SAMHSA Disparity Impact Statement 

Development Guide

[1] 

The Disparity Impact Statement (DIS) Development Guide assists SAMHSA grantees in developing each 

subsection of the DIS. The Guide includes questions and examples to help grantees improve the quality and 

comprehensiveness of the DIS. Additionally, grantees can use the information, examples, and notes in this 

Guide to understand how their DIS will be evaluated by their GPO. The development and implementation 

of the DIS will require grantees to put in effort up front to create a quality DIS; however, this has the 

potential to position each grantee to make progress towards equity. 

SECTION 1 – Identifying Behavioral Health Disparities

☐ Submit a narrative that addresses the following: 

☐ Includes a clearly identified problem/gap/disparity you are seeking to address using this grant 

program (funding opportunity). 

☐ Includes clearly identified disparity-vulnerable populations - based on a racial, ethnic, sexual, or 

gender characteristic - that experiences disparate access, use, and/or outcomes related to the 

behavioral health focus of the grant.

Questions to Consider Examples/Tips

Have you identified a disparityvulnerable population that has 

different characteristics from the 

overall population that you serve? 

If your service area represents a homogeneous population 

(e.g., most people are of the same race/ethnicity), you

would still need to identify a population group within your

service population that has disparate access, use, or 

outcomes. For example, if your organization serves the 

Hispanic/Latino community, you could identify 

underserved groups within the community, such as sexual 

or gender minorities (e.g., female, or LGBTQ), or older 

residents) as the population of focus. 

If your organization is developing 

infrastructure/capacity or providing 

training and TA (i.e., not providing 

direct, client level services), have you

identified a disparity-vulnerable 

population related to those activities? 

In cases where your grant is not a services grant but rather 

a capacity-building/ r training and TA grant, you can still 

identify underserved racial, ethnic, sexual, or gender 

populations as a population of focus. 

Example: 

You might aim to develop infrastructure/capacity to 

address underage alcohol use.

You can compare rates of underage drinking among racial, 

ethnic, sexual, or gender population groups to identify 

which group(s) in the community have higher rates; i.e., 

experience disparities. You can use this information to 

decide how to focus the infrastructure development, TA 

and training activities so that they focus on those 

populations.
[2] 

Questions to Consider Examples/Tips

Example:

Grantees with capacity-building grants have often used 

the DIS to support the establishment of a peer led 

organization. You could conduct an environmental scan to 

understand the demographic make-up (racial, ethnic, 

sexual, gender) of the staff, board, and/or leadership of 

existing peer led organizations in the community. You may 

be able to identify underrepresented groups and then 

direct grant program efforts to help establish peer led 

organizations that reduce this disparity and increase the 

diversity of peer led organizations. 

In cases where your organization provides Training and

Technical Assistance (TA), you may consider how you can 

tailor trainings to be culturally informed, utilize trainers 

from the disparity-vulnerable community, and develop 

marketing and outreach strategies that are populationspecific.

Have you identified and described how 

the disparity-vulnerable population 

experiences differences in the ability to 

access and use health care resources or 

achieve health outcomes? 

You may identify structural barriers such as 

transportation, childcare, financial resources, availability 

of programs, etc. and cultural or ethnic-specific barriers 

such as language capacity of the system and the 

population, and cultural beliefs and values, and stigma. 

For a description of the transportation barrier, you might 

state that there are limited bus routes in a neighborhood 

where members of the population of focus reside and 

therefore this population has limited ability to access the 

program. 

Is it clear that every level is being 

considered, including client level, 

organization level, systemic level, or a 

combination of these? 

Explain who your organization serves based on data at the 

local level, county, and national levels. Provide 

information about the barriers at each level, which led to 

the stated disparity your organization is going to address.

Example: 

One barrier for this grantee is the lack of providers who 

speak Creole, and they serve a growing population of 

Haitian refugees. You can work with the state to increase 

recruitment, retention, and training of providers who 

speak Creole while working with local universities or 

hospitals that may have a translation service or staff who 

can be trained in medical interpretation for Creole 

speaking clients. 
[3] 

☐ References verifiable and reliable data sources as evidence to support the identified 

problem/gap/disparity.

