Report 2020-103 All Recommendation Responses

Report 2020-103: California Department of Corrections and Rehabilitation: It Has Poorly Administered the Integrated Services for Mentally Ill Parolees Program, and With Current Funding Cuts, It Must Find Ways to Transition Parolees to County Services (Release Date: August 2020)

Recommendation #1 To: Corrections and Rehabilitation, Department of

To increase public safety and reduce the likelihood of recidivism, Corrections should establish a separate category in the appropriate data system to track the individuals who would have qualified for the integrated services program. It should also ensure that staff in the institutions, including mental health clinicians and staff involved in prerelease planning, coordinate with parole to assign these individuals to parole agents with specialized caseloads who have the training and experience to serve this population. Corrections should focus its efforts on at least the eight counties that are losing the integrated services program and complete the steps noted in this recommendation by February 2021.

Annual Follow-Up Agency Response From October 2023

The Department has already implemented parts of the CalAIM initiative through its enrollment of parolees into Medi-Cal benefits and assessments for mental health needs during the pre-release process. Based on their mental health needs, parolees are administered services through DAPO's Behavioral Health Reintegration. With the CalAIM initiative, DAPO or CCHCS will work with the counties to transition parolees to county mental health services. However, it should be noted that CalAIM may not apply to all releasing parolees since not all parolees may be eligible for Medi-Cal benefits and Medi-Cal eligibility is a pre-requisite to receiving CalAIM services. Medi-Cal benefits are voluntary as are CalAIM access services.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

2022 Update: Date of completion, pending federal approval. Since the issuance of the CSA 2020-103 audit, the Department of Health Care Services (DHCS) received federal approval for, and began implementing as of January 1, 2022, the California Advancing and Innovating Medi-Cal (CalAIM) and 1115 demonstration and 1915(b) waivers, the former of which will include 90-day pre-release from incarceration Medi-Cal services, targeted to be implemented on July 1, 2023, upon federal approval. After transitioning to the community, and once enrolled into a Medi-Cal Managed Care Plan, CDCR parolees will then have access to the new CalAIM Enhanced Care Management (ECM) and Community Supports (CS) benefits under the CalAIM Individuals Transitioning from Incarceration Population of Focus, also implementing on July 1, 2023, which provides an array of services that include and extend beyond those that would have been available in the past to ISMIP participants (e.g., primary care, Specialty Mental Health, Drug Medi-Cal, dental, and an array of community services and supports that address social determinants of health)). Given that all individuals releasing from CDCR who have mental health and/or substance use disorder conditions will have access to these CalAIM services, there is no longer a need to separately track ISMIP-like individuals. Accordingly, this audit item will be complete once the 90-day pre-release services, ECM and CS benefits for the Individuals Transitioning from Incarceration Population of Focus are implemented. Note: DHCS also revised/broadened the specialty mental health services criteria to increase access.

Supporting documentation will be submitted per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: Post Release Mental Health Needs Identifiers have been determined. Information technology requirement gathering has been initiated, with an implementation goal for the first quarter of 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Develop an algorithm to identify qualifying diagnostic data in the appropriate data system, and include community functioning level scores currently assessed pre-release by institution mental health staff, and "at risk of homelessness" upon release. The algorithm will trigger an identifying code as an indicator of releasing inmates that would have qualified for the Integrated Services for Mentally Ill Parolees (ISMIP) program.

Evaluate the feasibility of establishing specialized caseloads for parole agents providing supervision to parolees that would have qualified for the ISMIP program. This evaluation will include anticipated parole population and related parole agent staffing reductions, resulting from new parole term caps that took effect 7/1/2020.

1-Year CAP Update: Post Release Mental Health Needs Identifiers have been determined. Information technology requirement gathering has been initiated, with an implementation goal for the first quarter of 2022.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

After further review of the Medi-Cal specialty mental health services medical necessity criteria, it has been determined that it is not broad enough to include all potential ISMIP participants. As such, CDCR has shifted efforts toward analyzing the deleted Penal Code 2985.2(c), which outlined the ISMIP program participant requirements that existed prior to the elimination of the program, in order to operationalize and develop a method to identify and electronically track individuals who would have been in the ISMIP program had it continued. As part of this effort, CDCR will engage with internal and external stakeholders, as needed.

