CFA Counselor’s Committee Response to the CSU Select Committee Mental Health Report

CFA applauds the work that is being done on all 23 CSU campuses by the counselor faculty who work diligently despite budgetary constraints and furloughs to meet the mental health needs of the students on their individual campuses. CFA enthusiastically supports the counselor faculty in their dedication to promote student well being and support students’ mental and emotional health while they are engaged in meeting their academic goals.

CFA’s Counselor Committee wants to respond to the Report from the Chancellor’s Select Committee on Mental Health and make certain that all voices are heard in the review of what students need regarding mental health services on the CSU campuses. The Committee made eight recommendations after reviewing literature and conducting surveys of CSU administrators of counseling centers, health centers, and disability services. However, the committee did not directly survey counselors, students or parents and held no public meetings for comments by faculty, students or parents.

We are aware that the implementation committee has been formed and is meeting. We believe strongly that without student and faculty counselor participation the recommendations will be guided by a management analysis that is missing the voice of the consumers and the professional providers who are engaged daily in helping students and managing the complexities of providing mental health services within a college setting.
To further the goal of assessing and planning for the mental health needs of CSU students, CFA urges the Board of Trustees to: 1) appoint more counselors from the 23 campuses to the implementation committee and 2) require the committee to hold meetings for public comment or presentations from faculty, students and parents prior to issuing any further recommendations.

The Counselors Committee of CFA believes that the recommendation regarding creating an executive order for CSU Mental Health Services is a constructive objective that can delineate to CSU students and their parents what they can expect from campus mental health services and what the cost will be to the students for these services. The SCMH report also included an extensive literature review of national trends and a useful discussion about the various challenges for counseling centers within the CSU system, which provided a partial context for understanding the needs of students.

We are in agreement that general system-wide guidelines defining basic services and funding sources as well as outlining appropriate counselor and psychiatrist-to-student ratios, and outlining best practices for coordination of emergency services and referral systems, record keeping, and internal and external reviews will create a baseline that all campuses must satisfy. However due to the differences of the size and the variety of settings of the 23 CSU campuses, we believe that each campus community and counseling center can best define the most effective delivery modes, staffing needs, and
coordination efforts with the various departments on their individual campuses and that these are not areas that should be structured or mandated system wide.

We were specifically concerned about three aspects of the report: (1) data collection and averaging, (2) funding and its impact on counselor and psychiatrist ratios, and (3) counselor duties and the committee’s narrow definition of productivity. Before responding specifically to the 8 recommendations we want to address three specific areas within the report that were particularly troublesome:

  1. Data Collection and averaging: While the report refers to the significant amount of data compiled in the various surveys undertaken by the SCMH, we were troubled that the surveys were not included in an appendix to the report so that the public could understand how the data were collected and condensed. As stated earlier we were troubled that no information was sought from students or parents regarding their perceptions of mental health needs. Conducting a needs assessment on students without actually polling students or a majority of those directly administering the mental health needs of students (i.e. CSU Counselor Faculty) suggests results that are untrustworthy. The data in the report from 23 CSU campuses were blended and averaged, yet mathematically averaging data from systems of different sizes makes the average not a meaningful number for planning purposes. To find relevant information that helps you understand the systems you are addressing, you need to measure systems of equal size and complexity. One of the more valuable statistical reports missing from the select committee data is a campus-by-campus counselor-to- student ratio that would provide a system-wide breakdown of Counseling Center Professional FTE. A table of this kind would be one clear illustration of what the counselor staffing is at the present time and how it compares and contrasts with the recommended norms for counselor-to-student ratios at other public universities with similar student populations. Utilizing averages across such varied campuses and defining counselor productivity by a singular factor (one-on-one clinical sessions) led to recommendations that frankly misinterpreted the complexity of the counselor role on each of our campuses.
  2. Funding and its impact on counselors numbers and productivity: When reporting about the funding for CSU counseling centers and mental health services no specific description of how the 23 centers are presently funded was included, nor was information given about budget increases or decreases at the 23 centers and the impact of any budgetary decreases (including the furloughs in AY 2009-10) on the services that were being provided. The report summary states that CSU centers employ 15% less staff per student than the average four-year public university. Again using an average number obscures how having fewer staff impacts campuses with larger student populations. However it is clear the difference in the percentage of students seen at CSU campuses is connected to the 15% difference in the number of counselors available to see students and most likely accounts for the difference in the percentage of the average number of students at CSU campuses of 5% compared to the average four-year public university of 8%. Additionally the report states the staffing levels recommended by IACS is 1 counselor for every 1500 students and that the national norm of 4 year public institutions is 1:2607 while the average across the CSU campuses is 1:2933. The SCMH report admits this average is misleading since the campus student populations vary greatly, but does not present each campus statistic. However, this average number is distressing because it puts some individual CSU campuses at several times over the level of counselor to student ratio that is recommended, which of course leads to increases in waiting time for students and thus increased risk for students in distress and increased liability risks to the center and the university. Despite these concerns, the committee made no direct recommendations to increase staff sizes or to demand the centers to set goals to meet IACS standards. Additionally the committee reports that there has been a dramatic increase in “students coming to health centers for psychiatric purposes”, but makes no direct recommendations regarding the numbers of psychiatrists needed to meet this increase in demand for service, nor makes recommendations on positing required psychiatrist-to-student ratios.

