jennifer ;
Independence Center - Jocelyn Hertich ; Independence Center Paul Schoenig ; Karl, Barbara ;
Lafayette House - Teddy Brown ; Mark Twain ;
McMahon, Cory ; Midwest Assessment - Catie Platt
; Mineral Area CPRC - Karen Ferrell ;
Mineral Area CPRC - Vicky Winick ; Terry Trafton
(ttrafton@CommCARE1.org) ; Beck, Kimberly
; Busiek, Gary ; eydie
caughron ; CMHC - Jerry Morris ;
CMHC - Kate Hogsett ; CMHC - Nate Gulliford
; CMHC - Terri Morris ; Lafayette House Deb Allman ; Lafayette House - Teddy Brown
; Moore, Jonathan ;
Salvation Army - TSA Midland Contracts ; Turning
Point - Gary Stoner ; Turning Point - John Pruett
; Turning Point - Virginia Frese ; Westend

Clinic - Pamela Byes ; Miller, Oval ; Carter, Hardy
; CMHC - Cindy Brannan (cmhc.nmh.cbrannan@gmail.com)
; CMHC - Jerry Morris (cmhcjerry@sbcglobal.net)
; Swinfard, Tim ; Comprehensive - Jenny
Miller (jemil@thecmhs.com) ; Pigg, Margo ; Family
Guidance - Garry Hammond (ghammond@FGCnow.org) ; Jackson, Derek
; Brown, Joshua ; FCC - Ken Tombley
(ken.tombley@fccinc.org) ; FCC - Misty Brazel (mistyb@fccinc.org)
; 'FCC - Noble Shaver' ; Parrigon, Mary
; Gibson Center - John Gary (garyj@gibsonrecovery.org)
; Payden, Vernon ; Gibson Recovery Ryan Essex (essexr@gibsonrecovery.org) ; Gibson Recovery - Sherry
Eakers (eakerss@gibsonrecovery.org) ; McCollough, Shauntay
; Camp, Timothy ; Preferred Pam Leyhe (pleyhe@pfh.org) ; Brawner, Paula ; Queen of
Peace - Clara Stevenson ; Tri-County MHS - Jan Pool (janp@tri-countymhs.org)
; Truman Medical - Douglas Burgess (douglas.burgess@tmcmed.org)
; Carter, Wardell 
Cc: 'Brent McGinty' ; 'Emily Conde' (econde@mocoalition.org)
; Rembecki, Mark ; Cook, Natalie
; Turner, Rhonda ; Rudder, Timothy
; Smyser, Melissa ; Blume, Susan

Subject: RE: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement
—NEW
I agree with the others that this would create a lot of extra time.
From: Suneal Menzies
>
Sent: Thursday, October 18, 2018 12:53 PM
To: Clif Johnson CRAADC >; Bock, Nora
>; Cori Putz
(cmoore@pfh.org) >; Geoff
Moeller >;
lmccallister@placesforpeople.org; NCADA - St. Louis Nichole Dawsey >; NCADA St Louis - Jenny
Armbruster >; New Beginnings Freda Theus >; McCollough, Shauntay
>; Cheung, Chi
>; New Horizons - Laura Porting
>; New Horizons - Shanna
Behrens >; New Horizons
- Stacy Doggett >; North
Central MO - DeAnna Savage >; Irvine, Lori
>; North Central MO - Tammy Floyd

>; Francis, Lisa
>; Mieseler, Vicky
>; Ozarks Medical Center Curtis Cook
>; Ozarks
Medical Center - Joy Anderson
>;
Pathways - Amy Blake >; Pathways - Becky
Camden >; Pathways - Elisabeth
Brockman-Knight >; Pathways - Gloria
Miller >; Pathways - Julia Bozarth
>; Yach, Kristen
>; Pathways - Linda Grgurich
>; Pathways - Mel Fetter
>; Pathways - Shannon Crowley-Einsphar
>; Pathways - Todd Martensen
>; Foster, Tonie
>; Greening, Andrew
>; PFH - Andrew Schwend
>; Hutton, Ann
>; Putz, Cori >;
PFH - Darlene Harrell >; PFH - Jason Hinckley
>; PFH - Lorinda Meyer
>; PFH - Marilyn Nolan
>; PFH - Nancy Atwater
>; PFH - Rhonda Ferguson
>; PFH - Una Bennett
>; Phoenix - Laura Cameron
>; Phoenix
- Rhiannon Ross >;
Phoenix - Teresa Goslin
>; Phoenix
Health Programs - Tracy McIntyre
>; Places
for People - Diane Maguire
>; Places for People - Nicole
Stewart >; Bayliff, Scott
>; Places for People - Tiffany Lacy
Clark >; Spruell, Sharon
>; Flory, Alan
>; ReDiscover - Elizabeth Deason
>; ReDiscover - Jennifer Craig
>; ReDiscover - John Dean
>; ReDiscover - Lauren Moyer
>; ReDiscover - Marsha Page
>; Busiek, Gary

>; Beck, Kimberly
>; SAMHSA
Regional Administrator Region VII - Kimberly Nelson
>; Angela Toman, CRPS
>; Brenda Felkerson
>; Cathy Schroer BS
>; Dan Adams MBA
>; Jason W. Gilliam MBA MHA AICP
>; Storey, Janice >; Swope Health - Kortney Carr
>; Swope Health - Mark Miller
>; Holm, Christy >; Tri-County - JoAnn Werner >; Tri-County - Talina Nelson >; Tri-County - Tom Petrizzo >; Truman Medical Center - Barbara Warner
>; Zaiger, Bethany
>; Truman Medical Center - Jodi
Gusman >; Truman Medical Center Mark VanMeter >; Truman
Medical Center - Sharon Freese >;
Turning Point - Catie Franklin >;
Turning Point - Heather Higgins >;
Allyson Ashley >; Fred Rottnek
>; Percy Menzies
>; Arthur Center - Kristin
Fishback >; Arthur Center Rachel Ward >; BASIC - Keturah Ibrahim
>; BASIC - Kirby Anderson-El
>; Johnson, Lola
>; BASIC - Michael Batchman
>; BASIC - Robin Smith
>; Singleton, Yulonda
>; BHR Worldwide - Angela Tate
>; BHR Worldwide - Bart Andrews
>; BJC - Karen Miller
>; Bootheel Counseling - David Terrell
>; Kassinger, Micaela
>; Brandon,
Teresa >; Bridgeway - Craig Miner
>; Bridgeway - Jack Barnett
>; Morrison, Mike
>; Burch, Mitzi
>; Burell - CJ Davis
>; Burrell - Cristin Martinez
>; Burrell Center -

Adam Andreassen
>; Burrell
Center - Austin Burdine
>; Burrell Center Bethany Silliman
>; Burrell Center Brent Sugg >; Burrell Center Christopher Orr >;
Burrell Center - Denise Mills
>; Burrell Center - Gina
Burroughs >; Burrell
Center - Hunter Houston
>; Burrell Center Lauren Pratt >; Burrell
Center - Leslie Corbiere
>; Gass, Mathew
>; Burrell Center - Megan
Steen >; Burrell Center Sally Gibson >; Burrell
Center - Shae Hitchock
>; Burrell Center Stephanie March-Hopkins >; Burrell Center - Stephen Koch
>; Burrell Center - Wes
Starlin >; Camp,
Timothy >; CCC - Brenda
Robertson >; CCC - Lonnie Lusk
>; cheryl gardine
>; Ridenour, Brad
>; Clark CMHC Debbie Schoon >;
Beatie, Laura >; Clark
Mental Health - Christy Henley
>; CMHC - Jenny Wright
>; Anderson, Carl
>; CMHS - Jenny Duncan
>; CMHS - Julie Pratt
>; CMHS - Tara Yardley
>; CommCARE - Erica Immenschuh
>; Compass Health
/ McCambridge - Angela Allphin >;
COMTREA - Agnes Jos >; COMTREA - Andrea Cuneio
>; COMTREA - Jonathan Cochran
>; COMTREA - Rachael Bersdale
>; Susan Curfman
>; Crider - Carrie Rigdon

>; Crider - Laura Heebner
>; Crider - Nancy Gongaware
>; Crider - Victoria Walker
>; Family Guidance - Elizabeth Sprung
>; Family Guidance - Kristina Hannon
>; Family Guidance - Rachel Evans
>; Family Guidance - Raven Hutchison
>; Family Guidance - Rebekah Quillin
>; Family Guidance - Robin Reynozo
>; Family Self Help - Alison Malinowski Sunday
>; Family Self Help Gwen Ewing >; FCC - Ashley Singleton
>; FCC - Kelley Wilbanks
>; FCC - Melissa Weatherwax
>; FCC - Randy Ray
>; FCC - Shawn Sando
>; First Call - Susan Whitmore
>; Freeman Health - Melissa Moore
>; Freeman Health - Spencer
Ellis >; Feaman, Kimberly
>; Doherty, Steve
>; Hannibal Council
dba Turning Point - Jennifer Wilson
>; Hannibal Council dba Turning
Point - Kettisha Hodges >; Heartland Center
- Carolyn Ross >; Heartland Center - Kyle
Mead >; Hinton, Tineen
>; Hopewell Center - Barbara Tucker
>; Butler, Dwayne
>; Hopewell Center - Lynette Jones
>; Franklin, Wil
>; Higginbotham, Jennifer
>;
Independence Center - Jocelyn Hertich
>; Independence
Center - Paul Schoenig
>; Karl, Barbara
>; Lafayette House - Teddy Brown
>; Mark Twain
>; McMahon, Cory
>; Midwest Assessment - Catie
Platt >; Mineral Area
CPRC - Karen Ferrell >; Mineral Area
CPRC - Vicky Winick >; Terry Trafton
(ttrafton@CommCARE1.org)
>; Beck, Kimberly

>; Busiek, Gary
>; eydie caughron
>; CMHC - Jerry Morris
>; CMHC - Kate Hogsett
>; CMHC - Nate Gulliford
>; CMHC - Terri Morris
>; cheryl gardine
>; Lafayette House - Deb
Allman >; Lafayette House Teddy Brown >; Moore,
Jonathan >;
Salvation Army - TSA Midland Contracts
>;
Turning Point - Gary Stoner >;
Turning Point - John Pruett >;
Turning Point - Virginia Frese >;
Westend Clinic - Pamela Byes >; Miller,
Oval >; Carter, Hardy
>; CMHC - Cindy Brannan
(cmhc.nmh.cbrannan@gmail.com)
>; CMHC - Jerry Morris
(cmhcjerry@sbcglobal.net)
>; Swinfard, Tim
>; Comprehensive - Jenny Miller
(jemil@thecmhs.com)
>; Pigg, Margo
>; Family Guidance - Garry Hammond
(ghammond@FGCnow.org)
>; Jackson, Derek
>; Brown, Joshua
>; FCC - Ken Tombley
(ken.tombley@fccinc.org)
>; FCC - Misty Brazel
(mistyb@fccinc.org) >;
'FCC - Noble Shaver' >; Parrigon, Mary
>; Gibson Center - John
Gary (garyj@gibsonrecovery.org)
>; Payden, Vernon
>; Gibson Recovery - Ryan Essex
(essexr@gibsonrecovery.org)
>; Gibson Recovery - Sherry Eakers
(eakerss@gibsonrecovery.org)
>; McCollough, Shauntay
>; Camp, Timothy
>; Preferred - Pam Leyhe
(pleyhe@pfh.org) >; Brawner,

Paula >; Queen of Peace - Clara Stevenson
>; Tri-County MHS - Jan Pool (janp@tricountymhs.org) >; Truman Medical - Douglas Burgess
(douglas.burgess@tmcmed.org)
>; Carter, Wardell
>
Cc: 'Brent McGinty' >; 'Emily Conde'
(econde@mocoalition.org)
>; Rembecki, Mark
>; Cook, Natalie
>; Turner, Rhonda
>; Rudder, Timothy
>; Smyser, Melissa
>; Blume, Susan
>
Subject: RE: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement
—NEW
I agree – this will create a good deal of additional administrative and clinical work.
From: Clif Johnson CRAADC >
Sent: Thursday, October 18, 2018 12:28 PM
To: Bock, Nora >; Cori Putz
(cmoore@pfh.org) >; Geoff
Moeller >;
lmccallister@placesforpeople.org; NCADA - St. Louis Nichole Dawsey >; NCADA St Louis - Jenny
Armbruster >; New Beginnings Freda Theus >; McCollough, Shauntay
>; Cheung, Chi
>; New Horizons - Laura Porting
>; New Horizons - Shanna
Behrens >; New Horizons
- Stacy Doggett >; North
Central MO - DeAnna Savage >; Irvine, Lori
>; North Central MO - Tammy Floyd
>; Francis, Lisa
>; Mieseler, Vicky
>; Ozarks Medical Center Curtis Cook
>; Ozarks
Medical Center - Joy Anderson
>;
Pathways - Amy Blake >; Pathways - Becky
Camden >; Pathways - Elisabeth

Brockman-Knight >; Pathways - Gloria
Miller >; Pathways - Julia Bozarth
>; Yach, Kristen
>; Pathways - Linda Grgurich
>; Pathways - Mel Fetter
>; Pathways - Shannon Crowley-Einsphar
>; Pathways - Todd Martensen
>; Foster, Tonie
>; Greening, Andrew
>; PFH - Andrew Schwend
>; Hutton, Ann
>; Putz, Cori >;
PFH - Darlene Harrell >; PFH - Jason Hinckley
>; PFH - Lorinda Meyer
>; PFH - Marilyn Nolan
>; PFH - Nancy Atwater
>; PFH - Rhonda Ferguson
>; PFH - Una Bennett
>; Phoenix - Laura Cameron
>; Phoenix
- Rhiannon Ross >;
Phoenix - Teresa Goslin
>; Phoenix
Health Programs - Tracy McIntyre
>; Places
for People - Diane Maguire
>; Places for People - Nicole
Stewart >; Bayliff, Scott
>; Places for People - Tiffany Lacy
Clark >; Spruell, Sharon
>; Flory, Alan
>; ReDiscover - Elizabeth Deason
>; ReDiscover - Jennifer Craig
>; ReDiscover - John Dean
>; ReDiscover - Lauren Moyer
>; ReDiscover - Marsha Page
>; Busiek, Gary
>; Beck, Kimberly
>; SAMHSA
Regional Administrator Region VII - Kimberly Nelson
>; Angela Toman, CRPS
>; Brenda Felkerson
>; Cathy Schroer BS
>; Dan Adams MBA
>; Jason W. Gilliam MBA MHA AICP
>; Storey, Janice >; Swope Health - Kortney Carr
>; Swope Health - Mark Miller
>; Holm, Christy >; Tri-County - JoAnn Werner >; Tri-County - Talina Nelson >; Tri-County - Tom Petrizzo >; Truman Medical Center - Barbara Warner
>; Zaiger, Bethany
>; Truman Medical Center - Jodi
Gusman >; Truman Medical Center Mark VanMeter >; Truman
Medical Center - Sharon Freese >;
Turning Point - Catie Franklin >;
Turning Point - Heather Higgins >;
Allyson Ashley >; Fred Rottnek
>; Percy Menzies
>; Suneal Menzies
>; Arthur Center Kristin Fishback >; Arthur Center Rachel Ward >; BASIC - Keturah Ibrahim
>; BASIC - Kirby Anderson-El
>; Johnson, Lola
>; BASIC - Michael Batchman
>; BASIC - Robin Smith
>; Singleton, Yulonda
>; BHR Worldwide - Angela Tate
>; BHR Worldwide - Bart Andrews
>; BJC - Karen Miller
>; Bootheel Counseling - David Terrell
>; Kassinger, Micaela
>; Brandon,
Teresa >; Bridgeway - Craig Miner
>; Bridgeway - Jack Barnett
>; Morrison, Mike
>; Burch, Mitzi
>; Burell - CJ Davis
>; Burrell - Cristin Martinez
>; Burrell Center Adam Andreassen
>; Burrell
Center - Austin Burdine
>; Burrell Center Bethany Silliman
>; Burrell Center Brent Sugg >; Burrell Center Christopher Orr >;