California State Auditor's Assessment of 6-Month Status: Pending


60-Day Agency Response

Develop an algorithm to identify qualifying diagnostic data in the appropriate data system, and include community functioning level scores currently assessed pre-release by institution mental health staff, and "at risk of homelessness" upon release. The algorithm will trigger an identifying code as an indicator of releasing inmates that would have qualified for the Integrated Services for Mentally Ill Parolees (ISMIP) program.Evaluate the feasibility of establishing specialized caseloads for parole agents providing supervision to parolees that would have qualified for the ISMIP program. This evaluation will include anticipated parole population and related parole agent staffing reductions, resulting from new parole term caps that took effect 7/1/2020.

Specialty mental health services criteria requested and received via email from the Medi-Cal Behavioral Health Division with the California Department Health Care Services, to assist in identifying eligible candidates and establishing algorithm.Refined eligibility criteria requested from the eight counties via the California Behavioral Health Director's Association.

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #2 To: Corrections and Rehabilitation, Department of

To increase public safety and reduce the likelihood of recidivism, Corrections should continue to meet with the appropriate staff in the behavioral health departments of the eight counties where the integrated services program currently operates to facilitate coordination among Corrections' staff, the providers, and the counties. The coordination should focus on smoothly transitioning current program participants to the county services they need and on developing processes for future parolees with mental illness and issues with homelessness who will transition to county services. Corrections should begin holding these meetings by October 2020 and continue them until all necessary processes are in place.

Annual Follow-Up Agency Response From October 2023

The Department has already implemented parts of the CalAIM initiative through its enrollment of parolees into Medi-Cal benefits and assessments for mental health needs during the pre-release process. Based on their mental health needs, parolees are administered services through DAPO's Behavioral Health Reintegration. With the CalAIM initiative, DAPO or CCHCS will work with the counties to transition parolees to county mental health services. However, it should be noted that CalAIM may not apply to all releasing parolees since not all parolees may be eligible for Medi-Cal benefits and Medi-Cal eligibility is a pre-requisite to receiving CalAIM services. Medi-Cal benefits are voluntary as are CalAIM access services.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Meet with representatives from the eight impacted counties to develop processes for transitioning current ISMIP parolee clients to appropriate county mental health services. In addition, develop an ongoing process for referring parolees that would have qualified for the ISMIP program to the appropriate county mental health services.

2022 Update: Date of completion, pending federal approval. Recurring meetings between DAPO and counties ended in 2022, and CDCR/CCHCS and counties are focused on implementing DHCS' CalAIM 90-day pre-release services starting on July 1, 2023. In the interim, ISMIP-like individuals releasing from prison may be referred to ECM and CS services that are currently offered in the community by the Medi-Cal Managed Care Plans.

Supporting documentation will be submitted per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same

Previous Update: Engagement and meetings with the eight counties continues to occur, with post-release referral processes established in the following seven counties:

1. Fresno

2. Kern

3. Los Angeles

4. San Bernardino

5. San Diego

6. Sacramento

7. Santa Clara

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Meet with representatives from the eight impacted counties to develop processes for transitioning current ISMIP parolee clients to appropriate county mental health services. In addition, develop an ongoing process for referring parolees that would have qualified for the ISMIP program to the appropriate county mental health services.

