Letter on Staffing and Completion of Outposted Therapeutic Housing Units

SUMMARY

The Corrections and Community Reentry Committee (Paul Montuori and Karen Adelman, Co-Chairs), along with the Civil Rights Committee (Evan Henley and Molly Thomas-Jensen, Co-Chairs), Mental Health Law Committee (Maia Goodell, Chair), and New York City Affairs Committee (Stephen E. Louis, Co-Chair) wrote to out-going Mayor Eric Adams and City Council Speaker Adrienne Adams to express support for the following efforts: (i) the staffing and opening of the completed 100 Outposted Therapeutic Housing Units (collectively, “OTHUs” and each, an “OTHU”) at Bellevue hospital; (ii) the realization of the Adams Administration’s commitment to construction of OTHUs that are currently fully-funded at Woodhull and North Central Bronx hospitals;  (iii) the expansion of this initiative to establish 1,500 secure treatment beds within the next three years; and (iv) implementation of policies that divert individuals suffering from serious mental illness, substance abuse, serious physical illness and intellectual and other developmental disabilities from the ill-suited, debilitating conditions of city jail facilities. The committees plan to follow up with the incoming administration and Council to ensure that these commitments are carried forward and that progress toward these goals remains a priority. 

REPORT

Hon. Eric Adams
Mayor of the City of New York
City Hall
New York, NY 10007

Hon. Adrienne E. Adams
Speaker of the New York City Council
City Hall
New York, NY 10007

RE: Staffing and Completion of Outposted Therapeutic Housing Units

Dear Mayor Adams and Speaker Adams:

The Corrections and Community Reentry Committee, along with the Civil Rights Committee, Mental Health Law Committee, and New York City Affairs Committee of the New York City Bar Association (“City Bar”) write to express our support for the following efforts: (i) the staffing and opening of the completed 100 Outposted Therapeutic Housing Units (collectively, “OTHUs” and each, an “OTHU”) at Bellevue hospital; (ii) the realization of the Adams Administration’s commitment to construction of OTHUs that are currently fully-funded at Woodhull and North Central Bronx hospitals;^[1] (iii) the expansion of this initiative to establish 1,500 secure treatment beds within the next three years; and (iv) implementation of policies that divert individuals suffering from serious mental illness, substance abuse, serious physical illness and intellectual and other developmental disabilities from the ill-suited, debilitating conditions of city jail facilities.

I.  BACKGROUND

The City’s jail population has complex treatment needs. According to the Mayor’s 2024 Management Report, 53% of people incarcerated on Rikers Island have a mental health diagnosis, and 20% have a serious mental health diagnosis.^[2] According to Correctional Health Services (“CHS”), around 40% of people admitted to Rikers self-report active use of illicit drugs and/or excessive drinking (such as six or more drinks per day). As a result, the City has pledged that approximately 20% of units in the borough-based jails will be therapeutic beds, and the current administration has reiterated the City’s commitment to OTHUs.

The promise of OTHUs and other secure treatment bed settings is in their potential (i) to increase access to care that is tailored to complex clinical needs, away from factors attendant in the jail setting that detract from such care, (ii) to reduce barriers to visitation, an essential component of support and rehabilitation, (iii) to reduce logistical burdens related to transport of patients to and from jails for care and to improve continuity and collaboration between CHS and NYC Health + Hospitals, and (iv) to reduce the need for therapeutic beds in the anticipated borough-based jails, among other benefits.

