Behavioral Health Services Act (BHSA)Public Comment
OFFICIAL AUDIT REPORT:
Behavioral Health Services Act (BHSA)Public Comment
Met with county leadership, including Behavioral Health Bureau Chief Melanie Rhodes.
Attempted to obtain legal assistance through multiple channels.
Contacted HUD regarding concerns surrounding housing practices and accessibility protections.
Continued pursuing corrections and amendments to my health records and HMIS documentation.
Worked with community organizations to secure housing stabilization resources and transition planning.
During this period, I have also experienced:
Continued refusal of reasonable accommodation requests.
Ongoing disputes regarding the accuracy of information contained in my records.
Abrupt loss of utilities that significantly impacted my ability to maintain stability.
An active eviction process despite my ongoing efforts to secure housing and services.
Significant emotional and mental health impacts resulting from prolonged instability and uncertainty.
I remain deeply concerned about how individuals experiencing mental health challenges, housing instability, and system involvement can become increasingly destabilized while attempting to advocate for themselves.
My experience has raised broader questions regarding:
Accessibility and transparency of records correction processes.
The handling of reasonable accommodation requests.
The impact of inaccurate documentation on future housing opportunities.
The coordination between behavioral health, housing, and supportive service systems.
Whether current systems adequately protect individuals during periods of acute vulnerability.
EXECUTIVE SUMMARY
This packet documents systemic failures, retaliation, fabricated records, fraudulent billing, denial of services, ignored medical and VAWA protections, and obstruction of oversight across multiple agencies within Monterey County’s behavioralhealth and homelessservices systems.
The evidence demonstrates:
A coordinated pattern of retaliatory narrativebuilding
Backdated documentation used to justify withholding services
Fraudulent billing for services never provided
Ignored medicalnecessity relocation requests
Ignored VAWA protections
Misclassification to avoid legal obligations
Denial of PSH supportive services
Disruption of MediCal continuity
Eviction based on falsified ledgers
Obstruction of all oversight pathways
These failures resulted in:
A full year with no supportive services
Loss of medical continuity
A 10mile walk in 90degree heat while septic
Forced relocation to another county to access care
Ongoing eviction proceedings based on fabricated financial data
This packet provides a comprehensive record for attorneys, investigators, and oversight bodies.
CHRONOLOGY OF EVENTS
A structured timeline of key events, showing escalation, retaliation, and systemic breakdown.
2022–2024
No toxicology testing except two emergency hospital visits for infections.
No evidence of opioid use.
Staff begin circulating fabricated allegations based solely on “observations.”
2025
Refused blood work and toxicology testing.
Nurse practitioner Janyce Berg bills for services not provided.
Fraudulent billing for medication support despite no medications prescribed.
False allegations of heroin use with no evidence.
Backdated notes created to justify withholding services.
Interim closes case without transfer of care.
A full year with no supportive services.
2025–2026
Multiple grievances filed with QI, Interim, CCAH, and 504 Coordinator.
All grievances ignored or used to reinforce negative narrative.
Misconduct report mishandled; misclassified as “witness” to avoid VAWA obligations.
Medicalnecessity relocation request ignored for nearly 3 months.
VAWA protection request ignored.
Eviction initiated based on falsified ledger balances.
Requests to meet with CoC Board, BH Advisory Board, Interim leadership, and County leadership ignored.
FINDINGS OF FACT
These findings are supported by documentation, grievances, medical records, and agency behavior.
1. Fabricated allegations were created and backdated.
2. No toxicology evidence exists to support substanceuse claims.
3. Nurse practitioner billed for services not provided.
4. PSH supportive services were withheld for a full year.
5. Medicalnecessity relocation request was ignored.
6. VAWA protections were ignored.
7. Misclassification was used to avoid legal obligations.
8. Eviction is based on falsified financial records.
9. All oversight pathways were obstructed.
10. Harm resulted directly from these failures.
SYSTEMIC FAILURES
These failures are not isolated; they represent structural breakdowns across multiple agencies.
