Behavioral Health Services Act Integrated Plan

Lindsey Yourman Apr 8 2026 at 4:18PM on page 486

Suggestion

Disparities in older adult behavioral health are documented throughout this draft across many domains (DMC-ODS, SMHS, FUM, homeless service access, etc); and community engagement has extensively detailed how important it is to not only continue those services that have been provided in the past but to augment them. (see Caregiver Coalition provides detailed examples of how and why, p.292-293 and Affordable and supportive housing is needed for older adults with complex BH needs p.305-306, etc.)
YET
there is not a single dollar in the budget that I can find that is specifically allotted to older adults (All 21 year old plus are effectively grouped together). I highly recommend that we be intentional about budgeting and planning to serve the unique needs of older adults, which is the fastest growing demographic in San Diego and fastest growing segment of our homeless population. It will be much more efficient to do this proactively than reactively.

Lindsey Yourman Apr 8 2026 at 4:08PM on page 164

Suggestion

Plan states that engagement with older adult stakeholders “will be utilized to develop the services” though there is no specific Housing Intervention programming for older adults

Lindsey Yourman Apr 8 2026 at 4:08PM on page 152

Suggestion

This is one of the most substantive older adult-specific passages as it describes incorporating older adult needs into FSP development through data analysis, stakeholder engagement, and FSP service design with caregiver support.
- This is descriptive of a planning process but it doesn’t specify any services, dollars, or targets for older adults within FSP. My patients have previously depended on many of these service providers (the community engagement and input sections talking about these various programs, which can be life-altering and life-saving, are important)

Lindsey Yourman Apr 8 2026 at 4:04PM on page 43

Suggestion

Follow-up After ED Visit for Mental Illness (FUM)
Section Untreated Behavioral Health Conditions, Disparities Analysis (p. 42-43) and Planned Actions (p.43)
- Follow-up remains lowest among adults 65+, but older adults are not named as a targeted subgroup in any of the planned actions

Lindsey Yourman Apr 8 2026 at 4:04PM on page 27

Question

- Access to Care: 65+ among lower rates of access to homeless services.
- Yet Cross Measures and planned actions do not specify age-specific housing or homeless services intervention targeting older adults 65+ (including no plan for how shelters can serve older adult experiencing homelessness who needs help with activities with daily living; which shelters in San Diego County can serve older adults experiencing homelessness who need help with activities of daily living?)

Lindsey Yourman Apr 8 2026 at 4:01PM on page 25

Suggestion

Section Access to Care, Disparities, p 24-25
- lower penetration rates among older adults receiving AOD treatment compared to different subgroups but no specific action targeting older adults in the IET-INI response

Lindsey Yourman Apr 8 2026 at 4:01PM on page 25

Suggestion

DMC-ODS (Substance Use)
Section Access to Care, Disparities, p 24-25
- older adults named as disparity population, but the investments are framed as addressing the entire population without any specifically designed or targeted interventions for adults 60+

Lindsey Yourman Apr 8 2026 at 4:00PM on page 21

Suggestion

Specialty Mental Health Services
Section Access to Care, Disparities, p 21-25
- older adults 69+ named as a subgroup with lower access, but there is no specific intervention named for adults 69+ in the Specialty Mental Health Services response

Lindsey Yourman Apr 8 2026 at 3:58PM on page 1

Suggestion

BIG PICTURE FEEDBACK:
Older adults are referenced across multiple measure domains, community engagement summaries, and program planning sections as a priority group experiencing disparities. However, older adults receive comparatively little to no (unless I missed something) targeted intervention specificity relative to youth and racial/ethnic subgroups.

STRENGTHS of current plan draft:
- The current draft accurately reflects older adults (although variably defined, 60+, 65+, 69+) as a disparity subgroup across multiple measure domains (DMC-ODS, SMHS, FUM, homeless service access, etc)
- references older adult stakeholder engagement in planning processes (e.g., Housing Interventions), common care challenges that I see with my patients (e.g., digital divide, caregiver burden, stigma, etc.), and aspirational goals around housing and service providers

GAPS in current plan draft:
- current draft does not disaggregate budget or enrollment targets for adults vs. older adults in any place that I can find (e.g. age 21 years old to 100 years old are lumped into one category)
- I could not find any detailed operations regarding the aspirational goals, e.g., I could not find a single funded intervention or specific program name in the plan that specifically targets 60+
- social isolation in older adults is a significant risk factor for serious mental illness and suicide but I do not see any specific funded program response in the formal plan sections
- the need for caregiver support for older adults was expressed by many community members and organizations but does not appear as a funded initiative and I no longer see any of the critical organizations who provide this named in the document

Jennifer Kennedy Apr 8 2026 at 10:23AM on page 42

Question

There is a gap in reporting when we look at females 25 - 34. Of these females who are in child-bearing age, how many are parents/caregivers? How is the county addressing needs for people in the context of family and community? Do assessment and intake processes determine if individuals are caregivers/parents and if their children ages 0 - 5, in particular, need supports and services as well?