1-Year CAP Update: Engagement and meetings with the eight counties continues to occur, with post-release referral processes established in the following seven counties:

1. Fresno

2. Kern

3. Los Angeles

4. San Bernardino

5. San Diego

6. Sacramento

7. Santa Clara

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

All ISMIP participants have transitioned out of the CDCR contracted ISMIP program. Updates for each county are as follows:Los Angeles County has been working with CDCR on pre- and post-release referral processes to their managed Full Services Partnership (FSP) programs, with eight geographical referral locations.San Bernardino County is in the process of finalizing a contract with the prior ISMIP provider to continue the infrastructure for parolee referrals and services, and it is working with DAPO initiating referrals.Fresno County is contracting with the previous ISMIP provider for continued service to parolees.Kern County is accepting direct referrals from DAPO. Sacramento County accepts referrals and is in discussion with DAPO staff to formalize a sustainable referral process.Santa Clara County accepts referrals and is in discussion with DAPO staff to formalize a sustainable referral process.San Diego County accepts referrals and is in discussion with DAPO staff to formalize a sustainable referral process.San Francisco County: DAPO staff continues efforts to engage and develop a referral process.Per California State Auditor (CSA) Recommendation #1, CDCR continues to work to define the ISMIP participant criteria as part of the effort to establish processes for future referrals of parolees to the appropriate county services that are inclusive of the ISMIP legislative intent to provide evidence-based, comprehensive mental health and supportive services, including housing subsidies, to parolees who suffer from mental illness and are at risk of homelessness.

California State Auditor's Assessment of 6-Month Status: Partially Implemented


60-Day Agency Response

Meet with representatives from the eight impacted counties to develop processes for transitioning current ISMIP parolee clients to appropriate county mental health services. And develop an ongoing process for referring parolees that would have qualified for the ISMIP program to the appropriate county mental health services.

Ongoing communication between CDCR, the eight counties, and the California Behavioral Health Director's Association.

Two counties are working towards funding the services ongoing with the existing ISMIP contractors.

One county has begun taking referrals.

All counties are indicating that transition and future referrals can occur.

California State Auditor's Assessment of 60-Day Status: Partially Implemented


Recommendation #3 To: Corrections and Rehabilitation, Department of

To increase public safety and reduce the likelihood of recidivism, Corrections should create a regular forum for subject-matter experts to share information regarding their respective efforts to smoothly transition current program participants to county services and to develop processes for future parolees with mental illness and issues with homelessness who will transition to county services. Corrections should include its staff from the eight counties in which the integrated services program will no longer operate, including staff in the institutions, such as mental health clinicians and staff involved in prerelease planning, parole agents, and parole outpatient clinical staff. Corrections should also include the providers currently under contract, county services staff, and others as necessary. The forums should offer Corrections' staff the opportunity to receive updated training as necessary, and Corrections should begin hosting these forums by October 2020.

Annual Follow-Up Agency Response From October 2022

Discussion on this recommendation initiated with the eight counties during ongoing conversations that occur in relation to the CSA recommendation described in item #2 of this CAP. Internal planning pending to identify CDCR participants and scope of forum.

2022 Update: Recurring meetings between DAPO and counties ended in 2022, and CDCR/CCHCS and counties are focused on implementing DHCS' CalAIM 90-day pre-release services starting on July 1, 2023. In the interim, ISMIP-like individuals releasing from prison may be referred to ECM and CS services that are currently offered in the community by the Medi-Cal Managed Care Plans to individuals with serious mental illness(es) and substance use disorder(s), including those who are homeless or at risk of homelessness.

Supporting documentation will be provided per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: CDCR and CCHCS staff have reoccurring meetings with several counties and their invited contractual partners for discussion and development of pre-release and post-release referral processes, problem solving, and case conferencing. The county meetings are independent of each other. Development of a formal reoccurring forum inclusive of more than one county has not yet been developed.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Discussion on this recommendation initiated with the eight counties during ongoing conversations that occur in relation to the CSA recommendation described in item #2 of this CAP. Internal planning pending to identify CDCR participants and scope of forum.

1-Year CAP Update: CDCR and CCHCS staff have reoccurring meetings with several counties and their invited contractual partners for discussion and development of pre-release and post-release referral processes, problem solving, and case conferencing. The county meetings are independent of each other. Development of a formal reoccurring forum inclusive of more than one county has not yet been developed.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Engagement with the eight counties to develop service connections and referral processes is ongoing. This includes discussions on current referrals and issues/concerns that arise. On a related, parallel track, CCHCS, CDCR, and the Council on Criminal Justice and Behavioral Health (CCJBH) are working together on various components of transition planning for the broader behavioral health continuum of care.

