On March 21st we received a copy of the response from DHCS/CDSS concerning the letter sent from Senator Marie Alvarado-Gil’s office. This letter from these two directors highlighted how these proposed facilities in Rescue go against state priorities, and El Dorado County has the authority to ensure these developments “meet relevant zoning requirements to ensure programmatic and local requirements are met…includ(ing) ensuring construction work complies with the minimum standards of safety, and
protecting public and program participant health, safety, and welfare.”
State Priority: Geographic Equity
The second priority for these programs is the following:
“Seek geographic equity of behavioral health and community care options.“
The state programs that plan to fund these developments are meant to expand and fill gaps in local support infrastructure in disenfranchised communities, including mental health and SUD treatment and continued care facilities across California.
This same priority is listed in the following Behavioral Health Continuum Program (BHCIP) program update (link) – which states: “A gap analysis on BHCIP funding to-date coupled with existing behavioral health facilities across California has shown several regions, along with tribal entities, that continue to display unmet needs. Many counties in these regions are rural and/or small, making it challenging for individuals in these communities to readily access needed behavioral health services.”
With the stated priority of Geographic Equity above, and the following point made on ensuring investment goes to communities that need ready access to behavioral health services, why would DHCS want to transport pregnant women 100’s of miles away from their families, friends and established medical providers for Substance Use Disorder (SUD) treatment? This certainly does not fill a gap in needed services within disenfranchised communities, nor does it expand the continuum of care. In fact, this plan to centralize treatment far away from these communities will actually hinder geographical equity with competing interests for projects that would expand and fill that gap in geographical areas of need.
These locations in Rescue, for patients “in the San Joaquin Delta area” (link) or anywhere in California, does not put the facilities into communities that need more of these services. The unfortunate future patients of these facilities will need to be transported far away from home and any existing medical care to a treatment center that has no services, is far away from medical care, and is in the highest fire risk in the state. This is costly and provides an advantage only for profitability.
State Priority: Least restrictive settings
Another listed state priority is to “Ensure care can be provided in the least restrictive settings to support community integration, choice, and autonomy.” This highlights the importance of developing these facilities close to where the patients originate from, and in communities that need infrastructure investment to help deliver local care. Clearly the current HomeCA/Native Directions proposals do not do that. These facilities should be built in an area that needs more facilities to support Native American women, not a county, and parcels, that are already adequately serving this population, and are ill suited for developments of this size.
State Commitment to “Public Health, Safety and Welfare“
As highlighted above, one critical block of text in this letter is the following:
“However, for BHCIP and CCE projects to progress, awardees are required to work within their local jurisdiction to obtain necessary permits through local Planning and Building Departments and meet relevant zoning requirements to ensure programmatic and local requirements are met. This includes ensuring construction work complies with the minimum standards of safety, and protecting public and program participant health, safety, and welfare.” (emphasis added)
As we noted to Supervisor Parlin in an email response, “our hope is that the County can treat these commercial facilities in the same way any other commercial development would be treated. At a minimum the safety and long term wellbeing of the existing community must be considered, and as such, tools such as Environmental Impact Reports and Conditional Use Permits must minimally be required. We appreciate that the heads of these State agencies agree.”