Jennifer Kennedy Apr 8 2026 at 10:18AM on page 40

Suggestion

With certain populations experiencing higher risks like children identifying as Black or Hispanic 0 - 5 and children under 2 years, proposed efforts focusing on MCRT School Pilot Program TK - 12 does not adequate address need in the 0 - 3 and under 2 populations. At the least, programming needs to expand to include early child education, early child care, and preschools.

Jennifer Kennedy Apr 8 2026 at 10:06AM on page 28

Question

The county is silent about parents/caregivers with infants and children 0 - 18 experiencing homelessness. County needs to expand beyond individuals or PEH and include reporting for families experiencing homelessness. Where does county report on parents/caregivers and families experiencing homelessness and what services, supports, and facilities are available to them?

Jennifer Kennedy Apr 8 2026 at 9:59AM on page 25

Question

How will county specifically address lower rates of Non SMHS for age groups 3 - 11 and 18 - 20?

Jennifer Kennedy Apr 8 2026 at 9:56AM on page 24

Question

How will County specifically address lower penetration rates for SMHS among infants and children 0 - 11 and their caregivers?

Jennifer Kennedy Apr 8 2026 at 9:47AM on page 17

Suggestion

Please spell out acronyms

Andy Apr 1 2026 at 7:52AM on page 1

First, the final plan would be stronger if it clearly showed how community input shaped the document. A simple summary of major themes heard, what changed in response, and what did not change (with rationale) would help demonstrate that the Community Planning Process was meaningful rather than procedural.

Second, I encourage the County to specify a limited set of measurable outcomes for each major priority area, not only activities or service volumes. Public reporting over time should focus on whether people are actually doing better and gaining timely access to appropriate care, with results stratified where possible by age, race/ethnicity, language, geography, and other populations experiencing disparities. Client perspective should be included through self-report measures that are recovery-based.

Third, I hope the County will strengthen the role of lived-experience voices not only during planning, but during implementation and monitoring. Clients, family members, and community members with direct experience should have an ongoing role in reviewing progress and informing course correction.

Finally, I encourage the County to emphasize continuity across systems and transition points. Many of the most important gaps occur not within a single program, but between crisis response, outpatient care, housing supports, SUD treatment, justice-related services, and follow-up after acute episodes. The plan will be most meaningful if it can show how those handoffs will improve over time.

Thank you for the opportunity to comment.

Robin Sales 1 Mar 30 2026 at 10:22AM on page 11

Suggestion

The poor quality of behavioral health services in the County jails has been documented by the Grand Jury, the State legislature audit, the League of Women Voters, and many other entities. Deaths have occurred in custody as a result of the SDSO policies and procedures and the county has paid out upwards of $100 million in lawsuits in a 10 year period. The State must consider the quality of services as the incarcerated person re-enters the community as they likely will be more acute.

Robin Sales Mar 30 2026 at 10:01AM on page 10

Suggestion

There is a great need in this county to track individuals throughout the continuum of care, especially those individuals cycling in and out of county jails and juvenile detention. There currently is no way to clearly know if any interventions have been successful

Jonathan Mar 28 2026 at 4:18PM on page 181

Question

How is "improved equity" measured? Is race a factor? If so, which groups benefit from improved "equity" and at which group's expense is "improved equity" achieved?

Jonathan Mar 28 2026 at 4:05PM on page 176

Question

A workforce can only become "more diverse" by becoming less White and more Nonwhite.

How will the county achieve a "more diverse" workforce without actively discriminating against White people?

Jonathan Mar 28 2026 at 3:40PM on page 139

Question

"Counties should incorporate efforts to increase the racial, ethnic, and geographic diversity of the behavioral health workforce..."

When a "diverse" individual is placed into a role because they are "diverse," they are replacing a "non-diverse" individual because they are White.

Can someone explain how that is not a deliberate effort to achieve White erasure?

Jonathan Mar 28 2026 at 3:30PM on page 138

Suggestion

"Diversity" and "diversification" are synonymous with White erasure. County funds should not be used to disadvantage one specific demographic, including the White community. There are no legitimate barriers to employment for any group that must be overcome by giving special treatment to Nonwhites in the hiring and promotions processes. Claiming to be Equal Opportunity and "against racial discrimination" while simultaneously pursuing "diversification" is a contradiction. These programs that discriminate against the White population of San Diego County should be discontinued. Nobody deserves a job more than any other just because of the way they were born.