The City’s original pledge was to build 250 secure treatment beds. In 2021 that commitment was increased to 400 beds.^[3] In the intervening years, evidence has mounted to support the necessity of achieving swift completion of these units. Despite overall crime being down, violent incidents and disorderly conduct caused or exacerbated by the overwhelming lack of access to mental health interventions continue to occur.^[4]

Now, in 2025, construction of the first 100 beds at Bellevue is complete, but regrettably the unit remains unstaffed, and completion of the units at Woodhull and North Central Bronx is not anticipated until 2028.[5] The Department of Correction (“DOC”) has pointed to the New York State Commission of Correction as the source of this delay, however DOC has yet to submit a staffing plan to the state commission for approval.[6] It is within the Mayor’s power to direct DOC to submit the required staffing plan, and the Mayor must do so in order for the Bellevue units to open as soon as possible. Moreover, we urge the City to remain fully committed to expediting the completion of units at Woodhull and North Central Bronx hospitals. In tandem with efforts to address and prevent delays throughout the implementation of this policy, we also urge the City to assess potential strategies for expanding OTHUs and other secure treatment beds.  Such efforts are needed to effectively respond to ongoing challenges in accessing mental health services and enhancing the quality of care available to individuals in city jails who are most at risk.

The recent adoption of Local Law Int. 1242-2025 is a positive step in this direction and should be implemented without delay. This provision amends the City Charter to establish a “coordinator of the transition to borough-based jails and a department of correction coordinator for borough-based jail transition” whose responsibilities will include “coordinating actions and policies by agencies…including those with duties related to…design and construction of outposted therapeutic housing units[.]”[7]

II.  CITY BAR RECOMMENDATIONS

In view of these conditions, we urge the current administration and City Council to pursue the following efforts:

A.  Open Bellevue OTHUs by Spring 2026

This administration’s previously stated goal for completion of the Bellevue OTHUs was Spring 2025.^[8] These OTHUs are needed immediately and opening them by Spring 2026 will provide a critical release valve for patients, caregivers, and institutional and community stakeholders. Since the current administration and City Council agree that Rikers is not an appropriate environment for addressing the clinical needs of the most vulnerable,^[9] the Adams administration and City Council must prioritize this commitment and ensure that the Bellevue OTHUs are staffed and opened by Spring 2026 at the latest. It is within the power of the Adams administration to do so by directing DOC to submit its staffing plan to the state.

B.  Expedite Completion of North Central Bronx and Woodhull OTHUs

The North Central Bronx and Woodhull Hospital OTHUs are currently scheduled to open in 2028. That timeline should be expedited for the same reasons that opening the Bellevue OTHUs should be prioritized. These sites, like Bellevue, are prior commitments based on consensus agreements between policymakers and stakeholders. Geographic distribution of the OTHUs benefits the community. As of February 2025, together with Manhattan, the Bronx and Brooklyn accounted for 75% of the population at Rikers.[10] Accordingly, the Bronx and Brooklyn will especially benefit from having OTHU capacities functioning at the committed scale, promptly following the opening of the Bellevue units. As a preliminary step, the Adams Administration and City Council should ensure swift implementation of Int. 1242-2025 and appointment of the coordinator described therein to help mobilize and hasten these efforts.

C.  Expand Secure Treatment Beds To 1,500 Beds By 2028

By some estimates, as many as 63% of people with a history of mental illness incarcerated in state and federal facilities nationwide do not receive consistent and adequate treatment while incarcerated.^[11] That figure alone underscores the need to expand the City’s plans for secure treatment beds that can help address a broader range of serious treatment needs, including serious mental illness, behavioral health needs, drug and alcohol misuse, serious physical illnesses, and people with intellectual and other developmental disabilities.

When therapeutic beds are located in jail facilities, such as the 300 beds administered by the Program to Accelerate Clinical Effectiveness (“PACE”) at Rikers, there have been concrete signs of improvement.^[12] However, “[s]taffing is uneven and officers with specialized mental health training are not always assigned to the units” and, in May 2023, an incarcerated person committed suicide while housed in a PACE unit.^[13] As recently as August 2025, amid a rash of tragic deaths in Rikers custody, Ardit Billa died while housed in a PACE unit at Rikers.[14] Mr. Billa had previously been diagnosed with schizophrenia and was only 29 years old when he died.[15] These and other incidents have raised questions and serious doubts about whether the PACE beds at Rikers are providing the adequate environment or can even reach their potential in an environment like Rikers, and further underscore the need for the City to act quickly and move this care out of the jails.