A. Documentation and RecordKeeping Failures
Backdated notes
Shadow files
Missing HMIS entries
Contradictory internal spreadsheets
B. Clinical and Ethical Failures
False allegations
No assessments
No medication monitoring
No case management
C. Administrative and Governance Failures
Ignored grievances
Ignored oversight requests
No response from leadership
D. Legal and Compliance Failures
Ignored VAWA protections
Ignored ADA/504 obligations
Ignored medicalnecessity documentation
Fraudulent billing
E. Housing and PSH Failures
Denial of stabilization
Denial of transportation
Denial of documentation
Eviction based on fabricated data
VIOLATIONS OF LAW AND POLICY
This packet documents potential violations of:
VAWA (Violence Against Women Act)
ADA/504
MediCal medicalnecessity standards
HUD PSH program requirements
BHSA transparency and oversight requirements
Federal fraud and abuse statutes
State clinical documentation standards
CoC governance requirements
FULL SECTION INTEGRATION
1. INITIAL FAILURES
Documented failures in early engagement, including refusal to conduct assessments, refusal to provide documentation, and early narrativebuilding unsupported by evidence.
2. DOCUMENTATION GAPS
Missing HMIS entries, missing case notes, contradictory internal spreadsheets, and refusal to provide required documentation.
3. TIMELINE BREAKS
Critical breaks in the timeline, including October 2024, where documentation abruptly shifts to fabricated narratives.
4. WITHHELD SERVICES
Supportive services, case management, transportation, and stabilization withheld without justification.
5. MEDICAL HARM
Medical neglect resulting in a 10mile walk in 90degree heat while septic, loss of continuity of care, and delayed treatment.
6. LOSS OF MEDICAL
Failure to transfer MediCal, refusal to coordinate care, and administrative obstruction resulting in loss of coverage.
7. DENIAL OF TRANSPORTATION
Repeated denial of transportation despite medical necessity and program obligations.
8. RETALIATORY CONDUCT
Escalating retaliation following grievances and misconduct reports.
9. FABRICATED ALLEGATIONS
False claims of substance use, behavioral instability, and refusal of care, unsupported by any evidence.
10. BACKDATED RECORDS
Documentation created after the fact to justify withholding services and support fabricated narratives.
11. FRAUDULENT BILLING
Billing for services not provided, including case management, medication support, and clinical contacts.
12. DENIAL OF PSH SERVICES
Failure to provide required supportive services under PSH program standards.
13. IGNORED GRIEVANCES
More than ten grievances were filed across QI, Interim, CCAH, and the County’s 504 office. None were resolved. Many were ignored. Some were used to reinforce negative narratives. No corrective action was taken. No findings were issued. No documentation was provided. This represents a complete breakdown in grievance handling.
14. FABRICATED CLINICAL ALLEGATIONS
Staff circulated claims of heroin use, instability, and refusal of care without any evidence. No toxicology tests. No assessments. No clinical basis. Allegations were based solely on “observations,” which contradict medical records, hospital records, and toxicology results from emergency visits.
15. MISUSE OF LEVEL OF CARE (LOC) SCORE
The LOC score was manipulated to justify withholding services. No assessment was conducted. No documentation supports the score assigned. The score contradicts medical records, functional needs, and PSH program requirements.
16. CROSSSYSTEM FABRICATION
False allegations were shared across Interim, CCAH, QI, and County Behavioral Health. These allegations were used to deny services, block care, justify eviction, and undermine credibility. No evidence supports the allegations. Documentation contradicts them.
17. IMPACT OF FABRICATIONS
Fabricated allegations resulted in denial of services, loss of MediCal, medical harm, eviction
proceedings, and obstruction of care. These fabrications directly contributed to instability, medical deterioration, and systemic harm.
18. NO TOXICOLOGY EVIDENCE
No toxicology evidence exists to support any substanceuse allegations. Two emergency hospital visits for infections included toxicology testing — both negative. No other tests were conducted. Allegations were fabricated.
19. FRAUDULENT BILLING
Nurse practitioner billed for services not provided, including medication support, clinical assessments, and case management. No medications were prescribed. No assessments were conducted. Billing constitutes fraud.
20. ONE YEAR WITH NO SUPPORTIVE SERVICES
After closing out with Interim in April 2025, no supportive services were provided for a full year. No case management. No medication support. No stabilization. No transportation. No documentation. Despite this, staff documented “refusal of care,” which is contradicted by the fact that care was successfully established in another county.