Questions to Consider Examples/Notes

Are your organization’s data sources 

reliable and verifiable? Did the data 

come from one of the suggested 

sources provided in the examples? 

Examples of reliable and verifiable data sources: SAMHSA 

National Survey on Drug Use and Health (NSDUH); CDC 

and OMH Minority Health Social Vulnerability Index (SVI); 

CDC/ATSDR Social Vulnerability Index (SVI); CDC 

Behavioral Risk Factor Surveillance System and Youth Risk 

Behavioral Surveillance System; AHRQ National Healthcare 

Quality Disparities Report (NHQRDR); U.S. Census Bureau 

Data and American Community Survey (ACS); Federal 

Register Annual Update of the HHS Poverty Guidelines; 

CMS Informational Bulletin on 2022 Federal Poverty Level 

Standards; other federal, regional, state, county, tribal, or 

local level data. Also consider community data from 

hospitals, local clinics or other healthcare providers, 

nonprofit organizations, schools, and universities. 

PLEASE NOTE: You are also encouraged to use internal 

administrative and utilization data to help identify 

problems, gaps, or disparities. 

Are the data too broad or too specific 

to relate to the population of focus and 

how might that impact the identified 

disparity? 

You should use data to explain the challenges in the 

communities you are serving. Depending on the grant type 

(i.e., services, training/TA, capacity building), it may not be 

feasible to use national data. For example, an organization 

used data from an entire county that was not relevant to 

their specific geographical area. This resulted in the 

organization missing the disparate population that existed 

within the community they are serving. 

Have you used the most recent data 

available for that dataset? 

Datasets have different reporting cycles, sometimes 

annual, sometimes quarterly, others do real-time data 

reporting. Select the dataset most relevant for your grant.

If no data is referenced, did you 

describe your effort to find data? 

Your organization may not have relevant data if you are 

new or launching a demonstration project. In these cases, 

it is acceptable to create an activity that would allow you 

to collect the data. However, this should be used with 

caution if the organization is not new or launching a 

demonstration project. Organizations that have at least a 

two-year history are encouraged to review their internal 

utilization data. 

☐ Referenced data matches the data provided in the grant application. 
[4] 

☐ Submit a demographic table

Questions to Consider Examples/Notes

Have you included a table that includes

demographic details about the persons 

or organizations 

served/reached/trained by the grant 

that demonstrate the disparity at the 

individual/client, organizational, or 

systemic level presented by the grant 

reporting period (e.g., annually)?

You should indicate the actual or projected number of 

personsserved/reached/trained that were identified in your 

application broken out by demographic details.

You should provide information about the actual or

projected number of persons served during each grant 

reporting period (e.g., annually).

Be sure to state the disparity-vulnerable population as a 

percentage of the total population served by the grant.

Make sure the figures equal 100% in the table and match

the figures listed in the application.

SECTION 2 – Addressing Disparities Using the Funding Opportunity 

SOCIAL DETERMINANTS OF HEALTH (click here for more information on domains)

☐ Identify one or more SDOH domain(s) and related activities to address for the population of 

focus.

Questions to Consider Examples/Notes

What is the source of your information 

for identifying the SDOH? 

You should not make assumptions about the SDOH. Did you 

talk to members of the community to understand the 

barriers? You might include peers, partners, community 

members, etc. as sources of information. For example, 

AHRQ has a Social Determinants of Health database 

https://www.ahrq.gov/sdoh/data-analytics/sdohdata.html; there is also the American Community Survey 

https://www.census.gov/acs/www/data/data-tables-andtools/data-profiles/

For each identified domain, are the 

activities clearly and specifically tied to 

addressing the needs of the population 

of focus? 

