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Letter to Sec. Benton Re: Invol. Commitment Facilities |
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March 14, 2008
The Honorable Dempsey Benton
Secretary
North Carolina Department of Health and Human Services
2001
Mail
Service
Center
Raleigh, NC
27699-2001
Dear Secretary Benton,
The Mental Health Association in NC has serious concerns about the Secretary’s rule that was presented to the Commission for Mental Health, Developmental Disabilities and Substance Abuse Services on February 21, 2008.
The draft amendment to the existing Secretary Rules under Chapter 26C Section .0100 - .0105 Designation of Facilities for the Custody and Treatment of Involuntary Clients allows designation of involuntary commitment facilities to include facilities for:
· Non-hospital Medical Detoxification for Individuals who are Substance Abusers,
· Residential Treatment or Rehabilitation for Individuals with Substance Abuse Disorders
· Facility Based Crisis for Individuals of all Disability Groups.
We recognize and appreciate the Division’s stated intention, at the February 21st Commission meeting, to remove Social Setting Detoxification for Substance Abuse from the list of potential facilities. However, we still have concerns regarding the additional facilities that would be allowed to accept and treat individuals who are involuntarily committed (IVC).
As is, these facilities are not equipped to accept and treat our often, medically complex patients. We understand the Division intends to regulate those facilities that wish to take IVC, but until these rules and procedures are fully disclosed and vetted, MHA-NC asks that you suspend the implementation of the proposed rules and require a thorough review of the safety, staffing and appropriateness of any new designations of involuntary commitment facilities. The very nature of involuntary commitment makes the person committed fully exposed to all aspects of our system; we must assume the total safety and security of that individual. It is of particular importance that we do not fail those, who we have determined, cannot successfully exist without our help. The state has learned a difficult lesson about what happens when providers are invited to offer services without the proper guidelines in place; we hope that future policy decisions reflect these lessons. MHA-NC fears that the designation of new facilities, without fully established regulations, will only create more tragedies in an already compromised system.
We thank you for taking the time to consider the safety of those who are most in need.
Sincerely,
John Tote, III
Executive Director, Mental Health Association in NC
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