Burrell Center - Denise Mills
>; Burrell Center - Gina
Burroughs >; Burrell
Center - Hunter Houston
>; Burrell Center Lauren Pratt >; Burrell
Center - Leslie Corbiere
>; Gass, Mathew
>; Burrell Center - Megan
Steen >; Burrell Center Sally Gibson >; Burrell
Center - Shae Hitchock
>; Burrell Center Stephanie March-Hopkins >; Burrell Center - Stephen Koch
>; Burrell Center - Wes
Starlin >; Camp,
Timothy >; CCC - Brenda
Robertson >; CCC - Lonnie Lusk
>; Gardine, Cheryl
>; Ridenour, Brad
>; Clark CMHC Debbie Schoon >;
Beatie, Laura >; Clark
Mental Health - Christy Henley
>; CMHC - Jenny Wright
>; Anderson, Carl
>; CMHS - Jenny Duncan
>; CMHS - Julie Pratt
>; CMHS - Tara Yardley
>; CommCARE - Erica Immenschuh
>; Compass Health
/ McCambridge - Angela Allphin >;
COMTREA - Agnes Jos >; COMTREA - Andrea Cuneio
>; COMTREA - Jonathan Cochran
>; COMTREA - Rachael Bersdale
>; Susan Curfman
>; Crider - Carrie Rigdon
>; Crider - Laura Heebner
>; Crider - Nancy Gongaware
>; Crider - Victoria Walker
>; Family Guidance - Elizabeth Sprung
>; Family Guidance - Kristina Hannon
>; Family Guidance - Rachel Evans
>; Family Guidance - Raven Hutchison
>; Family Guidance - Rebekah Quillin

>; Family Guidance - Robin Reynozo
>; Family Self Help - Alison Malinowski Sunday
>; Family Self Help Gwen Ewing >; FCC - Ashley Singleton
>; FCC - Kelley Wilbanks
>; FCC - Melissa Weatherwax
>; FCC - Randy Ray
>; FCC - Shawn Sando
>; First Call - Susan Whitmore
>; Freeman Health - Melissa Moore
>; Freeman Health - Spencer
Ellis >; Feaman, Kimberly
>; Doherty, Steve
>; Hannibal Council
dba Turning Point - Jennifer Wilson
>; Hannibal Council dba Turning
Point - Kettisha Hodges >; Heartland Center
- Carolyn Ross >; Heartland Center - Kyle
Mead >; Hinton, Tineen
>; Hopewell Center - Barbara Tucker
>; Butler, Dwayne
>; Hopewell Center - Lynette Jones
>; Franklin, Wil
>; Higginbotham, Jennifer
>;
Independence Center - Jocelyn Hertich
>; Independence
Center - Paul Schoenig
>; Karl, Barbara
>; Lafayette House - Teddy Brown
>; Mark Twain
>; McMahon, Cory
>; Midwest Assessment - Catie
Platt >; Mineral Area
CPRC - Karen Ferrell >; Mineral Area
CPRC - Vicky Winick >; Terry Trafton
(ttrafton@CommCARE1.org)
>; Beck, Kimberly
>; Busiek, Gary
>; Center for Life
Solutions - Eydie Caughron
>; CMHC - Jerry Morris
>; CMHC - Kate Hogsett
>; CMHC - Nate Gulliford
>; CMHC - Terri Morris
>; Gardine, Cheryl

>; Lafayette House Deb Allman >; Lafayette
House - Teddy Brown >;
Moore, Jonathan
>; Salvation
Army - TSA Midland Contracts
>;
Turning Point - Gary Stoner >;
Turning Point - John Pruett >;
Turning Point - Virginia Frese >;
Westend Clinic - Pamela Byes >; Miller,
Oval >; Carter, Hardy
>; CMHC - Cindy Brannan
(cmhc.nmh.cbrannan@gmail.com)
>; CMHC - Jerry Morris
(cmhcjerry@sbcglobal.net)
>; Swinfard, Tim
>; Comprehensive - Jenny Miller
(jemil@thecmhs.com)
>; Pigg, Margo
>; Family Guidance - Garry Hammond
(ghammond@FGCnow.org)
>; Jackson, Derek
>; Brown, Joshua
>; FCC - Ken Tombley
(ken.tombley@fccinc.org)
>; FCC - Misty Brazel
(mistyb@fccinc.org) >;
'FCC - Noble Shaver' >; Parrigon, Mary
>; Gibson Center - John
Gary (garyj@gibsonrecovery.org)
>; Payden, Vernon
>; Gibson Recovery - Ryan Essex
(essexr@gibsonrecovery.org)
>; Gibson Recovery - Sherry Eakers
(eakerss@gibsonrecovery.org)
>; McCollough, Shauntay
>; Camp, Timothy
>; Preferred - Pam Leyhe
(pleyhe@pfh.org) >; Brawner,
Paula >; Queen of Peace - Clara Stevenson
>; Tri-County MHS - Jan Pool (janp@tricountymhs.org) >; Truman Medical - Douglas Burgess
(douglas.burgess@tmcmed.org)
>; Carter, Wardell

>
Cc: 'Brent McGinty' >; 'Emily Conde'
(econde@mocoalition.org)
>; Rembecki, Mark
>; Cook, Natalie
>; Turner, Rhonda
>; Rudder, Timothy
>; Smyser, Melissa
>; Blume, Susan
>
Subject: RE: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement
—NEW
For us and Preferred doing the GPRA for STR, this is a longer tool, it adds a 3 month reporting time (
not required with STR), so if the benchmark is 80% compliance in reporting like STR, this will add a
layer of time for something  that for us that is already very labor intensive in tracking , locating and
administering. For instance, we are currently tracking 95 STR GPRAs needing completion as of
yesterday.

[cid:image001.jpg@01D466E2.FD575C70]
Clif Johnson CRAADC | Director of Clinical Compliance and Physician Services | 573-756-5749 O 
+15737606084 M
1565 Ste. Genevieve Avenue-PO Drawer 459 | Farmington, MO  63640-0459
From: Bock, Nora [mailto:Nora.Bock@dmh.mo.gov]
Sent: Wednesday, October 17, 2018 4:53 PM
To: Cori Putz (cmoore@pfh.org); Geoff Moeller;
lmccallister@placesforpeople.org; NCADA - St. Louis Nichole Dawsey; NCADA St Louis - Jenny Armbruster; New Beginnings - Freda Theus; McCollough,
Shauntay; Cheung, Chi; New Horizons - Laura Porting; New Horizons - Shanna Behrens; New Horizons Stacy Doggett; North Central MO - DeAnna Savage; Irvine, Lori; North Central MO - Tammy Floyd;
Francis, Lisa; Mieseler, Vicky; Ozarks Medical Center - Curtis Cook; Ozarks Medical Center - Joy
Anderson; Pathways - Amy Blake; Pathways - Becky Camden; Pathways - Elisabeth Brockman-Knight;
Pathways - Gloria Miller; Pathways - Julia Bozarth; Yach, Kristen; Pathways - Linda Grgurich; Pathways Mel Fetter; Pathways - Shannon Crowley-Einsphar; Pathways - Todd Martensen; Foster, Tonie;
Greening, Andrew; PFH - Andrew Schwend; Hutton, Ann; Putz, Cori; PFH - Darlene Harrell; PFH - Jason
Hinckley; PFH - Lorinda Meyer; PFH - Marilyn Nolan; PFH - Nancy Atwater; PFH - Rhonda Ferguson; PFH
- Una Bennett ; Phoenix - Laura Cameron; Phoenix - Rhiannon Ross; Phoenix - Teresa Goslin; Phoenix
Health Programs - Tracy McIntyre; Places for People - Diane Maguire; Places for People - Nicole
Stewart; Bayliff, Scott; Places for People - Tiffany Lacy Clark; Spruell, Sharon; Flory, Alan; ReDiscover Elizabeth Deason; ReDiscover - Jennifer Craig; ReDiscover - John Dean; ReDiscover - Lauren Moyer;
ReDiscover - Marsha Page; Busiek, Gary; Beck, Kimberly; SAMHSA Regional Administrator Region VII Kimberly Nelson; Angela Toman, CRPS; Brenda Felkerson; Cathy Schroer BS; Clif Johnson CRAADC; Dan
Adams MBA; Jason W. Gilliam MBA MHA AICP; Storey, Janice; Swope Health - Kortney Carr; Swope
Health - Mark Miller; Holm, Christy; Tri-County - JoAnn Werner; Tri-County - Talina Nelson; Tri-County -

Tom Petrizzo; Truman Medical Center - Barbara Warner; Zaiger, Bethany; Truman Medical Center Jodi Gusman; Truman Medical Center - Mark VanMeter; Truman Medical Center - Sharon Freese;
Turning Point - Catie Franklin; Turning Point - Heather Higgins; Allyson Ashley; ARCA - Fred Rottnek;
Menzies, Percy; Menzies, Suneal; Arthur Center - Kristin Fishback; Arthur Center - Rachel Ward; BASIC Keturah Ibrahim; BASIC - Kirby Anderson-El; Johnson, Lola; BASIC - Michael Batchman; BASIC - Robin
Smith; Singleton, Yulonda; BHR Worldwide - Angela Tate; BHR Worldwide - Bart Andrews; BJC - Karen
Miller; Bootheel Counseling - David Terrell; Kassinger, Micaela; Brandon, Teresa; Bridgeway - Craig
Miner; Bridgeway - Jack Barnett; Morrison, Mike; Burch, Mitzi; Burell - CJ Davis; Burrell - Cristin
Martinez; Burrell Center - Adam Andreassen; Burrell Center - Austin Burdine; Burrell Center - Bethany
Silliman; Burrell Center - Brent Sugg; Burrell Center - Christopher Orr; Burrell Center - Denise Mills;
Burrell Center - Gina Burroughs; Burrell Center - Hunter Houston; Burrell Center - Lauren Pratt; Burrell
Center - Leslie Corbiere; Gass, Mathew; Burrell Center - Megan Steen; Burrell Center - Sally Gibson;
Burrell Center - Shae Hitchock; Burrell Center - Stephanie March-Hopkins; Burrell Center - Stephen
Koch; Burrell Center - Wes Starlin; Camp, Timothy; CCC - Brenda Robertson; CCC - Lonnie Lusk;
Gardine, Cheryl; Ridenour, Brad; Clark CMHC - Debbie Schoon; Beatie, Laura; Clark Mental Health Christy Henley; CMHC - Jenny Wright; Anderson, Carl; CMHS - Jenny Duncan; CMHS - Julie Pratt; CMHS
- Tara Yardley; CommCARE - Erica Immenschuh; Compass Health / McCambridge - Angela Allphin;
COMTREA - Agnes Jos; COMTREA - Andrea Cuneio; COMTREA - Jonathan Cochran; COMTREA - Rachael
Bersdale; Susan Curfman; Crider - Carrie Rigdon; Crider - Laura Heebner; Crider - Nancy Gongaware;
Crider - Victoria Walker; Family Guidance - Elizabeth Sprung; Family Guidance - Kristina Hannon; Family
Guidance - Rachel Evans; Family Guidance - Raven Hutchison; Family Guidance - Rebekah Quillin;
Family Guidance - Robin Reynozo; Family Self Help - Alison Malinowski Sunday; Family Self Help - Gwen
Ewing; FCC - Ashley Singleton; FCC - Kelley Wilbanks; FCC - Melissa Weatherwax; FCC - Randy Ray; FCC
- Shawn Sando; First Call - Susan Whitmore; Freeman Health - Melissa Moore; Freeman Health Spencer Ellis; Feaman, Kimberly; Doherty, Steve; Hannibal Council dba Turning Point - Jennifer Wilson;
Hannibal Council dba Turning Point - Kettisha Hodges; Heartland Center - Carolyn Ross; Heartland
Center - Kyle Mead; Hinton, Tineen; Hopewell Center - Barbara Tucker; Butler, Dwayne; Hopewell
Center - Lynette Jones; Franklin, Wil; Higginbotham, Jennifer; Independence Center - Jocelyn Hertich;
Independence Center - Paul Schoenig; Karl, Barbara; Lafayette House - Teddy Brown; Mark Twain;
McMahon, Cory; Midwest Assessment - Catie Platt; Mineral Area CPRC - Karen Ferrell; Mineral Area
CPRC - Vicky Winick; Terry Trafton (ttrafton@CommCARE1.org);
Beck, Kimberly; Busiek, Gary; Center for Life Solutions - Eydie Caughron; CMHC - Jerry Morris; CMHC Kate Hogsett; CMHC - Nate Gulliford; CMHC - Terri Morris; Gardine, Cheryl; Lafayette House - Deb
Allman; Lafayette House - Teddy Brown; Moore, Jonathan; Salvation Army - TSA Midland Contracts;
Turning Point - Gary Stoner; Turning Point - John Pruett; Turning Point - Virginia Frese; Westend Clinic Pamela Byes; Miller, Oval; Carter, Hardy; CMHC - Cindy Brannan
(cmhc.nmh.cbrannan@gmail.com); CMHC - Jerry Morris
(cmhcjerry@sbcglobal.net); Swinfard, Tim; Comprehensive - Jenny
Miller (jemil@thecmhs.com); Pigg, Margo; Family Guidance - Garry
Hammond (ghammond@FGCnow.org); Jackson, Derek; Brown,
Joshua; FCC - Ken Tombley (ken.tombley@fccinc.org); FCC - Misty
Brazel (mistyb@fccinc.org); 'FCC - Noble Shaver'; Parrigon, Mary; Gibson
Center - John Gary (garyj@gibsonrecovery.org); Payden, Vernon;
Gibson Recovery - Ryan Essex (essexr@gibsonrecovery.org);
Gibson Recovery - Sherry Eakers (eakerss@gibsonrecovery.org);
McCollough, Shauntay; Camp, Timothy; Preferred - Pam Leyhe

