Rosie D.
Reforming the Mental Health System in Massachusetts
Reforming the Mental Health System in Massachusetts
Complete Document Library
The Library contains a large volume of the most useful documents developed in the Rosie D. case, including documents related to the initial litigation, the remedy and its implementation, as well as home-based services throughout the country.
The Library is divided into multiple folders that track the evolution and issues in the case.
Rosie D. Litigation
Complaint
Complaint (2001)
Discovery
Access to records cases (2003)
Access to non-class members’ records memo (2004)
Access to non-class members’ records opposition (2004)
Answers to defendants’ request for admissions (2004)
Answers to defendants’ first interrogatories (2003)
Answers to defendants’ second interrogatories (2004)
Answers to defendants’ third interrogatories (2004)
Confidentiality – state law (2002)
Plaintiffs’ first interrogatories to Medicaid (2003)
Plaintiffs’ first interrogatories to human service agencies (2003)
Plaintiffs’ second interrogatories to human service agencies (2004)
Plaintiffs’ first document request (2003)
Plaintiffs’ second document request (2004)
Dismissal
Defendants’ Motion to Dismiss (2002)
Plaintiffs’ Opposition to Motion to Dismiss (2002)
Defendants’ Appeal brief re: Motion to Dismiss (2002)
Plaintiffs’ Appeal brief re: Motion to Dismiss (2002)
Amici NeHelp Appeal brief re: Motion to Dismiss (2002)
Court of Appeals decision (2002)
Experts Reports - Plaintiffs
Burns, Barbara – literature review
Conroy, James – utilization data review
Greer, Dr. James – client review
Joyner, Narell – client review
Kamradt, Bruce – program review
Koyanagi, Chris – other states
Sutherland, Michael – client review
Valentine, Carl – fiscal review
Whitaker, Beth – client review
Expert Reports - Defendants
Bickman, Leonard – effectiveness of home-based services
Bickman, Leonard (rebuttal) -- effectiveness
Foster, Michael - cost of home-based services
Metz, Peter – implementation of home-based services
Judgment
Court judgment and approved remedial plan (2007)
Court judgment – decision (2007)
Motions
Class certification memo (2002)
Class certification opposition (2002)
Class certification reply (2002)
Opposition to Defs’ Motion in limine re: clinical review (2005)
Opposition to Defs’ Motion in limine re: cost analysis (2005)
Opposition to Defs’ Motion in limine re: report of Koyanagi (2005)
Opposition to Defs’ Motion in limine re: legal opinions on EPSDT (2005)
Opposition to Defs’ Motion in limine re: relevance of other states (2005)
Opposition to Defs’ Motion in limine re: rebuttal experts (2005)
Opposition to Defs’ Motion in limine re: reliability of client reviews (2005)
Opposition to Defs’ Motion in limine re: use of treating physicians (2005)
Pls’ Motion in limine re: fact cut-off date (2005)
Pls’ Motion in limine re: effectiveness of home-based services (2005)
Protective order amended (2004)
Summary judgment opposition (2005)
Plaintiffs' Memorandum in Support of their Motion for an Award of Attorneys' Fees & Costs (12/07)
Remedial Plans
Defendants’ proposed remedial plan (2006)
Defendants’ memo on remedial plan (2006)
Plaintiffs’ proposed remedial plan (2006)
Plaintiffs’ memo on remedial plan (2006)
Affidavits
Friedman, Robert - Affidavit (2006)
Funk, Betty - Affidavit (2006)
Greer, Dr. Jim - Affidavit (2006)
Kamradt, Bruce - Affidavit (2006)
Keller, Dr. David - Affidavit (2006)
Knisley, Marti - Affidavit (2006)
Lambert, Lisa - Affidavit (2006)
Rotto, Knute - Affidavit (2006)
Valentine, Carl - Affidavit (2006)
White, Marci - Affidavit (2006)