Jonathan Mar 28 2026 at 3:16PM on page 137

Suggestion

"Diverse" means Nonwhite, since White people are the only group that cannot be considered "diverse." Therefore this reimbursement specifically discriminates against, and disadvantages, the White population in this - in the document's own words - "already diverse" (AKA, already sufficiently Nonwhite) workforce. That is not a method of ensuring equal opportunity and the policy should be struck from policy going forward. Everyone should be provided equal opportunities, not just Nonwhite people - especially if they are already well-represented, as is indicated in the document.

Aaron Meyer 1 Mar 27 2026 at 3:18PM on page 187

Question

Behavioral Health Services requests transferring 7% from Full-Service Partnerships and 3% from Housing Interventions into Behavioral Health Services and Supports to address “urgent system-level needs.” This equates to $27,460,897.

1. How did BHS determine that services provided to individuals presumptively eligible for a full-service partnership (currently experiencing unsheltered homelessness; transitioning from a locked setting; frequent involuntary holds, transitioning after six months or more in state prison or county jail) are less urgent than programs subsidized by Behavioral Health Services and Supports (BHSS)?

2. How did BHS determine that housing interventions for those chronically homeless are less urgent than programs subsidized by BHSS?

3. How many referrals were received for full-service partnership programs that did not lead to linkage to an FSP program?

4. How many individuals have been denied for FSP programs because they were determined to have a primary or standalone severe substance use disorder?

5. How many individuals were disenrolled because of lack of engagement? How many of these individuals were previously on conservatorship?

6. What are the steps required for the State to approve this transfer request?

Aaron Meyer 1 Mar 27 2026 at 3:15PM on page 494

Question

Can you define what services are provided in this category?

Aaron Meyer 1 Mar 27 2026 at 3:14PM on page 150

Question

The FY 26-29 Integrated Plan for San Diego County, indicates that full-service partnerships for individuals with primary substance use disorders will be created (page 150). However, $0 is allocated to this population (page 494). FSPs for primary substance use disorders is optional and separate from the required assertive field-based initiation of SUD services.

Can you clarify the discrepancy?

Aaron Meyer 1 Mar 27 2026 at 3:13PM on page 494

Question

During FY 23-24 in San Diego County, 3,278 adults (page 191) and 7,575 children (page 180) were served in full-service partnerships in San Diego County. This is a total of 10,853 individuals.

According to the FY 26-29 Integrated Plan for San Diego County, a total of 1,255 children/TAY and 6,325 adults/older adults (page 494) are projected to be served in full-service partnership programs in Year 1 (FY 26-27). This is a total of 7,580 individuals.

Interestingly, according to the State of California Accountability website, 4,788 people are receiving full-service partnership behavioral health services (as of February 26, 2026).

1. Why is there such a difference between the yearly figures of 23-24 and 26-27? What population does the State of California Accountability website measure?

2. According to the Integrated Plan equation used to calculate the projected number of individuals served in FSP programs, how many individuals are currently served in FSP programs?

Aaron Meyer 1 Mar 27 2026 at 3:11PM on page 107

Question

According to the FY 25-26 Mental Health Services Act Annual Update, Therapeutic Behavioral Services (TBS), Incredible Years, and Family Therapy are classified as full-service partnership programs (page 42).

According to the FY 26-29 Integrated Plan for San Diego County, Therapeutic Behavioral Services (TBS) (page 97) and Incredible Years (107) are classified as non-full-service partnership programs. Family Therapy is no longer listed at all as a supported program.

1. What led to the category change of TBS and Incredible Years in FY 26-29?

2. Why was Family Therapy classified as a full-service partnership program in FY 25-26?

June Dudas Mar 17 2026 at 3:13PM on page 304

Suggestion

It should also be easier for families to seek out interventions on behalf of their loved ones. The current process is a maze. The crisis line is helpful but needs to be augmented by public education and outreach about how to get help. A roadmap of services available with phone numbers and websites would be very helpful. Otherwise you are left to just start knocking on doors and hoping you are finding the right ones. Sometimes you are told who to contact instead, in my experience, and other times you are simply told just to call 911 when the situation escalates again.

June Dudas Mar 17 2026 at 3:08PM on page 302

Suggestion

Agree 100%. My brother, who suffered from schizophrenia and bipolar disorder, was able to live in a section 8 apartment and on his own for nearly 20 years because of the nearly daily day treatment activities he participated in through Bayview Clubhouse and others. These were literally a lifeline for him. They would engage him, give him purpose and a sense of value. The Therapeutic Recreation program through the City's Park and Rec Department was also very helpful by offering social activities like dances and sports. Collectively these also offer another way to monitor how the client is doing and to trigger early intervention when warning signs are seen.