(pleyhe@pfh.org); Brawner, Paula; Queen of Peace - Clara Stevenson; TriCounty MHS - Jan Pool (janp@tri-countymhs.org); Truman Medical Douglas Burgess (douglas.burgess@tmcmed.org); Carter,
Wardell
Cc: 'Brent McGinty'; 'Emily Conde' (econde@mocoalition.org);
Rembecki, Mark; Cook, Natalie; Turner, Rhonda; Rudder, Timothy; Smyser, Melissa; Blume, Susan
Subject: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement—
NEW
Importance: High
THIS WILL HUGELY IMPACT THE DATA REQUIREMENTS FOR SOR – I cannot emphasize enough how
important it is for you to review the proposed requirements and provide feedback!!
Nora

From: Gowdy, Rick
Sent: Wednesday, October 17, 2018 4:49 PM
To: 'Winograd, Rachel' >; Horn,
Philip >; Bock, Nora
>; Rudder, Timothy
>; Epple, Laurie
>; Anderson-Harper, Rosie
>;
Stuckenschneider, Angie
>; Cahalan,
Connie >
Subject: FW: Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR)
Program Data Collection and Performance Measurement—NEW
10-17-18.
See note below from Mr. Clark.
Written comments should be received by December 3, 2018
RNG.
Confidentiality Statement:
CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain confidential
and privileged information for the use of the designated recipients named above. The designated
recipients are prohibited from redisclosing this information to any other party without authorization
and are required to destroy the information after its stated need has been fulfilled. If you are not the
intended recipient, you are hereby notified that you have received this communication in error and
that any review, disclosure, dissemination, distribution or copying of it or its contents is prohibited by
federal or state law. If you have received this communication in error, please notify me immediately by
telephone at 573-751-9499, and destroy all copies of this communication and any attachments.

From: Clark, Spencer (SAMHSA/CSAT/DPT)
>
Sent: Wednesday, October 17, 2018 4:44 PM
To: lauren.siembab@ct.gov;
Michael.parks@maine.gov;
Tom.Connors@maine.gov;
Katherine.Coutu@maine.gov;
Allison.bauer@state.ma.us; amy.sorensenalawad@state.ma.us;
Nicole.m.schmitt@state.ma.us;
Jennifer.miller@state.ma.us;
Hannah.Lipper@state.ma.us;
Abby.Shockley@dhhs.nh.gov;
Donald.Hunter@dhhs.nh.gov;
Cynthia.Thomas@vermont.gov;
Megan.Mitchell@vermont.gov;
Mariah.Ogden@vermont.gov;
sgoldsby@daodas.sc.gov;
dwalker@daodas.sc.gov;
ckraeff@daodas.sc.gov;
bpowell@daodas.sc.gov;
rbraneck@daodas.sc.gov;
taryn.sloss@tn.gov;
linda.mccorkle@tn.gov;
Anthony.jackson@tn.gov;
richard.sherman@illinois.gov;
terry.cook@fssa.in.gov;
Rebecca.Buhner@fssa.IN.gov;
Jeremy.Heyer@fssa.IN.gov;
Cassandra.Anderson2@fssa.IN.gov;
Mark.Loggins@fssa.IN.gov;
Kelly.Welker@fssa.IN.gov;
ScottL11@michigan.gov;
BullardS@michigan.gov;
SmithA8@michigan.gov;
dave.rompa@state.mn.us;
faye.bernstein@state.mn.us;
Ellen.Augspurger@mha.ohio.gov;
Sanford.Starr@mha.ohio.gov;
joyce.allen@wisconsin.gov;
Jason.Harris@dhs.wisconsin.gov;
Scott.stokes@dhs.wisconsin.gov;
tcroom@odmhsas.org; monica.wilkebrown@idph.iowa.gov;
Sharon.Kearse@ks.gov; Gowdy, Rick
>;

rachel.winograd@mimh.edu;
philip.horn@mimh.edu;
tamara.gavin@nebraska.gov;
Marlies.Perez@dhcs.ca.gov;
tfsunia@dhss.as;
herbert.sablan@gmail.com;
bvictor@fsmhealth.fm;
athena.duenas@gbhwc.guam.gov;
temengil.ej@gmail.com
Subject: Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program
Data Collection and Performance Measurement—NEW
Dear STR and SOR Project Directors and Staff:
This is in follow-up to my correspondence to you of last week, indicating the publication of a Federal
Registry Notice (FRN) containing the proposed reporting guidelines for the SOR and TOR Grant
initiatives.
Please find attached below the proposed SOR information plans and reporting instruments that were
referenced in the recent posting of the Federal Register for your review and comment.
I cannot emphasize too greatly how important it is for you to carefully review and comment on these
reporting tools, and provide whatever recommendations that you have regarding implementation
issues.
I am hopeful that with your feedback we can enter into a meaningful dialogue to maximize the
usefulness of this reporting, and minimize any unnecessary reporting burden.
Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov.
Written comments should be received by December 3, 2018.
I would appreciate your copying me on any feedback that you provide in this process so that I can be
fully prepared to particiapte in this dialogue.
Thank you and best regards,
Spencer Clark
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,

Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
[cid:image002.jpg@01D466E2.FD575C70]

_____________________________________________
From: King, Summer (SAMHSA/OPPI)
Sent: Tuesday, October 09, 2018 10:19 AM
To: Clark, Spencer (SAMHSA/CSAT/DPT)
>
Cc: Jacobus-Kantor, Laura (SAMHSA/CBHSQ) >
Subject: RE: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a
Copy of the Information Collection Plans for the SOR and TOR Grant Initiatives

Hi Spencer,
Attached are copies of the information plans and the instruments.  Please let me know if you need
anything else.
Thanks,
Summer
_____________________________________________
From: Clark, Spencer (SAMHSA/CSAT/DPT)
Sent: Tuesday, October 9, 2018 10:07 AM
To: King, Summer (SAMHSA/OPPI)
>
Subject: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a Copy
of the Information Collection Plans for the SOR and TOR Grant Initiatives

Dear Summer:
Please provide me with a copy of the information collection plans and copies of the instruments as
described below in the FRN released last week:
In compliance with Section 3506(c)(2)(A) of the Paperwork Reduction Act of 1995 concerning
opportunity for public comment on proposed collections of information, the Substance Abuse and
Mental Health Services Administration (SAMHSA) will publish periodic summaries of proposed
projects. To request more information on the proposed project or to obtain a copy of the information

collection plans, call the SAMHSA Reports Clearance Officer on (240) 276-1243.
Comments are invited on: (a) Whether the proposed collections of information are necessary for the
proper performance of the functions of the agency, including whether the information shall have
practical utility; (b) the accuracy of the agency's estimate of the burden of the proposed collection of
information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and
(d) ways to minimize the burden of the collection of information on respondents, including through
the use of automated collection techniques or other forms of information technology.
Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data
Collection and Performance Measurement—NEW
The Substance Abuse and Mental Health Services Administration's (SAMHSA) Center for Substance
Abuse Treatment (CSAT) is requesting approval from the Office of Management and Budget (OMB) for
data collection activities associated with the State Opioid Response (SOR) and Tribal Opioid Response
(TOR) discretionary grant programs. Approval of this information collection will allow SAMHSA to
continue to meet the Government Performance and Results Modernization Act of 2010 (GPRMA)
reporting requirements that quantify the effects and accomplishments of its discretionary grant
programs which are consistent with OMB guidance. Information collected through this request will be
used to monitor performance throughout the grant period.
There will be up to 359 award recipients (states, territories, and tribal entities) in these grant
programs. Grantee-level data will include information related to naloxone purchases and distribution.
This grantee-level information will be collected quarterly.
All funded states/territories and tribal entities will also be required to collect and report client-level
data on individuals who are receiving opioid treatment services to ensure program goals and
objectives are being met. Client-level data will include information such as: Demographic information,
services planned/received, mental health/substance use disorder diagnoses, medical status,
employment status, substance use, legal status, and psychiatric status/symptoms. Client-level data will
be collected at intake/baseline, three months post intake, six months post intake, and at discharge.
CSAT anticipates that the time required to collect and report the grantee-level data is approximately
10 minutes per response, and the time required to collect and report the client-level data is
approximately 47 minutes per response. CSAT's estimate of the burden associated with the client-level
instrument includes an adjustment for data elements that are currently being collected by entities that
are likely to be funded by the SOR/TOR grant programs. Start Printed Page 50117
Table 1—Estimate of Annualized Hour Burden for SOR/TOR Grantees

SAMHSA data Collection
Number of respondents
Responses per respondent
Total number of responses
Burden hours per response
Total burden Hours

Grantee-Level Instrument
359
4
1,436
.17
244
Client Level Instrument: Baseline Interview
165,000
1
165,000
.78
128,700
Client-Level Instrument: Follow-up Interview 1
132,000
2
264,000
.78
205,920
Client-Level Instrument: Discharge Interview 2
85,800
1
85,800
.78

66,924
CSAT Total
165,359
516,236
401,788

Notes:
1 It is estimated that 80% of baseline clients will complete the three month and six month follow-up
interviews.
2 It is estimated that 52% of baseline clients will complete this interview.
Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov. Written comments should be
received by December 3, 2018.
Start Signature
Summer King,
Statistician.
End Signature End Preamble
[FR Doc. 2018-21576 Filed 10-3-18; 8:45 am]
BILLING CODE 4162-20-P

Thank you and best regards,
Spencer Clark
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027

Main Office Telephone: (240) 276-2700
<< OLE Object: Picture (Device Independent Bitmap) >>

SOR Data Collection Review
Grantee Quarterly Data Collection:
No comments, requirements include:
1. Naloxone overdose reversal kits that were purchased using grant funds.
2. Naloxone overdose reversal kits that were distributed using grant funds.
Seems like Britni Reilly already collects all of this information, just will have to add sites.

Client level data collection:
Broad Comments
Data collection Methods and time points:
1. “The SOR/TOR data collection will not interfere with ongoing program operations that
facilitate information collection at each site as state/territories and tribal entity are
already using collecting and reporting program data as a component of other SAMHSA
grants.”
This doesn’t make sense – these SOR data points are in addition to other SAMHSA data
collection requirements e.g. block grant, in some cases items are duplicative, but are not
collected at all of the same time points.
2. Also, more instructions per section for staff would be helpful in ensuring that SOR data
will be collected in a consistent manner.
Data Collection Time Points:
1. SOR/TOR grant programs will collect data at four time points: intake, three months post
intake, six months post intake, and discharge. The post intake data collections may
occur after the client has been discharged from the program. These 4 time points is
more than most SUD programs typically submit. Most complete 2 assessments
(enrollment and discharge), only MAT programs submit more (addition of a periodic
assessment, completed quarterly).
Difficulties:
Both of the sections noted below, requires programs to complete a clinical assessment prior to
completing these sections and related fields.
1. Behavioral Health Diagnoses: Depending on the type of program serving OUD patient
under SOR, it may be difficult to capture DSM 5 diagnoses/ICD 10 codes related to SUD
and MH (E.g. atr, wraparound or case management services). If there is no masters level
or higher clinician to make a clinical diagnoses, what is the data reporting expectation?
Is this a diagnosis that was made at the time of current treatment, or a previous
diagnosis? What if staff entering this data don’t know at the time of admission? There is
only an option “none of the above”. Should “don’t know” be added?
2. 2: Services Planned: Documenting all planned services during this current episode
treatment, would require a full clinical assessment assessing clients clinical and
wraparound needs prior to this point in time.

1

Question Specific Comments
Records Management:
1. Interview type – by having grantees fill his in an open ended space – it may be tough to
track what is baseline, 3 month, six months, and discharge (e.g. what if discharge was at
6 months, and technically they missed the actual 6 m assessment). Of course analysts at
the back end can figure this out, but may be messy. Perhaps having 2 questions that get
at which of the 4 time points this assessment is for, and a second question that collects
what month the actual assessment was completed.
Demographics
1. Question 3a – people who are transgender should be able to answer this question.
Currently the note says if sex=female, more directions might be helpful for staff
completing these assessments.
2. Question 3a- would be helpful to know how far a long someone is in their pregnancy?
Could inform treatment
3. Question 5 is missing a don’t know option (each question should consistently have a
don’t know and a declined option)
4. Question 4 – for Hispanic/Latino/a, or Spanish origin - add Salvadoran
5. Ethnicity is not collected. Suggestion – adding this element might be critical for
evaluation looking at cultural competency. (recommended responses: African, African
American, American, Asian Indian, Brazilian, Cambodian, Cape Verdean, Caribbean
Islander, Chinese Eastern European, European, Filipino, Haitian, Japanese, Korean,
Laotian, Latin American Indian, Middle eastern, Portuguese, Russian, Thai, Vietnamese,
Unknown, Unknown, Other – specify)
6. Currently no data collection related to Tribal community associations
7. Perhaps Q 9,10,11 should move under medical status
Medical Status
1. M1 and M1b. Might be helpful to ask these questions regarding past year as well.
2. M! and M1b – is there a maximum of digits?
Employment/Support Status
1. No comments/questions
Substance Use
1. Needs instructions. Yes/no, or indicating how many days?
2. For the alcohol us in the drug table, there is no definition for intoxication, or instructions
for completion

3. What about past year use?
4. For route of administration might be important to add vaping/e-cigarettes
5. Substance table is confusing in terms of how Opioids are captured – there should be a
clarification that this is non-medical use of prescription Opioids
2

6. D19 – 20. Remove “abuse” language, change to alcohol use disorder, and drug use
disorder
7. D19-D22 what if treatment episodes were for “addiction”/multiple SUD how would a
client respond to number of prior treatments by drugs or alcohol

Legal Status
1. Question L2 – asks if client is on parole or probation, is it potentially important to
distinguish these two categories (i.e. change the format of this question)
Family/Social Relationships
1. Question F4 has an option of “refused” which is inconsistent with all other SOR
questions that have the option as “declined”
2. Question F5 is missing the question number next to the question
3. Question F5 has an option of “refused” which is inconsistent with all other SOR
questions that have the option as “declined”
4. Questions skip from F10, to F18
5. Question F31 and F33 are out of order (they come after F34)
Psychiatric Status
1. For questions P1-2 Is there a maximum number of fields for number of times treated?
2. For P4 – P11, how should this be filled out (yes or not? Number of times?), also what
about options for don’t know in declined? These questions could benefit from
instructions.
Modified Colorado Symptom Index
1. For self-report measure of psychological symptomatology. Has good reliability and validity
(Conrad, K. J., Yagelka, J. R., Matters, M. D., Rich, A. R., Williams, V., & Buchanan, M. (2001)
Reliability and validity of a modified Colorado Symptom Index in a national homeless
sample. Mental Health Services Research, 3(3), 141-153.)