Court decision on plans (2007)
Trial
Defendants’ exhibit list (2005)
Defendants’ findings of fact and conclusions of law (2005)
Defendants’ witness list (2005)
Plaintiffs’ exhibit list (2005)
Plaintiffs findings of fact and conclusions of law (2005)
Plaintiffs findings of fact and conclusions of law – reply (2005)
Plaintiffs’ witness list (2005)
Decision
Rosie D. Remedy and Implementation
Pathway to home-based services flow chart (2006)
Assessment
Community Service Agencies (CSA)
Community Service Agency (CSA) Request for Response (RFR)
MassHealth Survey on MCE & CSA Interface, January 2010
Covered Services
State Plan Amendments (SPA) – EPSDT services
State Plan Amendments (SPA) – Targeted Case Management
Revised SPA for EPSDT services
CMS approved SPA for EPSDT services (6/09)
Revised SPA for targeted case management program ICC
CMS approved State Plan Amendment (SPA) 12/08
MBHP Emergency Services Providers
Covered Services: Providers
Crisis Stabilization
Covered Services: Medical Necessity Criteria
Therapeutic Mentoring Services
Covered Services: Performance Specifications
Therapeutic Mentoring Services
Covered Services: Powerpoint Presentations
Children's Behavioral Health Initiative Services
Therapeutic Mentoring Services
Data and Research
Behavioral Health Screening Reports
December 31, 2007 - December 31, 2013
CANS Reports
2009-2010 CANS Analysis
CANS data July - December 2010, Usage for all MCEs
CANS data July 2010 - September 2011
CANS data July 2010 - March 2012CSA Reports
July 2010
August 2010
September 2010
October 2010
November 2010
December 2010
February 2011
March 2011
May 2011
June 2011
October 2011
November 2011
December 2011
January 2012
February 2012
March 2012
May 2012
June 2012
July 2012
August 2012
September 2012
October 2012
November 2012
December 2012
January 2013
February 2013
March 2013
April 2013
May 2013
June 2013
July 2013
December 2013
June 2014CSR Reports & Monitor's Role
Stipulation on Monitor’s Role and Responsibilities
2010 CSR Regional Report - Metro Boston (preliminary)
2010 CSR Regional Report - Metro Boston (final)
2010 CSR Regional Report - Central MA
2010 CSR Regional Report - Northeastern MA
2010 CSR Regional Report - Southeastern MA (preliminary)
2010 CSR Regional Report - Southeastern MA (final)
2010 CSR Regional Report for Western MA
Statewide CSR Annual Report, FY 2010-20112011 CSR Regional Boston/Metro Boston
2011 CSR Regional Report - Northeastern MA (preliminary)
2011 CSR Regional Report - Northeastern MA (final)
2011 CSR Regional Report - Southeastern MA (preliminary)
2011 CSR Regional Report - Southeastern (final)
2011 CSR Regional Report - Western MA (preliminary)2011 CSR Regional Report - Western MA (final)
Statewide CSR Annual Report, FY 2011-2012
ICC Waitlist Reports
MCI Monthly Encounters Reports
MPR Reports
Service Utilization Reports:
System of Care Practice Review (SOCPR)July 1, 2009 - December 31, 2009
July 1, 2009 - March 31, 2010
July 1, 2009 - June 30, 2010
July 1, 2010 - December 31, 2010
July 1, 2010 - March 31, 2011
July 1, 2010 - June 30, 2011
July 1, 2011 - September 30, 2011
July 1, 2011 - December 31, 2011
July 1, 2011 - March 31, 2012
July 1, 2013 - September 30, 2013
July 1, 2013 - March 31, 2013
Western, May 2014
Southeast, March 2014
Central, January 2014
Northeast, October 2013
Metro Boston, June 2013Wraparound Reports
Wraparound Fidelity Index/Team Observation Measure Report 2010
Wraparound Fidelity Index/Team Observation Measure Report 2011Education & Training
Reforming The Medicaid Children's Mental Health System
Rosie D. Questions and AnswersReforming the Medicaid Children's Mental Health System:
What Schools Should Know about Rosie D.Rosie D.: Overview of the Litigation (2009)(ppt) – legal edition
Evaluating Wraparound Services
Eligibility
Serious emotional disturbance: IDEA regs
Serious emotional disturbance: SAMHSA regs
Serious emotional disturbance: IDEA and SAMHSA compared
Evaluation
Outcomes: assessment instruments
Outcomes: child functioning principles
Informing
MassHealth Provider Fact Sheet
Boston Medical Center Member Handbook
Fallon Community Health Plan Member Handbook
Neighborhood Health Plan Member Handbook
Motions
Eligibility for Services
Interim Services and Family Stabilization Teams (FST)
Defendants' Memorandum re: FST prior to full remedy implementation
Judge's Proposed Order on Interim Services
Defendants' Amended Memorandum re: FST prior to full remedy implementation
Modification of Implementation Dates
Defendant EOHHS' Motion to Modify Judgment
Defendant EOHHS' Memorandum of Law in Support of its Motion to Modify Judgment
Plaintiffs' Opposition to Defendant EOHHS' Motion to Modify Judgment
Memorandum and Order Regarding Defendants' Motion to Modify Judgment (2/2009)
In-Home Behavioral Services Staff and Eligibility Criteria
Plaintiffs' Reply to Defendants' Opposition to Emergency Motion
Waiting Lists for ICC Services
Plaintiffs' Proposed Order on Waiting Lists
Defendants' Response to Plaintiffs' Proposed Order
Plaintiffs' Motion to Ensure Timely Access to Remedial Services
Plaintiffs' Memorandum in Support of Their Motion to Ensure Timely Access to Remedial Services
- Exhibit 1 - Supplemental Affidavit of Lisa Lambert
- Exhibit 2 - 3rd Affidavit of Kathryn Rucker
- Exhibit 3 - Affidavit of Leslie Lockhart
- Exhibit 4 - Defs' August 2010 CSA Report
Defendants' Opposition to Plaintiffs' Motion for Order to Ensure Timely Access to Remedial Services
Monitor's Use of "CSR" Community Service Review
Defendants' Motion for Clarification
Defendants' Memorandum in Support of their Motion for Clarification
Affidavit of Emily Sherwood (Exhibit A)
Sherwood Exhibit 1
Sherwood Exhibit 2
Sherwood Exhibit 3
Sherwood Exhibit 4
Sherwood Exhibit 5Affidavit of Hannah Karpman (Exhibit B)
Affidavit of Stephen Barnard (Exhibit C)Plaintiffs' Opposition to Motion for Clarification
Affidavit of Dr. Robert Friedman (Exhibit 1)
Affidavit of Dr. Ivor Groves (Exhibit 2)Defendants' Reply to Plaintiffs' Opposition
Affidavit of Dr. Mary I. Armstrong (Exhibit A)
Defendants' Renewed Motion for Clarification of Jundgment As It Pertains to Monitor's CSRs
Affidavit of Jack Simons (Exhibit A)
Plaintiffs' Opposition to Defendants' Renewed Motion for Clarification of Judgment
Affidavit of Dr. Ray Foster (Exhibit 1)
Reports on Disengagement
Plaintiffs' Disengagement Report 4/13
Plaintiffs' Response to Defs' Supplemental Filing on Disengagement Criteria 10/12
Defendants' Reports on Status
Defendants’ First Report - 6/07
Defendants’ Second Report - 11/07
Defendants’ Third Report - 5/08
Defendants' Status Report - 10/08
Defendants' Fourth Report - 11/08
Defendants' Fifth Report - 3/09
Defendants' Sixth Report - 5/09
Defendants' Seventh Report - 7/09
Defendants' Eighth Report - 9/09
Defendants' Ninth Report - 12/09
Defendants' Ninth Supplemental Report 2/10
Defendants' Tenth Report - 5/10
Defs' Tenth Report Exhibit 1
Defs' Tenth Report Exhibit 2Defendants' Eleventh Report - 6/10
Defendants' Status Report on Crisis Stabilization 6/10
Defendants' Twelfth Report 11/10
Defs' 12th report - Exhibit 1
Defs' 12th report - Exhibit 2
Defs' 12th report - Exhibit 3
Defs' 12th report - Exhibit 4
Defendants' Thirteenth Report 5/11Defendants' Fourteenth Report - 1/12