June Dudas Mar 17 2026 at 3:03PM on page 299

Suggestion

We need to move past the notion that all mandated treatment is of the ilk of Hollywood's One Flew Over the Cuckoos Nest. The most compassionate thing we can do for some severely ill people is to take care of them when they are incapable of seeing how sick they truly are. My mother and my brother's lives were saved because of mandated treatment that neither sought out on their own.

June Dudas Mar 17 2026 at 3:00PM on page 296

Suggestion

Each time we have had to call 911 in 2025 for my cousin we feared that a negative outcome could occur, especially if he felt confronted. This is why we always asked for PERT or MCRT to come as well -- but they were never available, we were told. I made it clear each time that he suffered from severe mental illness but he would be taken to jail and there was no consideration, as far as I could tell, for his mental state.

June Dudas Mar 17 2026 at 2:52PM on page 297

Suggestion

Concur. Families should be viewed as partners as much as possible. They have much greater insight into how the individual is decompensating, especially outside of controlled settings. That insight can make all the difference in finding a meaningful way to connect with the individual and identifying the right course of treatment.

June Dudas Mar 17 2026 at 2:49PM on page 297

Suggestion

Concur 100%. Current mental health services are available only to those who have the neurological capability of asking or agreeing to participate in them. Those with anosognosia are treated as non-compliant when they should instead be regarded as someone who has another layer of psychiatric disability that needs a higher level of wrap around services.

Aaron Meyer Mar 17 2026 at 12:45PM on page 494

Suggestion

There are individuals with severe substance use disorders who are denied FSP services but require higher level of care than currently offered in the community. Allocating $0 to this population does not reflect the community need.

Aaron Meyer Mar 17 2026 at 12:42PM on page 487

Question

The total "other county behavioral health agency services/activities" is 5% of the total "other county expenditures." As this category includes "Public Guardian, CARE Act, LPS Conservatorships, DSH for Housing, and Court Diversion Programs," these programs serve some of the most vulnerable individuals in San Diego County. Does the current allocation adequately prioritize this population, especially in the context of prior audit findings?

link

Aaron Meyer Mar 17 2026 at 12:16PM on page 189

Question

There are individuals with severe substance use disorders who would benefit from an ACT level of care. San Diego County does not have existing programs for individuals with a standalone or primary severe substance use disorder. This reallocation will make treating these individuals in an ACT level of care more difficult.

How many individuals are rejected from an ACT level of care due to determination that the individual has a primary or standalone severe substance use disorder?

Aaron Meyer Mar 17 2026 at 12:04PM on page 149

Suggestion

FSP ICM should also have processes to increase the behavioral health support when individuals with severe mental illness are not engaging. This could be a sign of deterioration and discharge could be harmful.

Aaron Meyer Mar 17 2026 at 11:52AM on page 98

Question

How many of these individuals are able to safely transition to FQHC or CCBHC?

Aaron Meyer Mar 17 2026 at 11:42AM on page 43

How many individuals with Medi-Cal who were subject to incompetency proceedings received acute or outpatient San Diego County behavioral health services during the six month period prior to their arrest?

How many individuals with Medi-Cal who were treated in a hospital ED for a substance use disorder or mental health disorder were linked to behavioral health treatment at the time of discharge?

Aaron Meyer Mar 17 2026 at 11:34AM on page 29

Suggestion

The DHCS Assisted Living Waiver Program is an available option for housing individuals with severe mental illness who require the support of an adult residential facility. For instance, Los Angeles County utilizes the program for adults with severe mental illness, using the designation "mental health facility." San Diego County does not utilize this program for housing adults with severe mental illness in adult residential facilities.

link

Aaron Meyer Mar 17 2026 at 11:28AM on page 25

Suggestion

Welfare and Institutions Code 5200 can increase the penetration rate in populations that are unable to provide for their basic needs, particularly those who have not been durably linked to care through 5150 interventions or incarceration.

link;division=5.&title=&part=1.&chapter=2.&article=2.

Up until at least 2020, San Diego County had operational processes for court-ordered mental health evaluations. This is an important intervention point for those who need the most support.

Aaron Meyer Mar 17 2026 at 11:10AM on page 9

Question

Why are the involuntary hold numbers different from the involuntary hold numbers reported in this DHCS report?

link

Aaron Meyer Mar 17 2026 at 11:08AM on page 9

Question

Is this number inclusive of acute psychiatric hospitalizations with voluntary legal status?

Is this number inclusive of acute psychiatric services at hospitals that do not utilize SmartCare?

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