SOR/TOR Specific Questions
1. Subsequent to question 2, might be helpful to ask if Narcan was administered
2. For question 3, in the instructions indicate which section and question to refer back to
for this skip logic.
Services Provided
1. For baseline assessment, what is the timeframe for services received? Past year, past 6
months, etc.?
Discharge Status
1. Are staff supposed to fill out this portion, as well as all of the previous questions at
discharge? If so, directions would be helpful.

___________________________________________________________________
3

GPRA direction comparison to SOR client tool
1. Order of sections is different between two tools
2. Interview type is more clearly defined on gpra versus SOR tool
Gpra

SOR

3. GPRA asks about screening for co-occurring disorders, SOR does not

4. Planned services, gpra provides instructions, SOR tool does not
5. Planned services, medical services section is longer on SOR than GPRA (8 items versus 4)
6. SOR asks for ICD 10 codes related to behavioral health diagnoses, GPRA does not
7. Gender is captured differently
8. GPRA military section has skip logic, SOR does not
9. SOR does not ask about active duty, GPRA does
10. GPRA asks about family military involvement, SOR does not
11. Substance use history has different format, sor is missing instructions
12. GPRA has more detail regarding defining use (e.g. to intoxication, more than 5+ drinks in
one sitting), SOR does not have that

4

13. Past 30 days usual living arrangements are different
14. F6 – satisfaction scale is different
SOR

GPRA

15. SOR no longer has a military section, SOR has three questions that are at a much higher
level, e.g.
SOR

16. Gpra section on mental and physical health problems and treatment/recovery is more
detailed than SOR, which is now broken out into separate sections and does not have
the same level of detail
17. Services received in gpra, is now called services provided in SOR
18. Discharge status is different
SOR

5

GPRA

19. HIV questions not included in SOR, that are in GPRA

6

From:
To:
Cc:
Subject:
Date:
Attachments:

Pelotte, Tara M
King, Summer (SAMHSA/OPPI)
Clark, Spencer (SAMHSA/CSAT/DPT); Coutu, Katherine
FW: [EXTERNAL SENDER] Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection and Performance Measurement—NEW
Monday, December 3, 2018 4:17:39 PM
Attachment A - SOR TOR Client Instrument.docx
Attachment B - SOR TOR Program Instrument.docx
SOR TOR OMB SS-A 10.4.2018.docx
SOR TOR OMB SS-B 9.20.2018.docx

Good morning, Ms. King 
Please see the comments below from the State of Maine re: the proposed data collection instruments:
 
SSA Comments:
 
Based on the language of these documents, our understanding is such that in order to operationalize these data collection protocols properly, Maine will require the use a staff resource or contracted
resource to collect the required data from program providers as outlined in Attachments A and B. Program providers in Maine will Not be asked to complete a separate form, which would cause
duplication and undue administrative burden in the midst of an opioid crisis, they will only be asked to update their own EHR assessments and tools in order to comply with these new SOR reporting
requirements (if necessary).
 
Provider comments:
 
In regard to the information Katherine has requested we gather in our assessment there are a few challenges from a logistical standpoint. To that end, the measure would need to be done separately
and in addition to the biopsychosocial assessment. To that end however, many of the questions asked by the instrument would also assist in gathering and starting the discussion for much of the
information for the biopsychosocial itself. 
 
 My overall clinical consensus is that a good share of the information gathered will answer much of the questions asked of us to gather but will be cumbersome on both ends for the state to pull it
from our biopsychosocial. In addition,although some of the information/data is gathered as part of our biopsychosocial assessment: some of the questions regarding behaviors and circumstances for
specific time periods would not be (i.e., past 90 day mental health symptoms, etc) . To ask these questions with program clients in a general interview with such specificity in the psychosocial
interview would in many instances feel fragmented and awkward for the clinician and the client. 
 
Lastly, the section regarding past 30 day substance use will be skewed with many of our clients in the jail for obvious reasons. Will this issue be considered and weighted when the state/ feds look at
our indicators and outcomes? When I reviewed the instrument again I noticed that the job questions had a fine print guiding how incarcerated individuals should answer so that is helpful. 
 
Overall, I personally feel comfortable with administering this instrument as an additional piece to the assessment . More instrument equates to more time needed to assess a client in any setting; so
as long as that is understood by all then it should be fine. Clinically speaking, administering the intrustrument should be explained as such to the client as a way to gather information for current and
future program needs and outcomes as opposed to the biopsychosocial which is done to understand the individual.
 
 
Thank you and please reach out to me if I can offer additional information.
 
Tara
 
 

    Tara M. Pelotte

SAMHS Project/Grant Manager
Maine Department of Health and Human Services
Office of Substance Abuse and Mental Health Services
#11 State House Station, 41 Anthony Avenue
Augusta, ME 04333-0011
Desk (207) 287-2516   Cell (207) 458-4587

 
 
From: Clark, Spencer (SAMHSA/CSAT/DPT) [mailto:Spencer.Clark@samhsa.hhs.gov]
Sent: Wednesday, October 17, 2018 5:44 PM
To: lauren.siembab@ct.gov; Parks, Michael ; Connors, Tom ; Coutu, Katherine ; Allison.bauer@state.ma.us;
amy.sorensen-alawad@state.ma.us; Nicole.m.schmitt@state.ma.us; Jennifer.miller@state.ma.us; Hannah.Lipper@state.ma.us; Abby.Shockley@dhhs.nh.gov; Donald.Hunter@dhhs.nh.gov;
Cynthia.Thomas@vermont.gov; Megan.Mitchell@vermont.gov; Mariah.Ogden@vermont.gov; sgoldsby@daodas.sc.gov; dwalker@daodas.sc.gov; ckraeff@daodas.sc.gov; bpowell@daodas.sc.gov;
rbraneck@daodas.sc.gov; taryn.sloss@tn.gov; linda.mccorkle@tn.gov; Anthony.jackson@tn.gov; richard.sherman@illinois.gov; terry.cook@fssa.in.gov; Rebecca.Buhner@fssa.IN.gov;
Jeremy.Heyer@fssa.IN.gov; Cassandra.Anderson2@fssa.IN.gov; Mark.Loggins@fssa.IN.gov; Kelly.Welker@fssa.IN.gov; ScottL11@michigan.gov; BullardS@michigan.gov; SmithA8@michigan.gov;
dave.rompa@state.mn.us; faye.bernstein@state.mn.us; Ellen.Augspurger@mha.ohio.gov; Sanford.Starr@mha.ohio.gov; joyce.allen@wisconsin.gov; Jason.Harris@dhs.wisconsin.gov;
Scott.stokes@dhs.wisconsin.gov; tcroom@odmhsas.org; monica.wilke-brown@idph.iowa.gov; Sharon.Kearse@ks.gov; rick.gowdy@dmh.mo.gov; rachel.winograd@mimh.edu;
philip.horn@mimh.edu; tamara.gavin@nebraska.gov; Marlies.Perez@dhcs.ca.gov; tfsunia@dhss.as; herbert.sablan@gmail.com; bvictor@fsmhealth.fm; athena.duenas@gbhwc.guam.gov;
temengil.ej@gmail.com
Subject: [EXTERNAL SENDER] Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection and Performance Measurement—NEW
 
Dear STR and SOR Project Directors and Staff:
 
This is in follow-up to my correspondence to you of last week, indicating the publication of a Federal Registry Notice (FRN) containing the proposed reporting guidelines for the SOR and TOR Grant
initiatives.
 
Please find attached below the proposed SOR information plans and reporting instruments that were referenced in the recent posting of the Federal Register for your review and comment.
 
I cannot emphasize too greatly how important it is for you to carefully review and comment on these reporting tools, and provide whatever recommendations that you have regarding
implementation issues. 
 
I am hopeful that with your feedback we can enter into a meaningful dialogue to maximize the usefulness of this reporting, and minimize any unnecessary reporting burden.
 

Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57-B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov.
 

Written comments should be received by December 3, 2018.
I would appreciate your copying me on any feedback that you provide in this process so that I can be fully prepared to particiapte in this dialogue.
 
Thank you and best regards,
 

Spencer Clark
 
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/

Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857 
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
 

 
 
_____________________________________________
From: King, Summer (SAMHSA/OPPI)
Sent: Tuesday, October 09, 2018 10:19 AM
To: Clark, Spencer (SAMHSA/CSAT/DPT) 
Cc: Jacobus-Kantor, Laura (SAMHSA/CBHSQ) 
Subject: RE: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a Copy of the Information Collection Plans for the SOR and TOR Grant Initiatives
 
 
 
Hi Spencer,
Attached are copies of the information plans and the instruments.  Please let me know if you need anything else.
Thanks,
Summer
 
_____________________________________________
From: Clark, Spencer (SAMHSA/CSAT/DPT)
Sent: Tuesday, October 9, 2018 10:07 AM
To: King, Summer (SAMHSA/OPPI) 
Subject: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a Copy of the Information Collection Plans for the SOR and TOR Grant Initiatives
 
 

Dear Summer:
Please provide me with a copy of the information collection plans and copies of the instruments as described below in the FRN released last week:
In compliance with Section 3506(c)(2)(A) of the Paperwork Reduction Act of 1995 concerning opportunity for public comment on proposed collections of information,
the Substance Abuse and Mental Health Services Administration (SAMHSA) will publish periodic summaries of proposed projects. To request more information on the
proposed project or to obtain a copy of the information collection plans, call the SAMHSA Reports Clearance Officer on (240) 276-1243.
Comments are invited on: (a) Whether the proposed collections of information are necessary for the proper performance of the functions of the agency, including
whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden of the proposed collection of information; (c) ways to
enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including
through the use of automated collection techniques or other forms of information technology.

Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR)
Program Data Collection and Performance Measurement—NEW
The Substance Abuse and Mental Health Services Administration's (SAMHSA) Center for Substance Abuse Treatment (CSAT) is requesting approval from the Office
of Management and Budget (OMB) for data collection activities associated with the State Opioid Response (SOR) and Tribal Opioid Response (TOR) discretionary
grant programs. Approval of this information collection will allow SAMHSA to continue to meet the Government Performance and Results Modernization Act of 2010
(GPRMA) reporting requirements that quantify the effects and accomplishments of its discretionary grant programs which are consistent with OMB guidance.
Information collected through this request will be used to monitor performance throughout the grant period.
There will be up to 359 award recipients (states, territories, and tribal entities) in these grant programs. Grantee-level data will include information related to naloxone
purchases and distribution. This grantee-level information will be collected quarterly.
All funded states/territories and tribal entities will also be required to collect and report client-level data on individuals who are receiving opioid treatment services to
ensure program goals and objectives are being met. Client-level data will include information such as: Demographic information, services planned/received, mental
health/substance use disorder diagnoses, medical status, employment status, substance use, legal status, and psychiatric status/symptoms. Client-level data will be
collected at intake/baseline, three months post intake, six months post intake, and at discharge.
CSAT anticipates that the time required to collect and report the grantee-level data is approximately 10 minutes per response, and the time required to collect and
report the client-level data is approximately 47 minutes per response. CSAT's estimate of the burden associated with the client-level instrument includes an adjustment
for data elements that are currently being collected by entities that are likely to be funded by the SOR/TOR grant programs. Start Printed Page 50117
Table 1—Estimate of Annualized Hour Burden for SOR/TOR Grantees
SAMHSA data Collection

Number of
respondents

Responses per
respondent

Total number of
responses

Burden hours per
response

Total burden Hours

Grantee-Level Instrument

359

4

1,436

.17

244

Client Level Instrument: Baseline Interview

165,000

1

165,000

.78

128,700

Client-Level Instrument: Follow-up
Interview 1

132,000

2

264,000

.78

205,920

Client-Level Instrument: Discharge
Interview 2

85,800

1

85,800

.78

66,924

CSAT Total

165,359

516,236

401,788

Notes:
1

 It is estimated that 80% of baseline clients will complete the three month and six month follow-up interviews.

2

 It is estimated that 52% of baseline clients will complete this interview.

Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57-B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov. Written comments should be received by December 3, 2018.
Start Signature
Summer King,
Statistician.