21. RETALIATORY NARRATIVEBUILDING
Grievances and misconduct reports triggered retaliation. Staff escalated negative narratives, withheld services, and circulated false allegations. The County’s 504 Coordinator relayed information to program leadership instead of protecting rights. Misconduct reports were mishandled and used against the reporting party.
22. IGNORED MEDICAL & VAWA REQUESTS
A medicalnecessity relocation request from a treating physician was ignored for nearly three months. A VAWA protection request was ignored entirely. Despite pending protections, eviction proceedings continued. Ledger balances used for eviction were falsified.
23. MISCLASSIFICATION TO AVOID VAWA OBLIGATIONS
The County and Interim misclassified the reporting party as a “witness” instead of a victim to avoid triggering VAWA protections. This misclassification was used to avoid safety accommodations, documentation requirements, and nonretaliation obligations. It also allowed the County to continue adverse actions.
24. OBSTRUCTION OF OVERSIGHT
Requests to meet with the CoC Board, Behavioral Health Advisory Board, Interim leadership, and County leadership were ignored. No meetings were scheduled. No responses were provided. Oversight pathways were deliberately blocked. This prevented grievances, safety concerns, and systemic failures from being reviewed.
25. IGNORED REQUESTS TO MEET WITH LEADERSHIP
Direct requests to meet with the Executive Director of Interim, the Assistant Director, Melody Rhodes, and Phillip Shepherd were ignored. No responses were provided. No followup occurred. This represents a failure of leadership and governance.
VIOLATIONS OF LAW AND POLICY
The documented conduct constitutes potential violations of:
VAWA (Violence Against Women Act)
Failure to provide protections, safety accommodations, written responses, or nonretaliation safeguards.
ADA/504
Failure to provide accommodations, mishandling of grievances, conflict of interest by 504 Coordinator, and denial of access to services.
MediCal Medical Necessity Standards
Ignoring physician documentation, failing to coordinate care, and obstructing continuity of care.
HUD PSH Program Requirements
Withholding supportive services, failing to provide stabilization, and retaliatory conduct.
BHSA Transparency and Oversight Requirements
Ignoring publiccomment requests, refusing to schedule meetings, and obstructing oversight.
Federal Fraud and Abuse Statutes
Billing for services not provided, falsified documentation, and fabricated clinical notes.
State Clinical Documentation Standards
Backdated notes, missing records, contradictory entries, and fabricated allegations.
CoC Governance Requirements
Failure to respond to public concerns, failure to provide access to the Board, and failure to review grievances.
CLOSING STATEMENT
This packet documents a pattern of systemic failures, retaliation, fabricated records, fraudulent billing, denial of services, ignored medical and VAWA protections, and obstruction of oversight across multiple agencies. These failures caused direct harm, including medical deterioration, loss of services, and eviction proceedings based on falsified data. The evidence supports the need for immediate corrective action, investigation, and oversight.
Addendum to Behavioral Health Services Act (BHSA) Public Comment
Submitted by: Vincent Garcia Cardoza
Date: June 2026
I submitted my original public comment during the Behavioral Health Services Act (BHSA) planning process to document concerns regarding my experiences within Monterey County's behavioral health, housing, and supportive service systems. Since that submission, the circumstances I described have not improved. In many respects, they have escalated significantly.
I submit this addendum because I believe my experience raises important questions about autonomy, informed consent, housing stability, record accuracy, and the ability of individuals experiencing mental health challenges to meaningfully participate in decisions affecting their lives.
Continued Housing Instability and Eviction
Since my original comments, I have been subjected to ongoing housing instability and am now involved in active eviction proceedings.
This has occurred despite repeated attempts to advocate for myself, secure reasonable accommodations, and work collaboratively with multiple agencies regarding my housing needs and transition planning.
The uncertainty surrounding my housing has had a profound impact on my mental and emotional well-being. I have spent months attempting to stabilize my situation while simultaneously navigating multiple systems and responding to ongoing crises.
