Resources
Prevention Services Rule - Explanation and Public Comment Email Examples/Language
OhioMHAS has proposed a new version of OAC (Ohio Administrative Code) 5122-29-20 -- the Prevention Services Rule -- the Rule that requires organizations that provide prevention services be certified by OhioMHAS.
The new version maintains much of the language of the current version of the Rule that the prevention field has operated under, with minor adjustments, for decades. But, the new version begins by stating, "On and after the effective date of this rule, prevention services is not a certifiable service of the department...."
This statement turns a requirement that providers have qualified staff, deliver evidence-based services, and meet other standards that ensure consumer protection into a mere suggestion.
For 25 years, the Prevention Services Rule has been foundational to the delivery of effective prevention in Ohio, by requiring prevention interventions be evidence based and implemented by staff with legitimate qualifications, including prevention certification. If the Rule no longer has a regulation or enforcement component, the potential implications are significant, including:
- Prevention dollars can be allocated without consideration to evidence-based practice or qualified staff, undermining organizations that have earned prevention certification by following best practices and ensuring their staff are prevention certified.
- Prevention consumers receive substandard services, delivered by under- or unqualified individuals and organizations.
- Prevention becomes an ancillary service in Ohio's behavioral health field instead of a robust, distinct, science-based discipline and service.
- Prevention professional certification through the OCDP Board has much less value, sabotaging the professionalism of the prevention field and prevention practice.
The relevant documents/postings about the proposed new Rule:
OhioMHAS Prevention Services (announcement from OhioMHAS with link to submit public comments)
Rule 5122-29-20 (Current OAC Prevention Services Rule)
Proposed New Rule 5122-29-20 (Proposed OAC Prevention Services Rule)
Business Impact Analysis (OhioMHAS justification for the new Rule)
OPPA is providing sample language, developed by Ohio prevention leaders, for members to utilize in crafting their public comment in opposition to the OhioMHAS proposal to change the Prevention Services Rule, removing provider certification.
Each "Sample Email Language" focuses on a different priority in response to the proposed change. Members can pull language from the various samples or build a case based on a specific argument. We strongly encourage you to personalize your public comment as much as possible, even if you use some of the sample language provided below.
Questions? Contact OPPA at mail@ohiopreventionprofessionals.org.
Sample Email Language - Consumer Protections
Sample Email Language - Consumer Protections (v.2)
Sample Email Language - Moving the Field Backward
Sample Email Language - OhioMHAS Statutory Responsibility
Sample Email Language - Lack of Uniformity Across the State
Sample Email Language - Impact on Workforce
Sample Email Language - Unenforceable
Sample Email Language - Lack of Communication with the Field
Sample Email Language - Coalitions Certification Requirement