End Signature End Preamble
[FR Doc. 2018-21576 Filed 10-3-18; 8:45 am]
BILLING CODE 4162-20-P
 
 
Thank you and best regards,
 

Spencer Clark
 
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857 
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
 
<< OLE Object: Picture (Device Independent Bitmap) >>
 
 
 

From:
To:
Cc:
Subject:
Date:

Nora Murphy
King, Summer (SAMHSA/OPPI)
Loretta Dixon
Minnesota Dakota Consortium and Lower Sioux Indian Community Feedback on the Proposed Project: State
Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection and Performance
Measurement—NEW
Friday, November 30, 2018 4:50:28 PM

Hello Ms. King,
Below please find comment on the TOR collection data requirements from the Lower Sioux and the
MN Dakota Consortium, a TOR grantee.
Consortium members (including Dr. Rosemary White Shield, psychologist Dr. Hawkins, and a
community LADC) express great concern about the SPARS/CSAT-GPRA tool. One of the concerns is
that its use may cause harm and re-trigger many of our tribal members and lead to increased, not
decreased, opioid use. Furthermore, the tool is divergent to the Kinship System Circle Model (KSCM).
KSCM is the model that our Consortium is piloting through the TOR project. Therefore, the four
tribes, led by Lower Sioux, have sent a formal request to SAMSHA for exemption from using the
proposed GPRA tool. A copy of our formal request signed by the leaders of all four tribes is available
upon request.
Sincerely, Nora Murphy
 
Nora Murphy
Tribal Planner & Grant Writer
Lower Sioux Indian Community
Phone: (507) 697-8638
Email: nora.murphy@lowersioux.com

 

MICHAEL L. PARSON

MARK STRINGER

GOVERNOR

DIRECTOR

RICHARD N. GOWDY, PH.D.
DIRECTOR

DIVISION OF
BEHAVIORAL HEALTH
(573) 751-9499
(573) 751-7814 FAX

STATE OF MISSOURI
DEPARTMENT OF MENTAL HEALTH
1706 EAST ELM STREET
P.O. BOX 687
JEFFERSON CITY, MISSOURI 65102
(573) 751-4122
(573) 751-8224 FAX
www.dmh.mo.gov

December 1, 2018
To Whom It May Concern:
Missouri Opioid STR/SOR leadership and treatment providers have reviewed and discussed the potential impact of
the proposed data collection and outcomes measurement tool and our concerns are outlined below.
With resources limited and costs associated with a new treatment model being difficult to project, the Department of
Mental Health (DMH) spent Opioid STR direct treatment dollars six months ahead of schedule as we implement the
Medication First Model, a chronic disease/medical model, in Missouri. Due to increased costs associated with this
model and in an effort to make this model financially viable we are looking to fund administrative positions at our
treatment locations to support their efforts. With the added requirement of the proposed data collection tool we
would also need to reimburse our providers for the added work and time.
Our projected fiscal impact of this added requirement:
Our projected consumer target is 2,662. Assuming intake GPRAs are collected on each individual and an 80%
follow-up rate throughout our projected cost on services is $527,990. If intake GPRAs were collected on each
individual and maintain a 50% follow-up rate throughout our projected cost is $379,907. This does not take into
account any administrative time, personnel costs, or additional costs associated with follow-up tracking activities.
Previous GPRA follow-up tracking and locating efforts have included phone calls, letters, emails, and even homevisits. These additional costs on added services are difficult to project, but minimum calculations estimate a fiscal
impact between $132,780 - $265,561 in added services and an approximate administrative burden of $500,000 on
our Opioid SOR treatment provider system. Department staff conducted mock interviews with the proposed tool and
found it more time intensive than the GPRA tool used with two STR providers as part of an independent evaluation
with Mathematica. Without factoring in the administrative cost to our providers, conservative estimates place fiscal
burden at $512,687 and perhaps more realistic projected cost of $793,551.
Additionally, Missouri’s Medication First model dictates that our treatment providers collect and report relevant
information related to medication utilization for STR/SOR clients and this has placed an added un-billable
administrative burden, which would increase with the proposed tool. The Department of Mental health eliminated or
edited most all intake requirements to allow for someone in active withdrawal to be seen by a physician almost
immediately, and the proposed SOR data collection tool will add a significant barrier to the intake process utilizing
the Medication First Model. It is noted the beginning of the proposed tool is from the Addiction Severity Index
(ASI), one such component eliminated from the immediate intake process. Having to collect information upon
intake which is not minimally needed to be seen by a doctor was top priority for our Medication First Model and
adding this requirement will deeply impact the time associated with an intake and the number of individuals that
may access treatment on a given day as our treatment locations are limited by staff availability and staff time.
Sincerely,

Tim Rudder, LMSW, State Opioid Coordinator
Missouri Department of Mental Health
TR:ldn
An Equal Opportunity Employer; services provided on a nondiscriminatory basis.

From:
To:
Cc:
Subject:
Date:

Gavin, Tamara
King, Summer (SAMHSA/OPPI)
Clark, Spencer (SAMHSA/CSAT/DPT)
SOR Data reporting feedback
Monday, December 3, 2018 10:06:53 PM

Please accept the following feedback specific to SOR reporting information that was sent for state
feedback.
 
During the webinar on Friday, 11/30/2018, it was clarified that grantees will not be able to contract
out with 3rd party vendors to assist in SPARS data collection and entry. This is allowed in other
SAMHSA discretionary grants and, as such, Nebraska has established processes and contractual
relationships that make this a very efficient process. News that this will not be an allowable activity
and that grantees must be the point of SPARS data entry creates significant barriers—and will likely
create substantial delays in ability to conduct data entry—as systems will need to be updated in
order to allow for this. If any reconsideration could be made to this restriction, it would be greatly
appreciated.
 
Additionally, it was clarified that the client-level data tools that are awaiting OMB approval have not
been released for review; therefore, we ask if there will be an opportunity to review and provide
feedback on the client-level tool that will be used?
 
Tamara Gavin | Deputy Director Of Behavioral Health Services
BEHAVIORAL HEALTH

Nebraska Department of Health and Human Services
OFFICE:

402-471-7732

DHHS.ne.gov  |  Facebook  |  Twitter  |  LinkedIn

 

From:
To:
Subject:
Date:

shauntay McCollough
King, Summer (SAMHSA/OPPI)
SOR Program Data Collection
Tuesday, October 23, 2018 12:32:59 PM

I hope and pray that this is not something that will be implemented here in Missouri.  Our facility
along with others are doing a greater job than just a year ago with the tools that we have now and
adding additional data request will only cause the loss of consumer participation along with loss of
billing due to a non reimbursable additional questionnaire.  I understand the need for the data but,
this seems to be more about numbers and data instead of the actual service to the consumer. 
Thank you for your time and I hope the response’s from myself and others will make a direct impact
on the decisions being made.
 
 
Shauntay McCollough B.S.
Chief Executive Officer
New Beginnings C-STAR Inc.
1027 S. Vandeventer, Floor 3
St. Louis, MO  63110
PH: (314) 367-8989 Ext. 254
FX: (314) 367-2188
EM: shauntay@newbeginningscstar.org
CN: (314) 757-0106
 
Mathew 20:16 
 
 

NORTHWEST
PORTLAND
AREA
INDIAN
HEALTH
BOARD

SUBMITTED VIA EMAIL: summer.king@samhsa.hhs.gov
December 3, 2018
Summer King
SAMHSA Reports Clearance Officer
Substance Abuse and Mental Health Services Administration
5600 Fishers Lane, Room 15E57-B
Rockville, Maryland 20857

Burns-Paiute Tribe
Chehalis Tribe
Coeur d’Alene Tribe
Colville Tribe
Coos, Siuslaw, &
Lower Umpqua Tribe
Coquille Tribe
Cow Creek Tribe
Cowlitz Tribe
Grand Ronde Tribe
Hoh Tribe
Jamestown S’Klallam Tribe
Kalispell Tribe
Klamath Tribe
Kootenai Tribe
Lower Elwha Tribe
Lummi Tribe
Makah Tribe
Muckleshoot Tribe
Nez Perce Tribe
Nisqually Tribe
Nooksack Tribe
NW Band of Shoshoni Tribe
Port Gamble S’Klallam Tribe
Puyallup Tribe
Quileute Tribe
Quinault Tribe
Samish Indian Nation
Sauk-Suiattle Tribe
Shoalwater Bay Tribe
Shoshone-Bannock Tribe
Siletz Tribe
Skokomish Tribe
Snoqualmie Tribe
Spokane Tribe
Squaxin Island Tribe
Stillaguamish Tribe
Suquamish Tribe
Swinomish Tribe
Tulalip Tribe
Umatilla Tribe
Upper Skagit Tribe
Warm Springs Tribe
Yakama Nation

RE: Agency Information Collection Activities: State Opioid Response (SOR)
and Tribal Opioid Response (TOR) Program Data Collection and Performance
Measurements
Dear Officer King:
On behalf of the Northwest Portland Area Indian Health Board (NPAIHB), I
submit the following comments on the State Opioid Response (SOR) and Tribal
Opioid Response (TOR) Program Data Collection and Performance
Measurements, in response to the Substance Abuse Mental Health Services
Administration (SAMHSA) agency information collection request, dated October
4, 2018. Established in 1972, the NPAIHB is a tribal organization formed under
the Indian Self-Determination and Education Assistance Act (ISDEAA), P.L. 93638, representing the 43 federally-recognized Indian Tribes in Idaho, Oregon, and
Washington on health care issues. In the Portland Area, 75% of the total IHS
funding is compacted or contracted and includes 6 federally operated service units,
17 Title I Tribes, 25 Title V Tribes, 3 urban facilities, and 3 treatment centers.
NPAIHB operates several important health programs that support our member
tribes, including the Northwest Tribal Epidemiology Center,1 and works closely
with the Portland Area Indian Health Service (IHS). NPAIHB appreciates the
opportunity to provide comments on the accuracy of SAMHSA’s estimate of the
burden of the proposed collection of information on SOR and TOR grantees.
Background
American Indian/Alaska Native (AI/AN) communities experience disparities in
many health outcomes 2 including overdose deaths 3. In 2015, AI/ANs had the
1

2121 S.W. Broadway
Suite 300
Portland, OR 97201
Phone: (503) 228-4185

Fax: (503) 228-8182
www.npaihb.org

A "tribal organization" is recognized under the Indian Self-Determination Education Assistance Act (P.l. 93638; 25 U.5.C. § 450b(1)) as follows: "[T]he recognized governing body of any Indian tribe; any legally
established organization of Indians which is controlled, sanctioned, or chartered by such governing body or
which is democratically elected by the adult members of the Indian community to be served by such
organization and which includes the maximum participation of Indians in all phases of its activities."
2

Indian Health Service. Indian Health Disparities. In. https://www.ihs.gov/newsroom/factsheets/disparities/;
2017.

Summer King
SAMSHA Reports Clearance Officer
December 3, 2018
Page 2
highest drug overdose death rates and the largest percentage increase in the number of deaths over
time4. The opioid pain reliever-related overdose death rate for AI/ANs was 22.1 per 100,000
population in 20155. In 2010, the opioid overdose death rate among AI/AN women was 7.3 per
100,000 population, compared with a rate of 5.7 among white women and 4.2 among all U.S.
women6.
In addition, national trends documenting this disparity appear to be consistent regionally, by IHS
Areas and states, where AI/AN-specific data are available. In the Portland IHS Area (Idaho,
Oregon, and Washington) a race-corrected analysis found the age-adjusted drug overdose death
rate for AI/ANs for opioid, prescription drug, and all drug overdoses to be twice that of nonHispanic whites (NHW) 7. Limited access to specialized health care services contributes to and
exacerbates disparities in nonfatal and fatal opioid overdose among AI/ANs. Tribal communities
are often located far from urban facilities where various specialized health services for opioid
addiction treatment are available. In 2014, there were only eight tribal health facilities with
Medication-assisted treatment (MAT)/Office-based Opioid Agonist Treatment (OBOT) services,
and six tribal programs with MAT/OBOT policies and procedures 8.
The SAMHSA TOR grant program aim is to address the opioid crisis in tribal communities by
increasing access to culturally appropriate and evidence-based treatment, including MAT using
one of the three Food and Drug Administration (FDA)-approved medications for the treatment of
opioid use disorder (OUD). The intent is to reduce unmet treatment need and opioid overdoserelated deaths through the provision of prevention, treatment and/or recovery activities for OUD.
Overall, 35 of the 43 Tribes in the Idaho, Oregon and Washington received SAMHSA TOR
funding. NPAIHB was awarded SAMHSA TOR funding for a consortium of 22 Tribes in Idaho
(2), Oregon (6) and Washington (14) including Burns Paiute, Chehalis, Confederated Tribes of
Coos, Lower Umpqua and Siuslaw Indians (CTCLUSI), Confederated Tribes of Umatilla,
Coquille, Cow Creek Band of Umpqua, Hoh, Kalispel, Klamath, Kootenai, Lower Elwha Klallam,
NW Band of Shoshone, Nooksack, Quinault, Samish, Shoalwater Bay, Skokomish, Spokane,
Stillaguamish, Suquamish, Swinomish, Upper Skagit.
The NPAIHB TOR Consortium is working to address the opioid crisis in tribal communities by
increasing capacity to address the complex factors associated with a comprehensive opioid
response, including: access to culturally appropriate prevention, treatment and recovery activities
with the intent of reducing unmet treatment need and opioid-related deaths, as well as a focus on
3

Mack KA, Jones CM, Ballesteros MF. Illicit Drug Use, Illicit Drug Use Disorders, and Drug Overdose Deaths in Metropolitan and
Nonmetropolitan Areas - United States. MMWR Surveill Summ 2017;66(No. SS-19):1-12. DOI:
http://dx.doi.org/10.15585/mmwr.ss6619a1; Newell, Jennifer 
Subject: FW: SOR
Importance: High
 
fyi
 
From: Thierry, Kim (SAMHSA) 
Sent: Wednesday, October 31, 2018 3:40 PM
To: Skiles, Jodi 
Cc: Somerville, Gerlinda (SAMHSA/CSAT) ; DiDomenico, Ellen

Subject: RE: SOR
Importance: High
 
Hi Jodi. Attached are proposed SOR information plans and reporting instruments that are referenced in the recent
posting of the Federal Register bulletin. (attached)
Comments are requested by 3 Dec. and information on where to send those comments is referenced in the Federal
Register Notice.
I hope this information is useful.
Kim T-E
 
Kim Thierry English, M.ED, NCAC II, MAC
Public Health Advisor
Health Systems Branch
Division of Services Improvement
SAMHSA's Center for Substance Abuse Treatment
5600 Fishers Lane
13E70-E
Rockville, Md. 20857
Ph. 240.276.2907
Fax-240.276.1690
e-mail kim.thierry@samhsa.hhs.gov
AWS (off duty),Fridays
This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received
this email in error) please notify the sender immediately and destroy this email. Any unauthorized copying, disclosure or
distribution of the material in this email is strictly forbidden.

 
From: Skiles, Jodi 
Sent: Wednesday, October 31, 2018 2:52 PM
To: Thierry, Kim (SAMHSA) 
Cc: Somerville, Gerlinda (SAMHSA/CSAT) ; DiDomenico, Ellen

Subject: RE: SOR
 
Kim:
Just an FYI.  We were on a call with some other states regarding our data system and potential enhancements and
some of them were saying that they heard that it may be the same GRPA that we collected for STR?  Not sure if there

is any fact to that, but thought that if we thought that might be the route that we could at least begin serving
individuals from this funding stream. 
Thank you for understanding!!
Jodi
 
From: Thierry, Kim (SAMHSA) 
Sent: Wednesday, October 31, 2018 12:28 PM
To: Skiles, Jodi 
Cc: Somerville, Gerlinda (SAMHSA/CSAT) 
Subject: RE: SOR
 
Hi Jodi. I apologize., but I do not have any updates. I will re-forward your previous inquiry to  CSAT Leadership and
request a response.
Thank you,
Kim T-E
 
Kim Thierry English, M.ED, NCAC II, MAC
Public Health Advisor
Health Systems Branch
Division of Services Improvement
SAMHSA's Center for Substance Abuse Treatment
5600 Fishers Lane
13E70-E
Rockville, Md. 20857
Ph. 240.276.2907
Fax-240.276.1690
e-mail kim.thierry@samhsa.hhs.gov
AWS (off duty),Fridays
This email may contain confidential and/or privileged information. If you are not the intended recipient (or have received
this email in error) please notify the sender immediately and destroy this email. Any unauthorized copying, disclosure or
distribution of the material in this email is strictly forbidden.