At one point during this process, my electricity was abruptly disconnected for approximately two days. As a result, I lost food, experienced significant disruption to my daily life, and was left without reliable means of communication because I no longer had a working phone. I was forced to resolve the situation independently despite being enrolled in services intended to support individuals with significant mental health needs.
Experiences like this raise important questions about what meaningful support and stabilization actually look like in practice.
Refusal of Reasonable Accommodations and Concerns Regarding Autonomy Throughout this process, I have repeatedly attempted to advocate for accommodations and to participate meaningfully in decisions affecting my life and care.My concerns have never centered on refusing help simply for the sake of refusing help. My concerns have consistently centered on:
autonomy and self-determination;informed consent;accurate information and documentation;maningful participation in decisions affecting my care and housing; and the ability to disagree with recommendations without being viewed as noncompliant or incapable.
I have increasingly felt that my attempts to advocate for myself have been interpreted as resistance rather than participation.
The ability to disagree, ask questions, or seek clarification should not result in individuals feeling as though their autonomy is being diminished or their concerns are being dismissed.
Concerns Regarding Health Records and HMIS Documentation
I continue to have serious concerns regarding the accuracy of information contained within my records.
My records contain allegations regarding substance use and conduct that I dispute. To my knowledge, these allegations were not supported by objective evidence such as toxicology testing, blood work, police reports, or criminal findings.
Despite my attempts to address these concerns, I have experienced significant difficulty in obtaining meaningful review of my records and pursuing amendments.
I was provided access to my records and instructed to identify inaccuracies. After spending considerable time reviewing those records and preparing amendment requests, I was subsequently informed that I would need to complete additional forms and follow a different process.
I have repeatedly requested assistance understanding and navigating the amendment process, including opportunities to review records with staff. I have not felt adequately supported in that process.
Additionally, I requested that a personal statement disputing certain information be added to my HMIS record. I was informed that this would not be accommodated.I remain deeply concerned about the long-term impact that inaccurate or disputed information may have on future housing opportunities and service access
.
During my review of my HMIS record, I observed extensive activity associated with my file and remain concerned about the accuracy and handling of information maintained within these systems.
Advocacy and Oversight Efforts
Since submitting my original public comment, I have undertaken extensive efforts to seek resolution and accountability, including:
Meeting with Behavioral Health Bureau Chief Melanie Rhodes;
Engaging with county leadership and city officials;
Contacting HUD regarding housing-related concerns;
Seeking legal assistance through multiple avenues;
Filing and pursuing complaints with various oversight bodies;
Continuing to request clarification, records, and opportunities for review and resolution.
I have made these efforts because I believe transparency and accountability are essential components of effective behavioral health systems.
No individual should have to navigate multiple agencies and oversight entities simply to understand decisions being made about their life, records, and housing.
Emotional and Mental Health Impact
The cumulative impact of these experiences has been significant.
The prolonged uncertainty regarding housing, the inability to resolve concerns about records, the ongoing disputes regarding services, and the feeling of being unheard within systems intended to provide support have all contributed to substantial emotional distress.
I have often felt as though I have been required to expend extraordinary amounts of energy simply to maintain stability while simultaneously attempting to advocate for myself.
Individuals experiencing mental health challenges are frequently asked to navigate complex systems during periods of profound vulnerability. My experience has demonstrated how difficult and destabilizing that process can become when communication breaks down, concerns remain unresolved, and trust deteriorates.
Broader Systemic Questions
I respectfully ask that my experience be considered within the broader context of BHSA implementation and system planning.
My experience raises questions regarding:
How client autonomy and informed consent are protected.
How disagreements between clients and providers are navigated.
How individuals can meaningfully participate in decisions affecting their lives.
How records disputes and amendment requests are handled.
How housing instability and behavioral health needs intersect.
How systems respond when individuals report feeling unheard or unsafe.
Whether existing processes adequately protect vulnerable individuals from becoming further destabilized while attempting to seek help.
Closing Statement
I recognize that my experience represents only one perspective.
However, I also recognize that systems improve when individuals are able to speak honestly about where they have struggled and where they believe change is neede I submit this addendum not only to document my own experience, but in the hope that future planning efforts continue to prioritize dignity, transparency, meaningful participation, and the right of individuals to retain autonomy and voice within the systems intended to support them.