California State Auditor's Assessment of 6-Month Status: Pending

It is not clear from Corrections' response that it has taken the steps we recommended, which include establishing a forum, such as a periodic teleconference, in which relevant parties share information about transitioning ISMIP participants to county based services. Based on Corrections' response to the audit, we believe it is committed to implementing the recommendations we made and that future status reports on this recommendation will reflect its progress in implementing this recommendation.


60-Day Agency Response

Discussion on this recommendation initiated with the eight counties during ongoing conversations that occur in relation to the California State Auditor (CSA) recommendation described in item #2 of this CAP. Internal planning pending to identify CDCR participants and scope of forum.

California State Auditor's Assessment of 60-Day Status: Pending


Recommendation #4 To: Corrections and Rehabilitation, Department of

To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by determining the appropriate metrics to evaluate its processes and setting goals related to those metrics.

Annual Follow-Up Agency Response From October 2023

DHCS has set an implementation of April 2024 for both the State's and counties' implementation of CalAIM. The Department will determine the appropriate metrics and set goals related to the CalAIM initiative as we implement.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Determine the appropriate metrics to evaluate processes and set goals related to those metrics.

2022 Update: Date to be completed, pending federal approval. As part of the CalAIM 1115 demonstration waiver (p. 55), DHCS will evaluate the justice-involved initiatives, including 90-day pre-release services, to "assess progress toward achieving the desired outcomes."

Supporting documentation will be provided per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: To initiate after recommendations 1 and 2 are complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Determine the appropriate metrics to evaluate processes and set goals related to those metrics.

1-Year CAP Update: The Department's response remains the same.

To initiate after recommendations 1 and 2 are complete.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Determine the appropriate metrics to evaluate processes and set goals related to those metrics.

To initiate after recommendations 1 and 2 are complete.

California State Auditor's Assessment of 6-Month Status: No Action Taken


60-Day Agency Response

Pending completion of CAP item #1.

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #5 To: Corrections and Rehabilitation, Department of

To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by ensuring that it is collecting sufficient, consistent data to review those metrics.

Annual Follow-Up Agency Response From October 2023

The Department will determine the appropriate data metrics and begin collecting the data as we implement the CalAIM initiative.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Collect sufficient and consistent data to review the metrics.

2022 Update: Date to be completed, pending federal approval. As part of the CalAIM 1115 demonstration waiver (p. 55), DHCS will evaluate the justice-involved initiatives, including 90-day pre-release services, to "assess progress toward achieving the desired outcomes." This will include ensuring that the appropriate data elements are captured.

Supporting documentation to be provided per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: To initiate after recommendations 1, 2, and 4 are complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Collect sufficient and consistent data to review the metrics.

1-Year CAP Update: The Department's response remains the same.

To initiate after recommendations 1, 2, and 4 are complete.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Collect sufficient and consistent data to review the metrics.

To initiate after recommendations 1, 2, and 4 are complete.

California State Auditor's Assessment of 6-Month Status: No Action Taken


60-Day Agency Response

Pending completion of CAP items #1 and #4

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #6 To: Corrections and Rehabilitation, Department of

To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by establishing a timeline for conducting reviews regularly, but at least every three years. Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

Annual Follow-Up Agency Response From October 2023

DHCS has currently set an April 2024 CalAIM roll out date for statewide implementation for the State and the counties. The Department will regularly review its implementation of the CalAIM initiative and as we roll out with the counties, we will establish a timeline for conducting regular reviews.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Establish a timeline for conducting reviews regularly, but at least every 3 years, and include at least the eight counties formerly served by the integrated services program.

2022 Update: Date to be completed, pending federal approval. As per the CalAIM 1115 demonstration waiver requirements, oversight will be ongoing and in accordance with the requirements established in the Special Terms and Conditions of the waiver, once approved.

Supporting documentation to be provided per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: To initiate after recommendations 1, 2, 4, and 5 are complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Establish a timeline for conducting reviews regularly, but at least every 3 years, and include at least the eight counties formerly served by the integrated services program.