 
From: Skiles, Jodi 
Sent: Wednesday, October 31, 2018 10:09 AM
To: Thierry, Kim (SAMHSA) 
Subject: SOR
 
Good Morning Kim!
Hope that you are well!  I wanted to follow up with you on data and expectations.  We have projects ready to go, and
are hoping to understand the requirements, and if we can get started. 
Any insight would be helpful.
Thanks so much Kim.
 
Jodi Skiles | Director
Bureau of Treatment, Prevention and Intervention
Department of Drug and Alcohol Programs
One Penn Center, 5th Floor
2601 N 3rd Street, Harrisburg, PA 17110
Phone: 717.736.7454 |Mobile 717.503.6326 |Fax: 717.787.6285
www.ddap.pa.gov
 
Follow us:

 

  

From:
To:
Subject:
Date:

Cori Putz
King, Summer (SAMHSA/OPPI)
SOR/TOR potential reporting requirements
Monday, October 22, 2018 3:27:48 PM

Good Afternoon;
 
There is no doubt that we value outcomes and want to know that our applied interventions are
having a positive impact in the lives of those we serve.  However, over the past 18 months, Missouri
DMH, in conjunction with Providers, has done an incredible job of minimizing/removing barriers to
assist those most in need to access services in a timely manner & remain engaged in treatment.  This
accomplishment is primarily the result of the removal of stringent requirements for specified
services in order to be admitted and/or to remain enrolled in services.
 
We have made great strides in delivering only those services that the individual believes he/she will
benefit from.  The introduction of a mandated service brought about by these reporting
requirements at the said intervals (admission, 3 months, 6 months, and discharge) will place undue
expectations on those that we serve and is in direct conflict with the service model that we have
worked so very hard to create. 
 
This instrument is all too familiar to those of us in Missouri given that it is the Addiction Severity
Index (ASI) with several extra pages of questions on each end of it.  Asking an individual at time of
admission, who is usually in active withdrawal, to be alert and sit with us patiently while we
complete a questionnaire that takes about 45 minutes, is not reasonable nor is it a client-centered
practice which is exactly why Missouri, not so long ago, extended our assessment completion time
frame.  As a side note, there are still many agencies currently utilizing the ASI for assessments in
Missouri within a multitude of electronic medical records, this will be duplicative for both the client
and the clinician.
 
Facilitating this instrument at each said interval also has the potential to divert approximately $1
million away from direct service that will benefit the client for every 1,000 individuals served through
these funds in Missouri.  This number accounts for the direct service hours expected to be
associated with facilitation of this service since Providers will need to be reimbursed for facilitating
this tool at each said interval, including admission.   This does not take into account the additional
necessary staff time that will need to be dedicated to locating or contacting dis-engaged clients and
clients who have very low frequency/intensity of service in order to meet the 80% threshold of
completion.
 
Reducing the number of fields to “critical information only” coupled with less frequent intervals of
completion may be helpful in making this more palatable for those we serve OR we can utilize the
GPRA at Admission, 6 months, and Discharge.
 
Sincerely,
cori
 

Corinna Putz

Exec VP Substance Use Disorders
Preferred Family Healthcare
 

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From:
To:
Cc:
Subject:
Date:
Attachments:

Wolfgang, Tiffany
King, Summer (SAMHSA/OPPI)
Baltzer, Breinne; Rachel Oelmann; Bankhead, Jamal (SAMHSA)
FW: State Opioid Response 60-Day FRN for Data Collection Tool
Monday, December 3, 2018 4:53:11 PM
SOR TOR 60-Day FRN.pdf

Ms. King,
Please accept the below comments as part of the public comment period related to SOR/TOR
attached notice. Per the direction, South Dakota would like to submit the below as cited in the
attached document:
Comments are invited on:
(a) Whether the proposed collections of information are necessary for the proper performance of
the functions of the agency, including whether the information shall have practical utility;
The instruments as designed do not appear to collect much information regarding actual opioid use,
but rather focus on potential co-occurring behavioral health diagnoses, medical status on issues not
related to substance abuse or treatment, employment status, household cash flow sources,
incarceration/law enforcement history, pension payments, etc.  What and how will this information
be used for in terms of programmatic enhancement or improvement at the federal level in
combating the opioid crisis?  Some of the information collected may be useful at the state level,
however the current tool is intrusive and will result in clients not retaining in much needed
treatment and recovery services. South Dakota would not find the proposed data to be useful nor
necessary for proper performance nor to have practical utility.
 
(b) the accuracy of the agency’s estimate of the burden of the proposed collection of information;
 The GPRA Baseline and Follow-up/Discharge Instrument is considerably longer and more intense
than the state's assumptions upon creating a cost proposal to support administrative and data
collection efforts in SOR. In comparison, the baseline assessment GPRA tool presently used on the
state's SBIRT grant is limited to six (6) questions upon screening, an additional question series about
past-30 day use of alcohol or illegal substances upon delivery of a service, and brief questions upon
discharge as well as one follow-up interval. Should the drafted instruments move forward and be
required for use in SOR, the state will need to do significant re-planning with existing MAT providers
to ensure the data elements can be collected in a way that does not significantly impact clinic workflow. If this process is placed on the contracted entities to conduct with their patients (best case
scenario to ensure data is captured), it is burdensome to the point the state fears entities may opt to
not contract for MAT expansion/enhancement services, either pursuing on their own or more likely
not pursuing at all.
 
The practical application of asking a patient seeking treatment or peer recovery supports for OUD
the breadth of these questions presents a host of concerns, not the least of which will undoubtedly
be turning off patients from actually proceeding with the treatment or supports they were originally
seeking.  The estimated burden for collecting this information is noted as 30 minutes in the cover
sheet; ironically, this is the same level of burden associated with the previously mentioned GPRA
client outcomes tool used in the state SBIRT grant program which contains fewer questions and less
sub-questions/skip logic. The ability to ask and attain answers to this complexity and number of
questions upon intake into services is unreasonable and is anticipated to be off-putting to patients.
 

The types of questions asked (e.g. legal status, including arrest/charge records, # of days in the past
month the patient has been engaged in illegal activities for profit, experience and extent of family
problems) may be off-putting to patients, not necessarily garner truthful responses, and may be a
barrier to them seeking support/care/treatment.
 
The cost allocation to South Dakota for data enhancements (capped at 2% of the total award per
year, or $80,000) along with the timeline required for deployment (not formally defined but
anticipated to be ASAP, at the latest upon approval of the data collection tools from OMB) do not at
all align with needing to revamp an existing data system as previously mentioned or create a new
data system to capture these outcomes for a two-year grant period.
 
(c) ways to enhance the quality, utility, and clarity of the information to be collected; and
The state originally envisioned leveraging its existing statewide treatment data collection system
(STARS) to capture the required client-level outcomes data for SOR.  This system is used by
accredited substance abuse providers in South Dakota, so they are familiar with its functionality and
have access to it for the report of state-funded treatment outcomes data. Upon review of the
proposed baseline instruments, very few questions overlap between the proposed instruments and
what is presently reported in STARS, and thus significant enhancements to STARS and/or creation of
an entirely new system will be required to achieve the desired outcome and comply with the federal
requirements set forth. 
 
(d)ways to minimize the burden of the collection of information on respondents, including through
the use of automated collection techniques or other forms of information technology.
A critical control point in the SBIRT process has been to ensure screening and data collection tools
are integrated into the electronic medical record; if not integrated, the successful collection and
retention of that information is subject to staff time/availability and training to do so.  Given the
rapid deployment of a data collection solution for SOR grantees (essentially now) required by
SAMHSA, the fact that adoption of electronic medical records is not consistent across SD treatment
agencies, and the fact that clinics serving as a MAT prescriber in this case do not consistently use the
same EMR platform, significant technological hurdles will need to be overcome to ensure that the
data can be captured in a way that is not paper-based, burdensome to the clinic/treatment agency,
and accurate and timely in its collection. Partnership with the State's HIE is possible, but not in the
timeline required. Consideration should be given to data currently collected for TEDS and then
assessing what additional questions are needed to capture effectiveness/impact for OUD patients is
our recommendation.
 
 
Tiffany Wolfgang
Director, Division of Behavioral Health
Department of Social Services
3900 W Technology Circle, Suite 1
Sioux Falls, SD 57106
(605) 367-5236
 
DSS- Strong Families- South Dakota’s Foundation and our Future

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The Department of Social Services does not exclude, deny benefits to, or otherwise discreiminate against any person on the basis of
actual or perceived race, color, religion, national origin, sex, age, gender identify, secual orientation or disability in admission or access to,
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Complaint you may contact: Discremination Coordinator, Director of DSS Division of Legal Services, 700 Governor’s Drive, Pierre SD
57501, 605-773-3305.

 

From:
To:
Subject:
Date:

Clif Johnson CRAADC
King, Summer (SAMHSA/OPPI)
GPRA feedback SOR grant
Friday, October 19, 2018 11:57:03 AM

Please consider our feedback, we are currently doing the GPRA for the STR grant:
 
a. Whether the proposed collections of information are necessary for the

proper performance of the functions of the agency, including whether the
information shall have practical utility;  The collection of the data currently is
separate from the “function” of performance of our agency. We currently provide
the GPRA for the STR grant, we do not get consistent and timely data back to
allow the information to “provide practical utility”, this may be due to the period
of time data has been collected to allow for a large enough data pool.
 
b. The accuracy of the agency's estimate of the burden of the proposed
collection of information; The new GPRA tool for the SOR is much longer,
causing a corresponding increase in the time our staff must expend completing
the instrument.  The addition of a 3 month follow up to be completed adds
additional time for support staff to track due dates, and schedule a time to
complete the instrument. We currently, expend considerable resources spent
just scheduling and tracking the six- month follow up.
 
 
c. Ways to enhance the quality, utility, and clarity of the information to be
collected; The pressure to get an 80% completion rate may affect the accuracy
of the information collected.  We are expending resources to collect the data,
but are not receiving feedback timely enough to be as efficient in recognizing
deficit and strength areas.  More frequent reports would help the agency identify
trends for action planning.  A stipend to incentivize  the patient to complete the
follow up tools would help in increasing participation.  
 
d. Ways to minimize the burden of the collection of information on

respondents, including through the use of automated collection
techniques or other forms of information technology. Remove that 3 month
collection point for sure. Reduce the number of questions and pages to the
document. The sheer length of it would cause any person to not want to “selfcomplete” it as an option.  Development of a web-based system that allows
individuals to complete the instruments at the required times from their home, or
smart phone.
 
 
 

Clif Johnson CRAADC | Director of Clinical Compliance and Physician Services | 573-756-5749 O 
+15737606084 M
1565 Ste. Genevieve Avenue-PO Drawer 459 | Farmington, MO  63640-0459
________________________________
CONFIDENTIALITY NOTICE:  This e-mail communication and any attachments may contain
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573-756-5749, and destroy all copies of this communication and any attachments immediately.
 

From:
To:
Cc:
Subject:
Date:

Andrea Buford
King, Summer (SAMHSA/OPPI)
Clark, Spencer (SAMHSA/CSAT/DPT)
URGENT - Please respond (SOR) Program Data Collection and Performance Measurement—NEW
Tuesday, November 27, 2018 3:35:24 PM

Hello, we would have to agree with the responses of many of our colleagues.  A reporting
requirement of this magnitude and frequency would put a huge strain on providers and
support staff and create the need to consider how to capture reimbursement for time spent
collecting information.  The number of times this information is to be gathered is likely to
be a deterrent for clients who are in recovery and who have adjusted to the Medication
First Model.  The very nature of the questions and stringent reporting requirements would
set our processes back and could blur the concept and practice of service first.  The
information requested is duplicative and would be better obtained via an automated system
where information could be extracted from existing data fields and query enabled features
within agency EHRs.   
 
Regards,
Andrea Buford MSW, LCSW | Addiction and Telehealth Director, Behavioral
Health
Swope Health Services - Imani House | 3950 E. 51st Street, Kansas City, MO 64130
Office: 816-599-5659 | FAX: 816-599-5936
Email: abuford@swopehealth.org | Web: www.swopehealth.org
 

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saving them. Thank you.

State of Tennessee Comments
Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data
Collection and Performance Measurement—NEW

-

Record Management
o Site ID: what does this correspond to? Will we need to provide the list of provider agencies
in the SOR network and SPARS will assign an ID for each location where services may
be provided?
o Date of Admission: Is this something that is asked at Baseline and then pre-populated at
other interview types, or do we expect the user to fill this out at each interview type?
o Was the interview conducted? = No: would all of the sections of the instrument be skipped
or only selected ones? What are the expectations for data collection when the interview is
not conducted?

-

Services Planned
o Under the Case Management Services, question 3b. is listed as "Employment Couching",
this should likely be "coaching" and seems to be a typo.
o The numbering under Treatment Services should likely start at 1. for Medication-assisted
treatment (instead of 8) in order to be consistent with the other sections on that page.
o Should this section only be asked at Baseline?

-

Behavioral Health Diagnoses
o Are we expected to collect Primary, Secondary and Tertiary diagnoses, or only one?
o Are there any rules related to the section of the diagnoses that we should be aware of?
o Is this section asked at each interview type?

-

Demographics
o Is this section asked at each interview type? If yes, would some fields be pre-populated
from baseline as they would not likely change (i.e DOB, sex, ethnicity, race,…)

-

Employment/Support Status
o Questions E12-E17: do we need to provide a Declined and Don't know option for each
question or are Declined or Don't know for the entire section?

-

Substance Use
o The entry under Prescription Opioids for "OxyContin" is misspelled as "OxycContin"

-

Family/Social Relationships
o There is no number for the question “In the past 30 days, where have you been living most
of the time?”
o Questions F18 to F26 do not have the mention of Yes, No, Declined, Don’t know. Should
we assume these are the valid response options?

-

Psychiatric Status
o Questions P4 to P11 do not have the mention of Yes, No, Declined, Don’t know. Should
we assume these are the valid responses?

-

Modified Colorado Symptom Index
o What do the numbers 1 to 9 represent? Is a scoring expected for this tool (if yes, then what
is the calculation? Why is Don’t know a 9 for example?)

-

Services Provided:
o We noticed that Recovery Support and Peer Recovery Support services are not listed here
but are part of the Planned Services section. Is this intentional?
o At which interview type is this section asked? Each Reassessment and Discharge?

-

Overall:
o What fields are required? The paper tool does not designate what fields are required.
Should we assume everything or nothing is required? Please provide guidance.
o Are there any other rules not listed on the paper form that we should be aware of?
o Is this tool to be conducted on any client receiving services with SOR funding? Does it
include Prevention, Treatment and Recovery services?

