Rosalind:
I welcome the opportunity to respond to your letter of earlier this week. Overall, I disagree
wholeheartedly with what I consider to be inaccurate, misleading and negative characterizations
about Shadow Mountain Behavioral Health, the quality of the services we provide to our patients
and the dedication and competency of our staff.
I also believe that the central premise of your questions reveals an alarming lack of
understanding of and sensitivity to the realities of mental health care generally and the role that
Shadow Mountain plays in the Tulsa community specifically. The facility portrayed in your
questions bears no resemblance to the one that I am proud to lead and where we work tirelessly
each day to treat some of the most medically challenging and complex patients that other
facilities refuse and/or are unable to properly treat.
Apart from my service in the U.S. Army as a combat engineer, I am proud to say that I’ve spend
nearly 20 years working in the behavioral health industry in a variety of clinical care and facility
administration roles. I moved to Oklahoma to join Shadow Mountain in 2002 and was attracted
to the opportunity due to Shadow Mountain’s strong reputation for providing specialized care to
the neediest patients, particularly children.
We believe that every child no matter their circumstances or complexity of their illness deserves
high quality treatment in a safe and nurturing environment. We strive every day to uphold this
important responsibility and take great pride in the work we do especially considering that many
of our young patients come to us after 30-40 previous placements in foster care or other
facilities.
Shadow Mountain has also been recognized for its quality care and treatment. For example, we
were designated a Joint Commission Top Performer on Key Quality Measures during every year
of the program’s existence from 2011-2015.
Your representations also don’t accurately reflect the efforts of the dedicated mental health
professionals that on a day to day basis bring a huge passion, compassionate hearts and a desire
to help our patients improve the quality of their lives. Nevertheless, nearly every behavioral
facility treating acutely ill psychiatric patients will invariably experience isolated and regrettable
incidents and occasional regulatory action which provides us valuable feedback and
opportunities to further improve the quality of our services. When staff have not acted
appropriately with our patients, I have taken disciplinary measures including immediate
terminations when warranted.
With respect to the videos that you have provided me, I do not believe there is a credible way
that any outside person, in my view, could offer an opinion of a situation for which they were not
present, nor privy to the patient’s condition, treatment plan and events occurring before or after
the video. This footage is highly misleading and presented without sound or appropriate
situational context. Most importantly, none of the patients shown in the videos suffered any
bodily harm.

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 Our #1 job is to keep our patients safe. Many of our patients suffer from acute psychiatric
conditions resulting from severe trauma and abuse and sometimes this manifests in patients
exhibiting highly reactive and violent behavior that can endanger themselves, other patients and
staff. We consistently emphasize and provide ongoing clinical staff training and certifications on
verbal de-escalation techniques to avoid physical restraint interventions. To be clear, such actions
are undertaken as a last resort to ensure the safety of the patients and staff and never for punitive
reasons. Clinical staff are also certified and trained in proper restraint procedures that emphasize
safety.
Over the course of my career, I have personally completed several training courses on safe
physical management techniques.. My occasional participation in restraint interventions
(including in the videos) was typically limited to aiding clinical staff in difficult situations where
de-escalation efforts were repeatedly attempted but ultimately unsuccessful. I consider myself to
be an active manager and think it’s important to support my staff whenever possible and to
ensure that all patients under my care and our staff are kept safe. Moreover, the limited no-sound
video footage you shared did not include mine and other staff’s significant and repeated attempts
to verbally deescalate and diffuse the situation prior to employing physical management
techniques. My personal engagement in these rare situations was appropriate, reasonable and
proportional. At no time did any patients I interacted with sustain bodily harm or injuries.
Nevertheless, the decision on whether to utilize restraint and seclusion procedures is never an
easy one and often requires split second judgement calls under highly stressful circumstances.
While no facility or leader is free of occasional shortcomings or regretful departures from their
own high standards, I can assure you that I do everything possible to prioritize compassionate
care and safety always.
I also reject any contention that Shadow Mountain purposefully understaffs its units. We staff
appropriately based on patient acuity and in accordance with OHCA required ratios. In the case
of the November 2016 Sooner Care termination letter, we strongly disputed OHCA’s staffing
related allegations and believed they were largely related to changes that OHCA made to its
methods for defining staffing units and ratios coupled with some recordkeeping shortcomings
with our HR system. In the latter instance, we provided reconciled employee time cards to
demonstrate that our units were staffed appropriately. While we disputed the basis for the
termination letter and were surprised by this action, we cooperated fully with OHCA to quickly
remedy their concerns. Consequently, we were awarded a new Sooner Care contract within
approximately 30 days and have remained in good standing since.
Regarding the allegations of the largely unnamed sources, unfortunately, there are always going
to be situations when current and former employees are unhappy about their experience at an
organization and Shadow Mountain is no exception. As the facility CEO, I maintain an opendoor policy and strive to handle all complaints in an objective and fair manner while keeping in
mind that it is often impossible to make everyone happy all the time. I also wholeheartedly deny
the claims from anonymously sourced individuals that I acted in an inappropriate manner with
former staff or directed them to admit patients who did not meet medical criteria. As it relates to
the latter allegation, only an attending psychiatrist can admit a patient based on long established
clinical criteria.

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 I hope this letter provides you some important context that will lead you to re-assess your
preconceived notions and sensationalized, inaccurate depictions of Shadow Mountain and my
tenure as an employee and facility leader. It saddens me greatly that you’re willing to needlessly
hurt the reputation of many good, dedicated and hardworking people by spinning a story that just
doesn’t align with the facts.
Sincerely,
Mike Kistler
Chief Executive Officer, Shadow Mountain Behavioral Health System

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