    Despite lightly mentioning economic conditions for funding nationwide, briefly mentioning increasing and adding to the dramatic rise in student fees, and hardly mentioning the significant impact of the present budgetary conditions on the CSU, the committee report did not make any constructive proposals from a system wide perspective to allocate resources that would guarantee appropriate staffing levels in all aspects of mental health services and thus adequately support the basic services proposed in SCMH Recommendation 1.
  3. Counselors duties and the narrow definition of productivity (e.g. direct service): The SCMH first recommendation includes five areas of basic services counseling centers are charged to provide with the possibility of augmented services, these include: (1) Counseling/psychotherapy, (2) Emergency Crisis, (3) Outreach, (4) Consultation, and (5) Referral. Fulfilling these services and perhaps some augmented services will undoubtedly vary depending on the needs of the unique CSU campus communities. We would like to point out that nowhere in the executive order for Health Services is there a commentary or directive on how the doctors, nurses and other staff should practice medicine or how they are to deliver the basic services they are charged with.

    The model of productivity in the report seemed extremely narrow and appeared to be based on a conceptual framework that missed the complexity of how mental health services, including prevention, are delivered on the 23 campuses. Utilizing averages across such 23 widely diverse campuses and defining counselor productivity by a single factor (one-on-one clinical sessions) led to recommendations that did not accurately characterize the specifics of the counselor role on our campuses and the role of counseling services as described in the Accreditation Association for University and College Counseling Services.

    We want to particularly call attention to the focus on counselor productivity with the narrow, singular lens of individual face-to-face sessions and average numbers of clients seen per day. Despite recognizing the need for different approaches that are necessary to meet a variety of students needs, it appears the SCMH found no way to assess productivity of the other essential duties included in the basic services they endorse. Did they ask directors and counselors to quantify contact with emergency responses to individuals and groups, group therapy, outreach and prevention efforts, workshops presented, and consultation about students with parents, faculty, administrators, and other on-campus professionals? These are all essential services that provide support, build on prevention, help ensure retention, and provide necessary mental health information to and for students on a daily basis, but the report did not include data outlining the hours per day that counselors are involved in providing these services. All of these areas must be part of the picture of counselor productivity and how a center and the individuals within it are evaluated for their effectiveness in meeting student needs.

Please find below the specific comments on each recommendation.

Recommendation 1: Develop an Executive Order for Counseling Centers

We would amend this recommendation to read “Develop a Policy on University Mental Health Services” and believe the policy should clearly state what services students should expect and what additional services campuses should strive to augment.

We support this recommendation with the condition that the policy is drafted by a committee with majority representation of campus mental health providers (counselors and psychiatrists) as well the directors of the 23 counseling centers and is sent for review to all CSU Directors of Counseling and Psychological Services and other stakeholders for comments and suggestions prior to completion and execution.

Regarding recommendation 1, III, Augmented services, the counselors committee was unclear about the stipulation requiring the President of each respective campus to grant approval to authorize services for family members or student’s partners in providing augmented services. Presently clinical judgment by licensed mental health professionals guide counseling services in day-to-day decisions when it is necessary to involve family or partners with students who are being seen for crisis or on-going mental health needs. To provide the highest level of professional care, the ability to involve family as needed is imperative and these decisions should be considered clinical not administrative.

Regarding recommendation 1, IV, Qualifications, the counselors committee wanted to highlight that maintaining licensure requirements also require reciprocal insurance of funding by the CSU for mandatory license fees, for mandatory continuing education training, and for much needed conference participation that has been dramatically eliminated from several CSU counselor faculty as critical areas to support by the administration.

Recommendation 2: Provide Adequate Resources for Basic Services

The main objectives in providing adequate resources on all campuses should be to guarantee all funds allocated for mental health basic services will be used for direct service students and to increase faculty counselor ratios to be in compliance with nationally recognized standards.