From:
To:
Subject:
Date:
Attachments:
Importance:

Janice Storey
King, Summer (SAMHSA/OPPI)
FW: URGENT - Please respond (SOR) Program Data Collection and Performance Measurement—NEW
Thursday, October 18, 2018 5:05:20 PM
image001.png
High

Summer I wanted to submit some feedback on the attachments above:
Completing the GPRA for SOR program would be very labor intensive to collect and document the data.  If the expected compliance is 80% it would be difficult to achieve.  It also adds
an additional reporting time at the 3 month period. 
The process we have now with “Medication First” allows the client to see the physician sooner rather than later and avoids having the client go through a more lengthy assessment that
contains most of the same data as the Integrated Assessment we use now. Although I can see why data is important for supporting programs, I think that the consumer impact to this
also needs to be taken into consideration.
Thanks for your consideration. 
 
 
 

Janice Storey, LCSW

Clinical Director
Tri-County Mental Health Services, Inc.
3100 NE 83rd Street, Suite 1001
Kansas City, MO  64119
816.877.0444 (direct line)
816.468.6635 (fax)
 

Building a Resilient Tri-County

 
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email in error, please notify us immediately either by replying to it or by calling:  Tri-County Mental Health Services at 816.468.0400.

 
 
Dear STR and SOR Project Directors and Staff:
 
This is in follow-up to my correspondence to you of last week, indicating the publication of a Federal Registry Notice (FRN) containing the proposed reporting guidelines for the SOR and TOR Grant
initiatives.
 
Please find attached below the proposed SOR information plans and reporting instruments that were referenced in the recent posting of the Federal Register for your review and comment.
 
I cannot emphasize too greatly how important it is for you to carefully review and comment on these reporting tools, and provide whatever recommendations that you have regarding
implementation issues. 
 
I am hopeful that with your feedback we can enter into a meaningful dialogue to maximize the usefulness of this reporting, and minimize any unnecessary reporting burden.
 

Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57-B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov.
 

Written comments should be received by December 3, 2018.
I would appreciate your copying me on any feedback that you provide in this process so that I can be fully prepared to particiapte in this dialogue.
 
Thank you and best regards,
 

Spencer Clark
 
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857 
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
 

 
 
_____________________________________________
From: King, Summer (SAMHSA/OPPI)
Sent: Tuesday, October 09, 2018 10:19 AM
To: Clark, Spencer (SAMHSA/CSAT/DPT) 
Cc: Jacobus-Kantor, Laura (SAMHSA/CBHSQ) 
Subject: RE: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a Copy of the Information Collection Plans for the SOR and TOR Grant Initiatives
 
 
 
Hi Spencer,

Attached are copies of the information plans and the instruments.  Please let me know if you need anything else.
Thanks,
Summer
 
_____________________________________________
From: Clark, Spencer (SAMHSA/CSAT/DPT)
Sent: Tuesday, October 9, 2018 10:07 AM
To: King, Summer (SAMHSA/OPPI) 
Subject: SAMHSA Internal Request for More Information on the Proposed Project and to Obtain a Copy of the Information Collection Plans for the SOR and TOR Grant Initiatives
 
 

Dear Summer:
Please provide me with a copy of the information collection plans and copies of the instruments as described below in the FRN released last week:
In compliance with Section 3506(c)(2)(A) of the Paperwork Reduction Act of 1995 concerning opportunity for public comment on proposed collections of information,
the Substance Abuse and Mental Health Services Administration (SAMHSA) will publish periodic summaries of proposed projects. To request more information on the
proposed project or to obtain a copy of the information collection plans, call the SAMHSA Reports Clearance Officer on (240) 276-1243.
Comments are invited on: (a) Whether the proposed collections of information are necessary for the proper performance of the functions of the agency, including
whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden of the proposed collection of information; (c) ways to
enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including
through the use of automated collection techniques or other forms of information technology.

Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR)
Program Data Collection and Performance Measurement—NEW
The Substance Abuse and Mental Health Services Administration's (SAMHSA) Center for Substance Abuse Treatment (CSAT) is requesting approval from the Office
of Management and Budget (OMB) for data collection activities associated with the State Opioid Response (SOR) and Tribal Opioid Response (TOR) discretionary
grant programs. Approval of this information collection will allow SAMHSA to continue to meet the Government Performance and Results Modernization Act of 2010
(GPRMA) reporting requirements that quantify the effects and accomplishments of its discretionary grant programs which are consistent with OMB guidance.
Information collected through this request will be used to monitor performance throughout the grant period.
There will be up to 359 award recipients (states, territories, and tribal entities) in these grant programs. Grantee-level data will include information related to naloxone
purchases and distribution. This grantee-level information will be collected quarterly.
All funded states/territories and tribal entities will also be required to collect and report client-level data on individuals who are receiving opioid treatment services to
ensure program goals and objectives are being met. Client-level data will include information such as: Demographic information, services planned/received, mental
health/substance use disorder diagnoses, medical status, employment status, substance use, legal status, and psychiatric status/symptoms. Client-level data will be
collected at intake/baseline, three months post intake, six months post intake, and at discharge.
CSAT anticipates that the time required to collect and report the grantee-level data is approximately 10 minutes per response, and the time required to collect and
report the client-level data is approximately 47 minutes per response. CSAT's estimate of the burden associated with the client-level instrument includes an adjustment
for data elements that are currently being collected by entities that are likely to be funded by the SOR/TOR grant programs. Start Printed Page 50117
Table 1—Estimate of Annualized Hour Burden for SOR/TOR Grantees
SAMHSA data Collection

Number of
respondents

Responses per
respondent

Total number of
responses

Burden hours per
response

Total burden Hours

Grantee-Level Instrument

359

4

1,436

.17

244

Client Level Instrument: Baseline Interview

165,000

1

165,000

.78

128,700

Client-Level Instrument: Follow-up
Interview 1

132,000

2

264,000

.78

205,920

Client-Level Instrument: Discharge
Interview 2

85,800

1

85,800

.78

66,924

CSAT Total

165,359

516,236

401,788

Notes:
1

 It is estimated that 80% of baseline clients will complete the three month and six month follow-up interviews.

2

 It is estimated that 52% of baseline clients will complete this interview.

Send comments to Summer King, SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E57-B, Rockville, Maryland 20857, OR email a copy to
summer.king@samhsa.hhs.gov. Written comments should be received by December 3, 2018.
Start Signature
Summer King,
Statistician.
End Signature End Preamble
[FR Doc. 2018-21576 Filed 10-3-18; 8:45 am]
BILLING CODE 4162-20-P
 
 
Thank you and best regards,
 

Spencer Clark
 
Spencer Clark, MSW, LMSW, ACSW,
Public Health Advisor/
Government Project Officer,
Opioid State Targeted Response, State Opioid Response, and MAT-PDOA Grant Initiatives,
Division of Pharmacologic Therapies,
Center for Substance Abuse Treatment,
Substance Abuse and Mental Health Services Administration,
Department of Health and Human Services,
5600 Fishers Lane, Office 13E25C,
Rockville, MD 20857 
Email: Spencer.Clark@samhsa.hhs.gov
Personal Direct Telephone: (240) 276-1027
Main Office Telephone: (240) 276-2700
 
<< OLE Object: Picture (Device Independent Bitmap) >>
 
 

 

From:
To:
Subject:
Date:
Attachments:

John Pruett
King, Summer (SAMHSA/OPPI)
FW: SOR Data Collection
Friday, October 19, 2018 11:47:58 AM
image001.png

Sending again kicked back
 
From: John Pruett [mailto:jpruett@turningpointrc.org]
Sent: Friday, October 19, 2018 10:44 AM
To: 'summer.king@samhsa.hhs.gov.' 
Subject: SOR Data Collection
 
Ms. King,
 
In reviewing the documents I feel they are excessive and will put an extra burden on our agency.
 
Whether large or small, this will create problems for agencies due to the excessive amount of data
and the time needed to retrieve and record the data.  Not all agencies can devote as much time to
this process as would be required to still meet all the other requirements needed both
administratively and clinically for other functions.
 

John Pruett LCSW
Clinical Director
 

 
146 Communications Drive
Hannibal, Missouri 63401
 
Phone:    (573) 248-1196
Fax:        (573) 231-0982
Email:     jpruett@turningpointrc.org
Website:  www.turningpointrc.org
___________________________________________
CONFIDENTIALITY STATEMENT: The information contained in this e-mail message is intended only for the designated recipients
named above. The documents accompanying this transmission may contain information that is protected under the HIPAA
confidentiality act. If the reader of this message is not the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, distribution or copying of this message is strictly prohibited. If you have
received this e-mail in error, please notify us via e-mail or call (573) 248-1196 and delete the original message. Thank you for your
cooperation

 
 

From:
To:
Cc:
Subject:
Date:

Catie Franklin
King, Summer (SAMHSA/OPPI)
"Jennifer Wilson"; "John Pruett"
URGENT - Please respond (SOR) Program Data Collection and Performance Measurement-NEW
Monday, October 22, 2018 12:12:20 PM

Good morning.  I am the Program Director for the STR program we have here at Turning Point
Recovery Centers in Hannibal, MO and I interact with STR consumers on a daily basis.  I am writing in
response to the Data Collection email that was sent out last week.  My concern is that it appears to
be a very long and time consuming process and that at this time, it would take away from the main
focus of individualized consumer care and become more about completing paperwork, specifically
with the 80% required completion.  Thank you for your time.     
 
Catie Whitaker, BS CRADC/SQP/PD
CSTAR GP Program Director
Turning Point Recovery Centers
146 Communications Drive
Hannibal, MO 63401
(573) 248-1196
 

From:
To:
Cc:
Subject:
Date:
Attachments:

Porter, Rebecca
King, Summer (SAMHSA/OPPI)
Clark, Spencer (SAMHSA/CSAT/DPT)
RE: Proposed Project: State Opioid Response (SOR) and Tribal Opioid Response (TOR) Program Data Collection
and Performance Measurement—NEW
Wednesday, November 28, 2018 8:40:16 AM
Broad cross program outcome tool 6.1.18.docx
ED Data Intake Form 8.10.18.pdf
Employment Services Reporting Requirements.docx

Good Morning Summer,
 
I am writing from Vermont in response to the Federal request for comments on the proposed SOR
data collection tools and performance measurement plan. Attached please find the data collection
tools referenced in my comments that Vermont is currently using. WE have started multiple
initiatives with STR funding that will be continued with SOR funding, which is why we have so many
pieces in place already.
 

RESPONSE
 
Vermont Is a Medicaid expansion state with a robust system of healthcare including services for
Opioid Use Disorders (OUD). Vermont has an innovative and effective statewide hub and spoke model
of Medication Assisted Treatment (MAT) programs. The existing MAT programs and other OUD
treatment services are Vermont Medicaid and Block Grant funded services and will remain funded in
that way so Vermont is not utilizing SOR funding to pay specifically for MAT treatment.  Instead, the
Vermont SOR funds are used for activities and programming which augment supports for individuals
with OUD engaging in MAT services and for reducing barriers for individuals with OUD to access MAT
and evidence-based, non-clinical recovery support services. For instance, Vermont SOR funding will be
used to pay for Employment Consultants to work with people in varying stages of engagement in
treatment and recovery in existing treatment clinics and recovery centers. As the services we are
funding through SOR are not treatment and are provided by non-clinicians, it would be inappropriate
for these service providers to ask the full range of clinical questions included in the GPRA tool because
these providers, for example, the Employment Consultants, lack the clinical expertise required and to
do such is outside their scope of work. Vermont is concerned about the privacy of individuals
receiving these services should the GPRA data tool be utilized and that data collected.  Therefore,
instead of utilizing the proposed tools, Vermont advocates that utilizing the tools Vermont is currently
using for the Recovery support related services would lead to the most effective and appropriate data
collection for SOR reporting.
 
For Employment Consultants, this tool is the Employment Services Reporting Requirements. This tool
includes the 10 questions that comprise the Brief Assessment of Recovery Capital Tool (BARC-10) and
has and will continue to provide Vermont with the data necessary and appropriate to capture the
work funded through SOR and to make data-driven decisions around adjustments to continuously
improve the programming funded by SOR . See attached tool for more details.
 
For Peer Recovery Coach activities under this grant, an ED data intake form (see attached) and a
broad cross-program outcome tool (see attached) is being used that includes the BARC-10 questions

as well as quality of life ratings questions about the past two weeks and questions about the last
thirty days in relation to the individual’s:
Recovery Center use;
Engagement in substance use treatment services;
Interaction with police/arrest/incarceration/probation;
Substance use – amount/frequency/types of substances used;
Smoking cessation referral questions;
Mental health symptoms including suicide attempts;
Transportation;
Childcare;
Housing;
Employment; and
Education
 
Vermont will also be using SOR funding to purchase and distribute naloxone and feels the proposed
SOR/ TOR Program Instrument will match nicely with Vermont’s Naloxone-related SOR-funded
activities.
 
Best Regards,
Rebecca

 
 

From:
To:
Cc:
Subject:
Date:

Mayfield, Jim (DSHS/RDA)
King, Summer (SAMHSA/OPPI)
Speaker, Lyz (DSHS/RDA)
State Opioid Response (SOR) Program Data Collection and Performance Measurement
Friday, November 30, 2018 8:56:54 PM

Summer King
SAMHSA
Reports Clearance Officer
5600 Fishers Lane, Room 15E57-B
Rockville, Maryland 20857
Via email: summer.king@samhsa.hhs.gov
 
Dear Ms. King:
 
I am filing these comments in regards to the proposed protocols for the State Opioid Response
(SOR) Program Data Collection and Performance Measurement, document citation 83 FR
50116, document number 2018-21576.
 
First, I’d like to address something I learned on the November 30, 2018 SAMHSA Webinar.
Funding Opportunity Announcement (FOA) No. TI-18-015 did not specify requirements for
uploading data required for SAMHSA’s Performance Accountability and Reporting System
(SPARS). Based on my experience with other grants and a phone conversation months ago
with Deepa, our SOR data collection plan assumed that our sub grantees would have access to
SPARS and use that application to enter data directly. We were told today that only grantees
will have access to SPARS. This represents a considerable addition to an already burdensome
data collection environment. The solutions—an alternative web interface or batch up-load
processes—will require a considerable amount effort and time for grantees and their
contractors to stand up. At a minimum a substantial grace period will be necessary even if an
acceptable solution is found.
 
Please consider the following additional comments:
 
(a) Whether the proposed collections of information are necessary for the proper
performance of the functions of the agency, including whether the information shall have
practical utility.
 
It is unclear how these lengthy instruments are necessary for the proper performance
of your agency or to the performance of grantees. Because data are only collected for
individuals receiving services, it is not possible to use these data to make casual
inferences about program effectiveness; even worse, simple pre-post comparisons of
outcomes—a common “analysis” using these data—are particularly misleading without
the context of an adequate comparison group.
 