Certain preliminary designs of borough-based jails place patients “in large-capacity, double-tiered units, which threaten to spread staff thin, make oversight much more challenging, and increase suicide risk[.]”[16] The City can and must do better – and the surest course is meeting the ambitious but necessary goal of reaching 1,500 secure treatment beds by 2028.

III.  ENHANCE EXISTING COMMITMENTS AND COMMIT ADDITIONAL FUNDING TO JUSTICE INVOLVED SUPPORTIVE HOUSING, DEPLOY INTENSIVE MOBILE TREATMENT AND FORENSIC ACT TEAMS AND IDENTIFY NEW AVENUES FOR DIVERSION FROM JAIL TO TREATMENT AND HOUSING

Ultimately, a multi-faceted approach is needed for the City to close down Rikers and reduce the jail population. The Adams Administration and City Council must enhance existing commitments and find new opportunities to divert people from city jails to services they direly need.

A.  Justice Involved Supportive Housing

The Adams Administration and the City Council agreed to allocate “$4.8 million to enhance the Justice Involved Supportive Housing RFP to fulfill the City’s previous commitment to create an additional 380 supportive housing units for individuals with justice system involvement” in the City’s Fiscal Year 2026 budget.^[17] The Adams Administration and City Council must now ensure that these funds are allocated as quickly as possible to realize these commitments.

B.  Intensive Mobile Treatment

Following the Comptroller’s February 2024 audit report on the Department of Health and Mental Hygiene’s (DOHMH) Intensive Mobile Treatment (“IMT”) program detailing shortcomings in monitoring and oversight, the Adams Administration and the City Council agreed to allocate “$11 million to support the expansion of teams that provide intensive and continuous mental health support and treatment to individuals in their communities” in the City’s Fiscal Year 2026 budget.^[18] The new funding is a positive step in the right direction, but the 2024 audit cited a lack of coordination between DOHMH and DOC, a lack of consistent treatment, inconsistent reporting and lack of performance metrics, and declining rates of housing stability.^[19] In addition to taking steps to place funds allocated in the Fiscal Year 2026 budget as soon as possible, the City Council should take a close look at addressing the systemic operational issues raised in the Comptroller’s February 2024 audit report.

C.  Forensic Assertive Community Treatment (FACT) Teams

Studies examining the impact of Forensic Assertive Community Treatment (“FACT”) teams, which include substance abuse specialists, housing specialists, and criminal justice specialists that provide the requisite level of care for this high-needs population, have shown reduced rates of recidivism.^[20]  Accordingly, the Fiscal Year 2026 budget’s allocation of “$4.5 million to expand specialized, mobile mental health teams that provide intensive, comprehensive support to individuals with severe mental illness” is a positive step.^[21]  In view of the vital and effective community support that FACT teams provide for people with serious mental illness who often cycle in and out of Rikers Island, it is imperative that the City place these funds as soon as possible in order to utilize these specialized personnel with the expertise to address this vulnerable population’s full panoply of needs.

We recognize that the current administration and City Council term are approaching their conclusion. Nevertheless, given the critical importance of these issues to the safety, health, and dignity of justice-involved individuals and the broader community, we believe it is essential to raise these concerns now. We hope to continue this dialogue with the incoming administration and Council to ensure that these commitments are carried forward and that progress toward these goals remains a priority.  We appreciate your consideration of these recommendations and would be happy to discuss how our organization can help the City swiftly and efficiently meet these important goals so as to create a safer and more just correctional system.

Respectfully,

Paul Montuori and Karen Adelman, Co-Chairs
Corrections and Community Reentry Committee   

Evan Henley and Molly Thomas-Jensen, Co-Chairs
Civil Rights Committee

Maia Goodell, Chair
Mental Health Law Committee

Stephen E. Louis, Co-Chair
New York City Affairs Committee