Additionally, adequate funding for basic services should include psychiatry. The need for psychiatric care has been demonstrated system wide and more serious mental health issues are often best served with the additional expertise regarding medication treatment alternatives that psychiatrists offer.

Funding for data analysis and equipping all centers with electronic medical record keeping systems should be secured from chancellor’s office and be provided over and above the funding needed for direct services.

In response to stipulation of trainings mandated and selected by the MHSC, we believe these trainings should be selected by mental health professionals in accordance with state licensure requirements based on needs seen by mental health professionals, not the SCMH.

Recommendation 3: Review the Classification and Bargaining Unit Placement of CSU Mental Health Counselors

The Counselor’s Committee of CFA emphatically rejects this recommendation because a revision of the SSP-AR classification is not desirable and a change in the bargaining unit placement of this classification is not even possible, let alone desireable.

The characteristics and job descriptions of the SSP-AR categories are consistent with the International Association of Counseling Services accreditation standards for college counseling centers including the expectation that “the professional staff members be accorded the rights and privileges consistent with university or college faculty”. There is nothing to indicate that the SSP-AR classification in anyway hinders counselor faculty from being successful in their work meeting student’s mental health needs on campuses or being part of implementing new strategies around crisis response or wellness education within counseling centers. On the contrary: Our faculty counselor classification enhances and empowers our ability to meet the mental health needs of our CSU students.

The systemwide Collective Bargaining Agreement (“CBA”) and campus-specific shared governance structures outline and create procedures and criteria for retention, tenure and promotion. The various committees on each campus, along with the counseling center directors, are in the strongest position to assess what, if any, changes in these procedures and criteria would improve the focus of the counselors’ professional efforts to respond to the clinical mental health needs on each particular campus. Collective bargaining and shared governance, respectively, will control the implementation of any such changes.

Moreover, contrary to the suggestion to “review . . . the bargaining unit placement of CSU mental health counselors,” under applicable PERB regulations, the placement of CSU mental health counselors in Unit 3 could not be changed absent agreement by CFA to do so unless these classifications were (a) “management, supervisory, confidential, not covered by . . . HEERA, or otherwise prohibited by statute from inclusion in the unit,” (b) “[t]o make technical changes to clarify or update the unit description,” or © “[t]o resolve a dispute as to unit placement or designation of a new classification or position.” See PERB Regulation 32781. None of these conditions are met, and CFA will vigorously oppose the disenfranchisement of counselors by removing them from Unit 3.

CFA notes that Article 1.7 of the CBA provides for the “develop[ment] and implement[ation] of a “new Unit 3 SSP-AR Trainee classification” and states: “CFA shall be consulted at each state of the development process.” Certain aspects of the new classification, such as salary, are – independently of the contract language – within the scope of representation and therefore mandatory subjects of the meet and confer process. CFA briefly met with the administration in late 2008 to discuss these issues. However, letters from CFA to the administration commenting on aspects of the proposed classification(s) and reminding it of the need to meet and confer about salaries, dated March 23, 2009, May 11, 2009, and October 13, 2009, have remained unanswered. CFA intends to take up this issue again in bargaining about a successor CBA.

Recommendation 4: Require a Campus Review of Counseling Center Structure and Work Distribution

The CFA Counselor Committee believes this recommendation is redundant to Recommendation 1, Section V.(B). We strongly urge the Board of Trustees to include counselors and students in the design and creation of the categories for evaluation of the services provided by counselors and psychiatrists. These reviews should be based upon agreed constructs delineating all of the roles/responsibilities of CSU faculty counselors.

Including within the system wide executive order a recommendation for counseling centers to have a plan for program evaluation that includes both accountability data as well as program evaluation data seems sufficient to help each center improve it’s responsiveness to student needs without delineating from the Chancellor’s office how each center should organize counselors workloads.

Recommendation 5: Obtain Clarification Regarding Release of Student Health Information

In California the legal guidelines set forth by HIPPA, FERPA, and legal regulations for psychologists and other mental health providers protecting client privacy cannot be overridden by a directive by the Chancellor’s Office. A statement from the Chancellor’s Office outlining what is permissible by law for counselors to release and what is not permitted by law will assist the campus administrators, other faculty, parents and students in understanding the limits of what can shared by counselors regarding student mental health information.

