A final comment on SAMHSA's feedback site.
"The guidelines provide an excellent framework for beginning the assessment process for the development of an organizational change strategy to support a trauma informed approach. The key domains to be considered are very comprehensive and relevant. However, the focus is solely on assisting organizations to identify strengths and weakneses in order to provide milestones for measuring implementation progress. One key variable omitted is assessment of resources needed by an organization to do this. Domain # 9 references designing financing structures to support a trauma-informed approach which is absolutely critical. However, nowhere in the guidelines is there an acknowledgement that government funding streams are a major source of financing for many organizations and are not within their authority to redesign.
In addition, domain #7 assumes that cross-agency collaboration can be accomplished solely through cross-agency protocols without acknowledging funding requirements as well as legal and regulatory constraints that can sometimes inhibit cross-agency collaboration.
Clearly, SAMSHA is making an excellent contribution in assisting organizations to design a trauma-informed approach. Reference is made in the conclusion to the guidelines that they will serve to advance a common understanding of trauma across service sectors and provide a foundation for SAMSHA's efforts around training and technical assistance and development of a measurement strategy for trauma. To provide further assistance, it would be helpful if SAMSHA could assume a leadership role in collaboration with other federal agencies to promote cross-systems development of a trauma informed approach vis a vis federal policy and planning requirements and financing incentives to support state and, local efforts." - Betty Devine
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