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HLA testifies at the Dept. of Public Health’s hearing on proposed closure of child psych. inpatient beds

Testimony for  the Massachusetts Department of Public Health– Notice of Public Hearing Concerning Cambridge Health Alliance Inpatient Pediatric Psychiatry Services – 105 CMR 130.122(E).

Date:  May 8, 2013

My name is Samuel Leadholm and I’m a staff attorney at Health Law Advocates (HLA). HLA is a non-profit, public interest law firm providing legal representation and counsel to lower income individuals and families in the Commonwealth experiencing difficulties accessing or paying for needed medical services.

In 2006, HLA launched its Children’s Mental Health Access Project. This Project seeks to confront barriers to timely mental health care for children. Over the Project’s past seven years, HLA lawyers have expanded access to mental health services to children in lower income Massachusetts families through a range of ventures.  Other initiatives have done so as well.  However, significant barriers to timely and appropriate mental health care for children still exist. 

HLA is also a leader in advocating for the consumer-focused implementation of state and federal mental health parity laws, which impacts children and adults, and has been instrumental in working with state agency leaders to strengthen enforcement of parity laws in Massachusetts.

HLA is here today to express concern for the closing of eleven pediatric acute psychiatric inpatient beds at Cambridge Health Alliance (CHA). 

CHA is highly-regarded as a leading provider of a broad continuum of mental and behavioral health services to pediatric, adolescent, adult and geriatric patients. However, in 2009, due to changes in public reimbursement and state budget challenges, CHA closed 35 adult psychiatric beds and 25 substance abuse beds.

Clearly, inadequate reimbursement for mental health services has chipped away at needed inpatient resources; vital resources for vulnerable children and their families.  Anecdotal reports of children in mental health crises abound.  Many children in crises are screened at local ERs and are found to require inpatient care. However, because available inpatient beds cannot be found, children in emotional crises need to be boarded in emergency rooms, sometimes for days. It is hard to reconcile ER boarding and the delay of needed care, on the other hand, with the closure of 11 pediatric beds.  The proposed reduction in pediatric beds further erodes a vital and yet underfunded resource.

CHA is an important inpatient resource for pediatric admissions, both within its service area and in the Commonwealth. Although CHA is focusing the provision of its mental health services on its primary care patients and individuals within its service area, 69% of 8 year old and younger patients came from homes outside CHA’s service area.  Before approving the closure of these beds, CHA and the Departments of Mental Health and Public Health need to assure stakeholders there are sufficient resources to meet these children’s mental health needs. 

Before reducing bed capacity, a deliberative, independent analysis of the Commonwealth’s behavioral health needs should be completed.  The Mental Health Advisory Committee—established by Section 186 of Chapter 136 of the Acts of 2012—is midway through the process of gathering data and examining a number of factors impacting the delivery of mental health services in the Commonwealth. The Committee’s recommendations based on the independent analysis are due by December 31, 2013.  Closing beds in one service area before a statewide analysis is completed is premature. 

One of the preliminary findings of the independent analysis supports is that the “current movement in and out of acute care is problematic and inefficient making it difficult to gauge acute care capacity versus need.” Closing beds before a systemic analysis is completed is may cause greater inefficiencies. 

In closing, HLA supports a deliberative, open process to determine how best to meet the mental health needs of the Commonwealth’s children. Thank you for your time today and the opportunity to provide this testimony.  

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