CSR Update & Call for Public Participation
The Department of Mental Health (DMH) is proposing changes to the Code of State Regulations (CSR) governing the Self-Directed Services (SDS) program and is seeking public input.
We strongly encourage everyone to register for and attend at least one of the public comment sessions listed below. Showing up in numbers matters, and these sessions are an opportunity to put our concerns on the record.
Public Comment Sessions (Register to Attend)
- January 30 at 1:00 PM https://events.gcc.teams.microsoft.com/event/48dcec96-d99d-43f0-a037-31ce540eb927@831ecdf9-06f4-49a9-9b3e-32a7eac7ca52
- February 2 at 11:00 AM https://events.gcc.teams.microsoft.com/event/85b5d001-876b-42d2-b3d8-949793f59519@831ecdf9-06f4-49a9-9b3e-32a7eac7ca52
- February 5 at 5:30 PM https://events.gcc.teams.microsoft.com/event/2e632dd0-2d45-414e-8216-4e1344bae123@831ecdf9-06f4-49a9-9b3e-32a7eac7ca52
Background on the CSR Changes
The CSR (Code of State Regulations) for SDS establishes the rules DMH uses to operate the program.
- The current CSR language (in effect since 2020) can be found on page 10 here: https://www.sos.mo.gov/cmsimages/adrules/csr/current/9csr/9c45-3.pdf
- The proposed revised CSR is available here: https://dmh.mo.gov/media/pdf/9-csr-45-3080-self-directed-supports-0
Major Areas of Concern
1. New Employee Exclusions – Section (4)(B)3
The proposed CSR introduces new exclusion language that is not acceptable.
The new section would prohibit employment of:
“Any person with legal responsibilities recognized by a Court and/or Social Security and the equivalent thereof, including but not limited to Guardian, Conservator, Power of Attorney, Payee.”
This language is entirely new and significantly broader than the current rule, which only excludes legal guardians. These added exclusions would negatively impact many families who rely on trusted individuals to provide care.
2. Budget Calculation Changes – Section (17)
The proposed CSR also changes how SDS individual budgets are calculated.
New proposed language (Section 17):
“The SDS individual budget allocation shall be based on the total number of hours needed for the span dates of the [ISP] PCSP multiplied by the applicable service rate, as determined by appropriations received by the General Assembly.”
Current language (Section 16(A)):
“The SDS individual budget allocation shall be based on the total number of hours needed for the span dates of the ISP multiplied by the statewide base rate for comparable agency-based supports.”
This change shifts budget authority away from a consistent statewide standard and ties it directly to legislative appropriations, creating uncertainty and potential reductions in services.
What Has Not Changed
Aside from the issues noted above, the remainder of the CSR appears unchanged.
IMPORTANT: Prepare a Public Comment Statement
Please prepare a brief, specific statement explaining why these changes are not acceptable for your family.
Include real-world examples whenever possible.
After attending a public comment session, be ready to send your statement to: [email protected]
Setting Expectations
We want to be transparent: public comment is largely ceremonial, and the department is legally free to proceed as it chooses.
However, showing up in large numbers still matters. During COVID, this community’s participation was so strong that it overloaded the state’s virtual meeting system. Visibility and volume remain our strongest tools.
What’s Next
Our broader and ongoing effort focuses on proposed SDS budget cuts.
Please plan to attend our meeting next Monday to learn how you can help educate lawmakers and advocate for the value of the SDS program.
Thank You
This is a volunteer-driven community, and every call, email, meeting, and comment matters.
Thank you to everyone who has already contacted their elected leaders. Your efforts are sincerely appreciated.