Examples of activities include providing free bus passes, 

translating materials in multiple languages, establishing 

service locations in hard-to-serve areas, providing mobile 

clinics, etc. 
[5] 

Additional Notes:

• The DIS should not present an additional data collection burden for your organization. The selected 

domains should be only those that are within the scope of the grant.

• While you only need to include one domain, applying critical thinking about where there’s overlap 

in domains will allow you and your grant project officer to think forward about sustainability and 

adaptability throughout the grant term and into the future.

CLAS STANDARDS

☐ Identify one or more of the National Standards for Culturally and Linguistically Appropriate Services 

(CLAS) that your organization plans to meet, expand, or improve through this grant opportunity. Describe

any activities, policies, and procedures that you will undertake to ensure adherence.

Questions to Consider Examples/Notes

How is the identified CLAS Standard 

connected to both the program 

requirements and the identified 

disparity-vulnerable population? 

Here are a few commonly selected CLAS Standards: 

Translation of materials (CLAS Std 8), providing interpreters

(CLAS Stds 5 & 7), hiring staff that reflect the disparityvulnerable community (CLAS Std 3), training staff on 

culturally appropriate Evidence-Based or EvidenceInformed programs (CLAS Std 4), or reviewing and updating 

policies and procedures related to culturally and 

linguistically appropriate services to ensure they are 

responsive to the community (CLAS Stds 9 & 13). 

Example:

You are providing integrated behavioral health and primary 

care services to clients from the Ethiopian community and 

hire someone who speaks Amharic and provide written 

signage, brochures and flyers in the waiting area. 

How are the identified CLAS Standards 

being implemented in practice? 

Example;

In order to increase access to integrated care services for 

the Ethiopian community, you partner with the local 

community center that serves Ethiopian refugees and is a 

“trusted entity” in the community, to obtain input on how 

to improve access, engagement and retention in services. 

How is your organization outreaching 

the disparity-vulnerable population? 

List strategies for reaching, engaging, and/or marketing to 

underserved communities that represent the disparityvulnerable population. Specify whether you are using 

printed materials, online/social media posts, word of 

mouth, attending community events, partnering with other 

organizations, etc. 

Example:

To increase awareness of your services within the Ethiopian 

community, you work with the local community center to 

post information in the center and participate in 

community events sponsored at the center.
[6] 

Additional Notes: 

• It is insufficient to copy and paste the CLAS Standard(s) and offer a one word/sentence response 

indicating that you will adhere to it or complete it. You must clearly describe the proposed 

activities to meet CLAS Standards. 

• Although it is not required, it could be helpful to offer CLAS Standards training to staff members. 

SECTION 3 – Developing a Disparity Reduction Quality Improvement Plan

IMPLEMENTATION OF ACTIVITY 

☐ Describe the activities that you will implement to reduce disparities for the disparity-vulnerable 

population(s). 

Questions to Consider Examples/Notes

Do the identified activities match those 

listed in the grant application? 

PLEASE NOTE: You do not have to speak to all of the 

goals/objectives listed in your application. You could 

choose to implement DIS activities on two or three of your 

program objectives. 

How are the planned activities 

responsive to the needs and cultures of 

the disparity-vulnerable population? 

Example: The grantee plans to implement a program to 

improve mental health on a college campus and the 

disparity-vulnerable population is Asian women because 

they have higher rates of untreated mental health needs 

according to the college data. The grantee decides to 

implement Asian Women’s Action for Resilience and 

Empowerment (AWARE) which is an evidence-based 

practice designed to treat Asian women by training college 

counselors and providers to identify and use a culturally 

informed intervention. 

If your organization plans to provide training and 

education, the identified activity should reflect how you will 

conduct outreach to the population of focus. An example of 

this is to use social media to direct your outreach to zip 

codes where the disparity-vulnerable population resides. 

If you are hosting events/training and your disparityvulnerable population is women, you could host hybrid 

meetings, record meetings and post them on your website, 

and coordinate with community partners to provide 

childcare and/or activities for children.

