Constructive Feedback and thoughts on the SAMHSA Unified Client-Level Performance Reporting Tool (SUPRT)

~ billstaufferpa

As posted in the Federal Register in early September, The Substance Abuse and Mental Health Services Administration (SAMHSA) is the agency within the U.S. Department of Health and Human Services that leads public health efforts to advance the behavioral health of the nation. SAMHSA is seeking approval for the new SAMHSA Unified Client-level Performance Reporting Tool (SUPRT) to modify the existing Center for Substance Abuse Treatment (CSAT) and Center for Mental Health Services (CMHS) Client-Level Performance Instruments into a streamlined, multi-component SAMHSA Client-Level Performance Tool. Currently, over 7,500 grantees across a range of prevention, harm reduction, treatment, and recovery support discretionary grant programs report program performance data into SAMHSA’s Performance Accountability and Reporting System (SPARS) that serves as a central data repository.  

The newly proposed tool includes important questions and will  serve to improve understanding of how related programs using this new tool if adopted to measure recovery capital as part of their efforts to help people heal from the spectrum of substance use conditions, from mild to severe.

  • There is both a challenge and an opportunity to consider the full range of healing across this spectrum.
  • Our comments, in part posted here and in full as a linked PDF are wholly constructive in nature.
  • We embrace the inclusion of healing from less severe substance use conditions and the comments are intended to support persons with the most severe forms while acknowledging and supporting that there is a range of experience in relation to healing from the spectrum of substance use conditions.
  • From our perspective, delineating the experience of healing across the spectrum of substance use conditions from mild to severe has the potential to improve our understanding of how people heal and supporting their varied needs.
  • The challenge in doing so is to support frameworks of understanding and measurement that articulates and honors the broad range of experiences in ways that support that full range of healing.
  • What is lost in the draft tool is the experience of those with the most severe form of substance use conditions that typically includes loss of control that can be life threatening.
  • We are on the cusp of broadly expanding how we view and support the broad range of healing from the spectrum of substance use conditions and see related efforts as one of the most significant ways to move our collective efforts forward. It can and should be crafted in ways that support all experiences.

A PDF of my public comment is here as written, we appreciate the opportunity to provide input to the proposed new client-level performance tool and the efforts to align recovery-oriented outcome goals in the SAMHSA Core Outcomes of Recovery (SCOR) Scale through 13 recovery-oriented measures that align with SAMHSA’s approach to recovery and how these will be measured at baseline and at points of reassessment for all age groups served. Aligning these measures to recognize individual level recovery capital makes a great deal of sense and can serve to improve services and support across the care continuum.

In our comment, we raise concerns about one question in the proposed tool, which is question three that reads “I am in control of my substance use” which deploys a six-point Likert scale from strongly agree to strongly disagree.  As noted in the submitted comment:

  • This seems to suggest that the core outcome that SAMHSA is pursuing is the moderation of use for persons across the continuum of healing from a substance use condition from mild to severe.
  • For the vast majority of people with the most severe form of substance use conditions, this question presents risks of focusing them on successfully using in moderated ways rather than cessation of use as part of their healing.
  • We are people in recovery from the most severe form of Substance Use Conditions. We experience a terrifying and unpredictable loss of control and use with significant consequence to ourselves and those around us, far often to the point of death unless we stop using alcohol and other drugs. Recovery for us and as commonly defined in the substance use recovery space, includes no recreational use or the misuse of prescribed substances in any way.
  • We often experience deep shame for not being able to predictably control our use, despite us trying to do so repeatedly, often as noted above with horrific consequences. We have watched many people die in this way, while ruefully claiming that they were in control of their use, up to the very point of death.

We would respectfully request that SAMHSA revise this question to accommodate persons with severe substance use disorders for whom the term control presents inherent risks and underlying shame for not being able to control use.  

As the tool is to align with the development of recovery capital, the BARC 10 question: I regard my life as challenging and fulfilling without the need for using drugs or alcohol, may be more useful as a Likert measure. This would ensure that the focus of efforts at SAMHSA with the use of this tool are not mistaken for the goal of moderation of use for persons with severe substance use disorders, a deadly prospect for many of us, one we far too often pursue to point of death.

It may also be considered to add an additional question for persons who are able to moderate less severe forms of SUD for whom this is a viable option, potentially as framing it as: I have been able to resolve a substance use problem through moderation strategies if this is an area of interest in collection for the tool.

You can view the revised client level tool including the proposed recovery scale here. Comments can be mailed to the SAMHSA Reports Clearance Officer, 5600 Fishers Lane, Room 15E45, Rockville, Maryland 20857, or email a copy tosamhsapra@samhsa.hhs.gov. View the draft tool here.

Written comments should be received by October 15, 2024.

Sources

GPRA Modernization Act of 2010. (2024). Samhsa.gov. https://www.samhsa.gov/grants/gpra-measurement-tools?utm_source=SAMHSA&utm_campaign=87982bbfbd-EMAIL_CAMPAIGN_2024_09_13_03_29&utm_medium=email&utm_term=0_-87982bbfbd-%5BLIST_EMAIL_ID%5D

SAMHSA (2024, September 6). Notice from SAMHSA. Federal Register.

https://www.federalregister.gov/documents/2024/09/06/2024-20051/agency-information-collection-activities-proposed-collection-comment-request-correction?utm_campaign=subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov&utm_source=SAMHSA&utm_campaign=87982bbfbd-EMAIL_CAMPAIGN_2024_09_13_03_29&utm_medium=email&utm_term=0_-87982bbfbd-%5BLIST_EMAIL_ID%5D Stauffer, W. (2024, September 19). PRO-A Public Comment -Substance Abuse and Mental Health Services Administration (SAMHSA) Unified Performance Reporting Tool (SUPRT) -C. https://pro-a.org/wp-content/uploads/2024/09/PRO-A-Public-comment-on-SAMHSA-SUPRT-C-Tool.pdf

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Published by billstaufferpa

William Stauffer is the Director of Pennsylvania Recovery Organization Alliance (PRO-A). In recovery for well over 3 decades, he is a nationally recognized trainer and writer addiction and recovery. He has testified to the US Senate Special Committee on Aging and in 2019, he organized a hearing with the PA House Human Services Committee to expand opportunities for young people. He is a past co-chair of the public policy committee for Faces & Voices of Recovery and the 2019 recipient of the Vernon Johnson Award Individual Recovery Advocate of the year. He teaches Social Work at Misericordia University. He was recently named to the Leadership Council of Foundations for Drug Policy Solutions (FDPS) a national think / do tank where he serves alongside some of the most respected leaders in the SUD service system. In December 2022, Mr. Stauffer was invited to serve Governor-Elect Josh Shapiro & Lieutenant Gov-Elect Austin Davis on the state Human Services transition team.