Recommendation 6: Constitute an Implementation Committee

The CFA counselors committee objects to the proposed composition of the implementation committee. As proposed by the SCMH the implementation committee continues to be dominated by administrators who do not have mental health expertise. Creating a committee charged with addressing the mental health needs and not including a majority of mental health experts inclusive of both Counseling Center Directors with clinical psychological expertise as well as counselors presently working with students seems to ignore the fact that the CSU has within its employ leading experts in the field of college mental health services.

We are in agreement that the implementation should include representatives from other units that interface with students with mental health issues, such as university police, university housing, disability services, and veterans affairs.

Regarding the restructuring and the implementation of new procedures we were uncertain why this discussion was included under this section and will discuss the various proposals concerning restructuring in #7. However, the committee would like to comment on the statement on page 29, in Recommendation 6 that, “The MHSC also should examine alternative methods of service delivery, given that the traditional 50- minute, weekly, face-to-face session with students is taxing resources extraordinarily.” Clinical judgment based on the safety, needs, and welfare of our student clients are always of upmost concern and discretion in deciding how long and how often we handle a crisis or spend in session is a direct clinical issue and not an administrative one. Replacing clinical judgment of what is needed by mental health professionals with administrative policy by non-mental health professionals is the seed for increased liability, uncontrolled crisis, and increased unmet mental health needs of our students.

Recommendation 7: Structure and Coordinate Data Collection

Regarding the mission of the counseling centers, we believe insufficient information was included in the study about what the centers have been doing to fulfill their mission especially regarding how they are addressing the tasks of providing access to counseling services requested by students, crisis intervention, outreach/teaching, prevention and wellness services. No mention was made about how individual centers may have already adjusted their missions to deal with decreases in staffing and increase in demand. The committee focused almost exclusively on averaged numbers of counseling centers’ client sessions and did not include data about the range of other services provided by each center. This limited approach in the review of services seems to indicate some prior agenda of reorganization that was not outlined in the charge to the SCMH. Where is the data that illustrates what the centers have done to adjust their services to an increase in severity of student pathology, decreases in staff sizes, involvement on crisis intervention teams, creation of mental health screening and assessment programs, peer training programs, mental health education, and other creative programs including counseling center web pages and online mental health education and resource guides and information.
For example, the proposed common set of data points by MHSC is:

  1. % of students using services
  2. Average # of visits per student user
  3. # of clients each counselor sees per day
  4. # of attempted and completed suicides
  5. # of police transports
  6. # of Tarasoff notifications

However, the proposed stats fall short of the entire picture of roles/responsibilities of a Counselor in the CSU system in providing quality mental health care. To these ends, the roles and recommendations mentioned on page 45 of the MHSC report itself, in citation of Archer and Cooper (1998), include:

  1. Increased brief therapy
  2. Group therapy
  3. Coordination with other university departments
  4. Self-help material
  5. Medication as appropriate
  6. Outreach
  7. Consultation

We would add to these categories the following other areas of work performed by counselors on our CSU campuses that are not found on the SCMH stats display: (1) training of faculty to identify and refer students with emerging mental health issues, (2) inclusion of general case management, (3) consultation with parents and students by phone, and (4) time spent in the medication referral process. These items, as discussed in the SCMH report, delineate just some of the tasks of a university counselor that must be included in the proposed analysis. Further, it is the recommendation of this union committee that any input from both students and parents regarding mental health needs be included in the proposed collection of statistics across all 23 campuses.

Recommendation 8: Better Integrate Counseling Services with Other Campus Departments in an Effort to Promote Overall Wellness

After reading this recommendation, the CFA counselors committee wonders if the SCMH gathered data in their surveys that could have illustrated what is presently being done on the 23 campuses to promote overall wellness and integrating counseling services with other departments. As counselors from various campuses we are aware that partnerships already exist on many campuses and that counselors are already involved with veterans groups and foster youth as well as sororities, fraternities, housing programs, EOP programs, Active Mind student organizations, peer mentoring programs, women’s centers and pride centers on the various campuses, and working with students on retention issues through support groups and classes. Obviously tracking the programs and hours spent on the proactive services that are presently taking place on the CSU campuses would be the starting point to understanding how the integrated model of responding to students overall health, preventative mental health needs and students in distress can be enhanced to provide the most comprehensive care and services possible with the resources and funding provided.

In summary, the CFA counselor committee, not withstanding our objections to some of the SCMH recommendations, knows that the counselors are ready to work together with the SCMH to provide a more comprehensive review of what is being done on each campus. Counselors are committed to assist in identifying and delineating the mental health needs of today’s students and to continue to develop innovative and practical methods and partnerships to bring needed mental health services to the students within the CSU campus communities.