1-Year CAP Update: The Department's response remains the same.

To initiate after recommendations 1, 2, 4, and 5 are complete.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Establish a timeline for conducting reviews regularly, but at least every 3 years, and include at least the eight counties formerly served by the integrated services program.

To initiate after recommendations 1, 2, 4, and 5 are complete.

California State Auditor's Assessment of 6-Month Status: No Action Taken


60-Day Agency Response

Timeline pending completion of CAP items #1, #4, and #5. 07/2021

First review to initiate after CAP item #5 is complete. 12/2021

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #7 To: Corrections and Rehabilitation, Department of

To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by reporting on its success in meeting its goals to the Council on Criminal Justice and Behavioral Health and the public. Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

Annual Follow-Up Agency Response From October 2023

The Department continues to engage CCBJH on the CalAIM initiative and will begin reporting to CCJBH and to the public on its CalAIM status as we begin the implementation phases.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Report to the CCJBH and to the public.

2022 Update: CCJBH featured DHCS at its October 29, 2021, Full Council Meeting where DHCS provided Councilmembers with an overview of the CalAIM justice-involved proposals, all of which will benefit the ISMIP-like population (see October 29, 2021, CCJBH Full Council Meeting PowerPoint presentation). CCJBH continues to closely engage with CDCR/CCHCS and DHCS on the implementation of the CalAIM justice-involved proposals, serving as a forum for ongoing presentations and information dissemination.

Supporting documentation will be provided, per CSA' direction.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

In its response, Corrections refers to actions taken by other entities but does not claim to have taken any action to implement this recommendation.


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: To initiate after recommendations 1, 2, 4, 5, and 6 are complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Report to the CCJBH and to the public.

1-Year CAP Update: The Department's response remains the same.

To initiate after recommendations 1, 2, 4, 5, and 6 are complete.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Report to the CCJBH and to the public.

To initiate after recommendations 1, 2, 4, 5, and 6 are complete.

California State Auditor's Assessment of 6-Month Status: No Action Taken


60-Day Agency Response

Reporting plan pending completion of CAP items #1, #4, and #5. 07/2021

First review to initiate after CAP item #5 is complete. 12/2021

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #8 To: Corrections and Rehabilitation, Department of

To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by using the reviews to identify changes to improve its processes for connecting parolees to resources, including improving training for Corrections' staff.Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

Annual Follow-Up Agency Response From October 2023

As the Department implements the CalAIM initiative and evaluates its processes, we will also identify changes needed to improve on connecting parolees to resources as well as identify staff training needed.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2022

Use the reviews to identify changes to improve processes for connecting parolees to resources, including the improvement of training for CDCR staff.

2022 Update: Date to be completed, pending federal approval. As per the CalAIM 1115 demonstration waiver requirements, oversight will be ongoing and in accordance with the requirements established in the Special Terms and Conditions of the waiver, once approved.

Supporting documentation to be provided, per CSA's direction.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From October 2021

The Department's response remains the same.

Previous Update: To initiate after recommendations 4, 5, and 6 are complete.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


1-Year Agency Response

Use the reviews to identify changes to improve processes for connecting parolees to resources, including the improvement of training for CDCR staff.

1-Year CAP Update: The Department's response remains the same.

To initiate after recommendations 4, 5, and 6 are complete.

California State Auditor's Assessment of 1-Year Status: Pending


6-Month Agency Response

Use the reviews to identify changes to improve processes for connecting parolees to resources, including the improvement of training for CDCR staff.

To initiate after recommendations 4, 5, and 6 are complete.

California State Auditor's Assessment of 6-Month Status: No Action Taken


60-Day Agency Response

Reporting plan pending completion of CAP items #1, #4, and #5. 07/2021

Usage of reviews to identify changes to improve processes will initiate after completion of first review. 12/2021

California State Auditor's Assessment of 60-Day Status: No Action Taken


All Recommendations in 2020-103

Agency responses received are posted verbatim.