 

A grantee listed a grant activity to provide EBP training to 

staff, a goal to increase access to SUD treatment, and 

identified the disparity-vulnerable population as African 

American women. Your DIS activity could be to provide 

staff training on how to implement culturally appropriate 
[7] 

Questions to Consider Examples/Notes

Evidence-Based or Evidence-Informed programs for the 

disparity-vulnerable population. 

If your organization plans to work with local business to 

reduce underage drinking, your DIS activity could be to 

identify and work with local businesses in communities 

where the disparity-vulnerable population lives. 

☐ The identified activities are written using SMART elements (Specific, Measurable, Achievable, Realistic, 

and Time-Bound). Please refer to the NOFO appendix titled “SMART Goals/Objectives,” the DIS guidance 

document, or the link provided in the Resource page at the end of this document.

INTENDED OUTCOMES AND IMPACT 

☐ Describe how the identified activities will improve access, use, or outcomes for the population of focus.

Questions to Consider Examples/Notes

When considering the proposed 

activities, do you provide details on 

how you expect the activities to reduce 

disparities? 

Example.

You might propose to address cultural and linguistic 

barriers by developing consumer-facing printed materials 

for outreach, services, and supports in Spanish. The 

intended outcome is increased awareness of treatment 

services by Spanish-speaking clients. The process of 

reducing the language barrier is expected to increase 

access, use, and outcomes for the population of focus. 

CLIENT/PEER/PARTNER INVOLVMENT 

☐ Describe how you will involve client, peer, family, or other stakeholders in addressing the identified 

disparity.

Questions to Consider Examples/Notes

Have you included specific ways you

will involve client, peer, family, and 

other stakeholder voices to inform 

grant activities? 

People with lived experience are involved in the program in 

meaningful ways (e.g., members of staff, steering 

committees, or other governing boards, peer support 

groups, youth who develop prevention campaigns and 

social media posts). How will you outreach and engage 

members of the community?

Have you identified community 

partners, resources, other agencies as 

opportunities for networking and 

sharing best practices? 

Discuss partnerships with community organizations or 

other referral sources. You might indicate that you partner 

and refer clients to community agencies that provide

services related to the SDOH of focus (e.g., case 

management, legal advocacy, housing assistance, etc.)
[8] 

TIMELINE

☐ Provide a timeline to implement the identified activities.

Questions to Consider Examples/Notes

Do each of the identified activities 

include an implementation timeline? 

Example: You might propose to develop and disseminate 

consumer-facing printed materials for outreach, services, 

and supports in French. You might anticipate having the 

translation completed within 6 months of the grant and 

plan to disseminate the materials within 7 months of the 

grant. 

Are the timelines realistic? Per the example described above:

✓ Your organization proposes it will take 6 months to have 

materials translated into French and 2 months to have 

documents printed. In this case, it would be unrealistic for 

your organization to have this completed within 7 months 

and you should revise the timeline to be 8 months. (If the 

you have already started the translation, you should adjust 

the timeline for translation to be shorter.)

✓ Your organization proposes to hire staff that are 

representative of the disparity-vulnerable population

within one year. This could be considered realistic based on 

where your organization is located and how the behavioral 

workforce shortage is impacting their community. Your

organization should describe recruitment methods.

✓ Your organization plans to implement a staff training on 

culturally appropriate treatment methods so that it can 

better address mental health disparities among Asian 

women. You plan to implement the training in year two 

because the training program is six months, and the next 

training date is four months away. This could be considered 

realistic as the treatment modality being used in the 

training is most appropriate for the disparity-vulnerable 

population. 

Is the timeline specific to the 

implementation of DIS activities rather 

than the project implementation time? 

The timeline must address the timeframe that you will 

implement the DIS activities. You cannot state that per the 

NOFO, the implementation of activities will begin no later 

than 4 months of the grant award date. 
[9] 

MEASUREMENT/EVALUATION 

☐ Describe a planned approach to measuring the process, progress, and outcomes of improving the 

identified disparity.

Questions to Consider Examples/Notes

Do you discuss measurement and 

evaluation outside of the use of GPRA 

data? 