Defendants' Fifteenth Report - 5/12Defs' 14th Report - Exhibit 1
Defs' 14th Report - Exhibit 6
Defs' 14th Report - Exhibit 9
Defs' 14th Report - Exhibit 11Defendants' Sixteenth Report 12/12Defendants' Seventeenth Report 5/13
Defs' 19th Report - Exhibit A
Defs' 19th Report - Exhibit BDefendants' 20th Report - 6/14Defendants' 21st Report - 9/14Defendants' 22nd Report - 12/14Defendants' 23rd Report - 5/15Defendants' 24th Report 9/15Plaintiffs' Reports on StatusPlaintiffs’ First Report - 7/07
Plaintiffs’ Second Report - 10/07
Plaintiffs’ Third Report - 12/07
Plaintiffs' Fourth Report - 3/08
Plaintiffs' Fifth Report - 6/08
Plaintiffs' Sixth Report - 10/08
Plaintiffs' Supplemental Sixth Report - 11/08
Plaintiffs' Seventh Report - 12/08
Plaintiffs' Eighth Report - 4/09
Plaintiffs' Ninth Report - 5/09
Plaintiffs' Tenth Report - 7/09
Plaintiffs' Eleventh Report - 9/09
Plaintiffs' Twelfth Report - 12/09
Plaintiffs' Twelfth Supplemental Report - 2/10
Plaintiffs' Thirteenth Report - 5/10
Plaintiffs' Fourteenth Report - 6/10
Plaintiffs' Fifteenth Report - 1/11
Plaintiffs' Sixteenth Report - 6/11
Plaintiffs' Seventeenth Report - 1/12
Plaintiffs' Eighteenth Report - 6/12
Plaintiffs' Twentieth Report - 6/13
Plaintiffs' Twenty-first Report - 9/13
Plaintiffs' Twenty-second Report - 12/13
Plaintiffs' Twenty-third Report 3/13
Plaintiffs' Twenty-fourth Report 6/14
Plaintiffs' Twenty-fifth Report 9/14
Plaintiffs' Twenty-sixth Report 12/14
Plaintiffs' Twenty-seventh Report 5/15Plaintiffs' Twenty-eighth Report 9/15
Plaintiffs' Twenty-ninth Report - 12/7/15
Plaintiffs' Thirtieth Report - 2/29/16
Exhibit 2 - Plaintiff’s Summary of Remaining Disengagement Criteria and Proposed Outcome Measures
Plaintiffs' Thirty-fourth Report - 9/22/17Exhibit 3 - Massachusetts Practice Review Protocol Practice Indicators and Ratings Scales
Screening
Medicaid manual – EPSDT requirements
Massachusetts regulations – revised (2007)
Massachusetts screening procedures – revised Appendix W (2007)
Massachusetts billing procedures – revised Appendix Z (2007)
MassHealth transmittal letter (2007)
State Agency Protocols
Department of Children and Families (DCF)
Department of Developmental Services (DDS)
Department of Mental Health (DMH)
Department of Public Health (DPH)
System Design
Utilization Management
Service Utilization Parameters
Questions and Answers
Core Components of Home-Based Services for Children
Evaluating the Need for Home-Based Services for Children
Home-Based Services in Selected States
Rosie D. v. Romney - Plaintiffs' Final Remedial Plan Appendix
Using Home-Based Remedial in Other States
Using Medicaid to Obtain Home-Based Services for Children with SED
Press Coverage
EPSDT
Medicaid Act – federal statutes
Federal regulations
Massachusetts regulations
Medical Necessity
Memorandum and Case List (2002)
Memo to SAMHSA - Medical necessity under the EPSDT program: when is coverage required? (2002)
NHeLP Advocate's Guide to the Medicaid Program
(available for purchase)Juvenile Justice
NHeLP EPSDT Case Dockets and DevelopmentsGeneral 7/07
Mental and Behavioral Health7/04
Home-Based Services - Massachusetts
Report on home-based services in Massachusetts (2005)
MHSPY Massachusetts – covered services (2004)
Home-Based Services – Other States
Arizona – J.K.
Questions and Answers:
Legal Advocacy Network
Rosie D. Advocacy Training (powerpoint presentation)
Miscellaneous
Report of the Governor’s Commission on Children’s Mental Health (2005)
Center for Public Representation
22 Green Street, Northampton, MA 
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