FR 2024-29515

The document titled "Agency Information Collection Activities: Submission for OMB Review; Comment Request" outlines proposed updates to the data collection methods used by the Substance Abuse and Mental Health Services Administration (SAMHSA) for the Treatment Episode Data Set (TEDS) and related datasets. These datasets are critical for tracking substance use and mental health treatment services across the United States.

General Summary

SAMHSA is seeking to revise how it collects data in order to improve inclusivity and align with national guidelines and reporting requirements. The proposed changes include updating terminology to be less stigmatizing, adding new data fields like sexual orientation and gender identity, and enhancing the comprehensiveness of drug data by including substances like Fentanyl and Xylazine. These updates also involve mapping state data systems to the federal framework, which could standardize data collection across different jurisdictions.

Significant Issues and Concerns

One concern is the lack of detail regarding how substances are selected for inclusion in the Detailed Drug Code list. Understanding these criteria could help clarify decisions for stakeholders and the public. Additionally, while the document describes the shift to non-stigmatizing terminology, it does not address the transition plan for stakeholders who currently use existing terminology, which could lead to confusion and resistance.

The process for public comment is outlined but lacks specific instructions, which might hinder participation from individuals unfamiliar with regulatory systems. Moreover, the document does not elaborate on the financial or operational impacts of these changes, which are necessary to evaluate the cost-effectiveness and practicality of their implementation.

The roles and responsibilities for states in implementing these changes also aren't clearly defined. Without explicit guidance, states might face challenges in adapting to the new data collection methods.

Impact on the Public Broadly

These changes aim to enhance the relevance and quality of data collected on mental health and substance use treatment, which could lead to better-informed public policies and resource allocation. By using inclusive language and data fields, SAMHSA hopes to appropriately reflect the diversity of the population receiving treatment. However, the lack of detailed guidance might lead to inconsistencies in how the data is collected and reported by different states.

Impact on Specific Stakeholders

For state agencies and treatment facilities, these proposed revisions will require adjustments in how data is collected, reported, and managed. While such changes can improve data accuracy and inclusivity, they may initially burden these entities with new training and system updates. Understanding the transition and financial implications will be essential for these stakeholders.

Service providers in the mental health and substance use sectors might welcome the move towards non-stigmatizing language, which could foster a more supportive environment for clients. However, the addition of new data fields, such as 'School attendance status at admission', lacks a clear explanation of benefits, potentially raising questions about their utility and rationale.

In summary, while the updates promise improvements in data collection quality and inclusivity, the document could benefit from a more detailed transition plan, clearer guidance for states, and a thorough impact assessment, which would better support stakeholder adaptation and public engagement.