✓ Plan to monitor treatment outcomes though the use of 

PHQ-9 screenings, suicide risk screenings, and other 

behavioral health screening tools. 

✓ Plan to collect and analyze qualitative/ quantitative 

program enrollment data every quarter to measure its 

progress towards increasing enrollment of the disparityvulnerable population. 

✓ Conduct treatment surveys to measure client satisfaction. 

✓ Discuss how you will evaluate your dissemination process 

to determine if /how the disparity-vulnerable population is 

engaging. 

Was a baseline measurement 

identified? If not, do you propose

what that baseline may be or how you

plan to measure the baseline? 

Have you identified an individual 

responsible for measuring and 

evaluating the outcomes? 

Individuals might include the program analyst, evaluator, 

data analyst, etc. 

Do you identify the tools or methods 

you will use to measure the outcomes 

that indicate making progress towards 

your goals? 

For instance, you could: 

• Measure engagement/attendance, referrals, 

completion rates 

• Conduct baseline interviews 

• Track social media traffic 

• Use surveys, questionnaires, long term follow up 

• Monitor trends, adaptations, and improvements 

• Gather client success stories 

• Disseminate client satisfaction surveys 

• Monitor internal program data collection 

• Review data from community surveys (for example, 

YRBS) 

• Review disparity index data 

Note: This list is not exhaustive. 

You should also discuss measuring your progress on their 

SDOH and CLAS Standard activities. For example, if you 

propose to develop a community coalition, you could discuss 

how you plan to monitor the formation and activities of the 

community coalition. 
[10] 

Questions to Consider Examples/Notes

Do you have a plan to monitor the 

data to know if you are on track to 

meet the goals you set? 

You could list benchmarks to track progress. For example, if 

your goal is to increase enrollment of Koreans by 20% within 

the next 8 months, you could indicate a benchmark to 

increase enrollment of Koreans by 5% every 2 months. 

Benchmarks are not required; however, they are commonly 

used to determine how well a process is working and 

implement quality improvement efforts as needed. 

SUSTAINABILITY 

☐ Describe a planned approach to sustain activities to continue improving the identified disparity after 

the grant ends.

Questions to Consider Examples/Notes

How will the proposed activities be 

sustained after conclusion of the grant? 

Did you identify at least one category 

(e.g. policies, financing, budget, 

training, systems, environmental 

changes, etc.) that could help the work 

continue after the grant ends? 

✓ Your organization plans to train staff on culturally 

appropriate EBPs, and you intend to host annual refresher 

trainings. 

✓ There is a budget line dedicated to sustaining activities 

✓ You describe a plan to continue to implement activities 

to address the disparity. 

✓ You opened a new location and have budgeted to 

maintain the location. 

✓ You developed partnerships with local community-based 

organizations that are trusted entities in the disparityvulnerable communities.

✓ You have established internal oversight for monitoring 

the outcomes that will continue or are going to make policy 

changes that will endure beyond the end of the grant. 

Additional Considerations 

• The DIS is meant to be a tool for grant monitoring. It is intended to be a living document used to 

measure your progress as part of a data-driven approach to quality improvement aimed at 

advancing equity. 

• The DIS should be routinely discussed during GPO monitoring calls. 

• The disparity reduction Quality Improvement Plan should be reviewed annually to help grantees 

understand what worked, what did not work, and what modifications may be needed to the 

planned activities. 
[11] 

Resources 

Disparity Impact Statement (DIS) webpage which includes guidance, examples and training materials: 

https://www.samhsa.gov/grants/grants-management/disparity-impact-statement

National Standards for Culturally and Linguistically Appropriate Services (CLAS) in Health and Health Care 

(CLAS Standards): https://thinkculturalhealth.hhs.gov/clas

SMART Goals description: https://www.mindtools.com/a4wo118/smart-goals

 

Social Determinants of Health (SDOH) https://health.gov/healthypeople/priority-areas/socialdeterminants-health