While some information is useful from a program monitoring standpoint—e.g.
enrollment and discharge dates, discharge reason, treatment and services, past-30-day
substance use, basic socio-economic information, and demographics—there is little
value in systematically collecting all measures in the proposed instruments. In the

context of SOR, there is little value to many of these measures, for example: life-time
hospitalizations, non-SUD related medical problems, the distinction between years of
technical or other education, the detailed questions about employment and income,
the very detailed questions about criminal involvement, etc. If there is a research
justification for these questions, they should be asked in the context of a specific
project, not as a general, systematic reporting requirement for a project of this scale.
 
(b) ‘Accuracy of the agency’s estimate of the burden of the proposed collection of
information;
 
The .78 hours per response is a reasonable estimate of the baseline interview, but it is
a considerable underestimate of the follow-up and (non-administrative) discharge
surveys. These surveys require time for scheduling, notifications, tracking down clients,
repeated attempts to contact clients, etc. The populations receiving services under
SOR will be more transient than patients in other interventions, which will compound
these tracking and scheduling issues. This burden estimate needs considerable
revision. 
 
(c) Ways to enhance the quality, utility, and clarity of the information to be collected; and
 
A considerably shorter and project-focused instrument would significantly improve
data quality and completeness. Also, it is unclear what kind of documentation or
training are available for these new instruments. I cannot ask providers to field these
instruments without sufficient documentation or training.
(d) Ways to minimize the burden of the collection of information on respondents, including
through the use of automated collection techniques or other forms of information technology.
 
While a technical solution seems attractive, the burden of data collection is primarily a
matter of human factors: time, training, staff turnover, quality of interviewer, patient
participation, the treatment environment and workflow, and invasiveness of the
questions, etc. While improvements in the data entry application would certainly be
helpful, these human factors and the length of the instruments are the greater
challenges. Even in data collection efforts that incorporated GPRA surveys in tablet
applications, most providers conduct surveys on paper and enter data later. That said,
if sub grantees are not allowed to access the SPARS system, then an alternative webbased data entry system that supports batch uploads to SPARS would be very valuable.
 
Given the scale of the SOR grant, the administrative costs associated with the
proposed data collection poses a substantial burden. I recommend the following:
 
1. Ensure there is adequate training and documentation for the new instruments,
including Q-by-Qs, train-the-trainer, and appropriate training support for subgrantees.
 
2. Use a significantly shorter survey focusing on the measures most relevant to
SOR.
 
3. Eliminate the 3- or the 6-month follow-up survey.
 
4. Require only “administrative” discharges.

 
5. Permit sampling instead of requiring surveys for every participant.
 
6. Create survey modules that can be used to customize the survey based on the
intervention: e.g. a low-barrier clinic established in an urban jail setting would
focus on criminal justice outcomes, while a nurse care manager model in rural
medical clinics could focus on employment, health and child welfare outcomes.
 
7. Develop a web-based interface for sub grantees to enter data and support
batch uploads to SPARS. States should not have to develop this capacity
independently.
 
8. Identity management is going to be very challenging in SOR environment. For
example, a non-profit agency in Spokane providing recovery support services
and tracking clients on a spread sheet, will not know if a new client received
treatment at a SOR-funded jail in Seattle the month before. This identity
management challenge must be confronted if SAMHSA expects grantees to
assign unique IDs to all SOR-funded clients.
 
Thank you for taking the time to consider my comments.
 
Sincerely,
Jim Mayfield
 
JIM MAYFIELD  /  SENIOR RESEARCH SCIENTIST  /  Research and Data Analysis Division
Facilities, Finance & Analytics
Washington State Department of Social and Health Services
(Office) 360-902-0764  /  (Cell) 360-534-0316  / jim.mayfield@dshs.wa.gov

Transforming Lives
 

From:
To:
Cc:
Subject:
Date:
Attachments:

Michelle Jenson
King, Summer (SAMHSA/OPPI)
Brenda Ahlemann (bahlemann@utah.gov)
Federal Register--SOR Program Data Collection and Performance Measurement
Wednesday, October 17, 2018 5:42:19 PM
image002.png

Ms. King,
 
I would like to take this opportunity to respond to the Federal Register publication related to SOR
program data collection.  We were invited to comment regarding, “Whether the proposed
collections of information are necessary for the proper performance of the functions of the agency,
including whether the information shall have practical utility.”  My response to that is that the
proposed utilization of GPRA data collection for this program has absolutely zero practical utility and
instead creates HUGE barriers to actual clients receiving services from the program.  Clients just
want to get help!  They don’t want to have to answer dozens of questions just to get in the door. 
Especially for clients looking for MAT assistance (which is what this program is focusing on), at
“intake” they are not in a good state of mind or physically able to sit there for that long to answer all
of these questions.  Our organization has participated in at least 2 other federal grants from SAMHSA
that required the use of the GPRA; in neither of those programs did we as a service provider or the
clients ever find any utility with the information. 
 
Furthermore, I believe that the estimate of 47 minutes per response for client-level data is
significantly underestimated.  First of all, a population seeking MAT resources is usually actively using
or may be going through withdrawals.  This will significantly slow down the interview process and
may even require that the data be collected in multiple visits.  Secondly, this estimate does not
include the provider time that must be spent in tracking down the clients for any follow-up
administrations.  In one of our programs, we estimated that we spent on average a total of 2 hours
of staff time for tracking down clients per follow-up.
 
We sincerely hope that you will take into consideration the barrier to care that this level of data
collection creates for the individuals trying to access care.  We know that government want to be
accountable, and we already collect TEDS data on all of these individuals, but we should not be
sacrificing client access to services to meet that accountability requirement.
 
Sincerely,
 
Michelle Jenson
 

Michelle Jenson | Director of Compliance and Quality
237 26th Street, Ogden UT 84401
Phone    801-778-6888
Fax         801-625-3847

michellej@weberhs.org
www.weberhs.org
 

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DIVISION OF CARE AND TREATMENT SERVICES
1 WEST WILSON STREET
PO BOX 7851
MADISON WI 53707-7851

Scott Walker
Governor

Linda Seemeyer
Secretary

State of Wisconsin
Department of Health Services

Telephone: 608-266-2717
Fax: 608-266-2579
TTY: 711 or 800-947-3529

Summer King
SAMHSA Reports Clearance Officer
5600 Fishers Lane, Room 15E57-B
Rockville, MD 20857
Summer.king@samhsa.hhs.gov

Ms. King,
Thank you for the opportunity to comment on the SAMHSA data reporting proposal for the State Opioid
Response (SOR) Grant. In the following document and attachment A, please find my feedback on the
proposed SOR Grant data collection requirements. High level comments can be found below. Attached
you will also find more specific comments regarding the proposed GPRA client-level data collection tool.
The specific GPRA client level tool comments were produced by the University of Wisconsin Population
Health Institute, our state agency that has done GPRA Reporting for the MAT PDOA grants. Their
expertise has helped us more fully understand the proposed burden for the new reporting outlined in the
current SAMHSA proposal for the SOR Grant.

High-Level Data Collection Comments:
1. Data Collection for Outcomes Management. Wisconsin does not dispute the need for
appropriate outcome indicator data collection. Wisconsin has found that assuring an appropriate
level of accountability using specific outcomes indicators that are seen as valuable by funders,
clients and providers can add a critical component to achieving success. We found that in MAT
PDOA grant the level of evaluation of outcome indicators allowed us to have a feedback loop to
our providers which spurred progress towards more effective and efficient programs.
2. Data Collection Allocation (2%). As noted above, Wisconsin sees considerable value in data
collection and evaluation. However, we believe that two percent of the total grant is a very small
amount for the scope of data that is being required for the SOR Grant. In comparison, for the
MAT- PDOA grant, where a GPRA was required at three data points: at intake, 6 months and
discharge, that grant allowed us to use 16% of the total award for data collection and performance
management. Even with that percentage, it was difficult to attain an 80% follow-up rate. When
we have asked about using additional funding for these duties in SOR which now includes four
GPRA data points (intake, 3 months, 6 months and discharge), it was pointed out we could also
use the 5% that states can use for state related grant oversight. However, the administration of
contracts, the requirement that we fund a State Opioid Initiatives Director, and the fiscal
management required of such a large grant, also must be recognized and paid for within that 5%
for state operations. As a result, that truly only leaves 2% for data collection activities which will
not fund the true cost of the data collection burden outlined in the SAMHSA proposed SOR Data
Collection proposal.
3. Additional Data Burden Not Recognized in SAMHSA Documents. The SAMHSA Supporting
Document, “State Opioid Response (SOR) and Tribal Opioid Response (TOR), Program Data
Collection and Performance Measurement, A.3” document states, “The SOR/TOR data collection
will not interfere with ongoing program operations that facilitate information collection at each
site as state/territories and tribal entity are already using collecting and reporting program data as
a component of other SAMHSA grants.” Wisconsin does not agree with this statement. The new
GPRA data elements are not collected for our existing Substance Abuse Prevention Treatment
www.dhs.wisconsin.gov

Block Grant funding. The proposed GPRA was substantially changed from that used for the MAT
PDOA grant which also allowed additional resources to be used for data collection and evaluation
activities.
4. Time to complete the GPRA. For the MAT-PDOA grant, we estimated a time of about 45
minutes per interview, as well as 20 minutes for data entry. In your estimation only 47 minutes
was given for both the interview and the data entry. This would increase the total burden hours
from 401,788 to 555,984, which again is a very large amount of hours for 2% data collection
allocation. As an example, if we served 1,000 people and all were provided all four interviews
that would total 80 minutes per person for just the data entry, or 80,000 total hours for 1,000
people served. If we estimate an hourly rate of $30/hr. for data entry with fringe costs, that would
total $2.4 million out of the Wisconsin allocation of $11.9 Million for SOR or 20% of the grant
costs. That is ten times what is being proposed at 2% for data entry alone.
5. Client Services to be Tracked. Guidance is needed on how to record client services in the
proposed GPRA system. For example, what if a client is assessed using SOR grant funding, the
GPRA is completed and they begin treatment using SOR funding. Then the client transitions onto
partial insurance funded treatment services but SOR is continued for those services insurance will
not cover such as case management, and recovery support. Would the GPRA continue to record
the non-funded Substance Use Disorder treatment services?
6. System Implementation. As noted in item 3 above, the proposed GPRA for SOR is a new
instrument. An existing electronic instrument does not exist. In the first year of the State Targeted
Response to the Opioid Crisis Grant, we served 900 people. With the additional SOR funding, we
believe the number will be considerably higher. Time will be needed to give providers sufficient
time to implement the GPRA in their local EHRs and clinical processes. A site-based electronic
data collection system would reduce the data reporting burden. It is difficult to see how states will
be able to implement this within the first grant year.
Thank you for your consideration of my feedback.
Sincerely,

Joyce Allen
Director, Bureau of Prevention Treatment and Recovery,
Division of Care and Treatment Services,
WI Department of Health Services
1 W. Wilson St., Room 850
Madison, WI 53707
Joyce.Allen@wisconsin.gov
608-266-1351

cc: Spencer Clark

From:
To:
Cc:
Subject:
Date:

Morrison, Beth J
King, Summer (SAMHSA/OPPI)
Thierry, Kim (SAMHSA)
State Opioid Response (SOR) program data collection and performance measurement - state comments - WV
Tuesday, December 4, 2018 8:10:11 AM

Summer King
SAMHSA
Reports Clearance Officer
5600 Fishers Lane, Room 15E57-B
Rockville, Maryland 20857
Via email: summer.king@samhsa.hhs.gov
 
 
Dear Ms. King:
 
The West Virginia Bureau for Behavioral Health is filing this comment in regards to the
proposed client level protocol for the State Opioid Response (SOR) Program Data
Collection and
Performance Measurement, document citation 83 FR 50116, document number 2018-21576,
as referenced in Funding Opportunity Announcement (FOA) No. TI-18-015. 
 
As with any data tool it is important that there be a balance between the amount of data
collected and the burden on the participant.  As you increase the burden, you decrease the
accuracy of the data as patients get fatigued and often do not answer questions truthfully or
refuse to answer.  This tool is 32 pages long for the baseline.  It is the opinion of the clinical
and data team from WV’s State Targeted Response (STR) funded MAT initiative that it is far
too long.
 
Specific recommendations include:
 
Medical Status section:
Eliminate questions: M1 and M1b.
People are not going to remember how many times they have been hospitalized so this
information is not going to be accurate.
Eliminate question M8
 
Employment/support status section:
E1 – I think phrasing the question this way compared to how is was in the GPRA will get less
accurate results.  People will be unclear, do I count per-school, kindergarten, what if they did
not go to either of those?  They also will not accurately recall months.
E5 – do you have an automobile available is not a good was to phrase the question.  Most
people who borrow a vehicle sometimes have it available and sometimes do not and it is
inconsistent.  Do you own an automobile would be a better question. Or does someone in your
household own an automobile.
E11 – how much money have you earned from the follow sources – this level of detail is
burdensome
E19 and E20 should be combined and E21 eliminated.
 
Substance Use chart:

It is very important to capture misuse of prescription medications or “street use”,  As in the
individual is using a prescription medication but it is not prescribed to them.  It is not clear
how it would be differentiated is the person is being prescribed a medication (say
benzodiazepines or opioids)  or using medications not prescribed to them.
 
The additional questions D26, D28, D27, D29 are burdensome and will not yield meaningful
data.
 
Legal status:
L18, L19, L20 should be added to the options listed in the chart regarding “how many times
have you been arrested and charged with the following”
L27 – people WILL NOT answer this question generally and it is not a good question to ask at
an initial baseline before you have earned an individual’s trust.
L28 and L29 – remove.  People’s opinion about their legal situation or substance abuse
severity at baseline is not an important data point to collect at the cost of making this
assessment so long.
 
Family Social/relationships:
F30, F31 – redundant and should be removed.  This will be captured in the chart about serious
problems getting along with people
 
If the modified Colorado Symptom Index is being administered then the previous symptom
chart can be eliminated, as they are redundant:
P4, P5, P6, P7, P8, P9, P10
 
SOR/TOR specific questions:
1. This is repetitive as incarceration in the past 30 days have already been asked about
 
Any effort to reduce the length of this tool would be of benefit.  If you have questions or
need additional information, please contact me via email at Beth.J.Morrison@wv.gov.
 
Kind regards,
 
Beth Morrison, Program Director
Programs Section
Bureau for Behavioral Health
350 Capitol Street, Room 350
Charleston, West Virginia 25301
Ph:  304-356-4976
Cell:  304-550-8450
Email:  Beth.J.Morrison@wv.gov
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