Patricia Kay Drozdowski

7580 E. Cactus Wren Rd.

Scottsdale, Az. 85250

August 25, 2008

Centers for Medicare and Medicaid Services

Department of Health and Human Services

Attention: CMS-1404-P

Mail Stop C4-26-05

7500 Security Boulevard

Baltimore, Maryland 21244-1850

To Whom It May Concern:

**Re: Response to Proposed Changes to the CY2009 Hospital Outpatient
PPS-CMS-1404-P Partial Hospitalization**

On behalf of Friendship Community Mental Health Center, we appreciate
the opportunity to submit comments regarding CMS's proposed OPPS rates
concerning APC Code 0034 -- Mental Health Composite Services, APC Code
0172 -- Level I Partial Hospitalization Programs, APC Code 0173 Level II
Partial Hospitalization Programs and 0322, 0323, 0324, 0325 --
Outpatient Psychiatric Services

[FRIENDSHIP COMMUNITY MENTAL HEALTH CENTER]{.mark} is A FREE-STANDING
Community Mental Health Center and I am deeply concerned about the
direct impact a fifth consecutive rate reduction will have on partial
hospitalization and hospital outpatient services.

[FRIENDSHIP COMMUNITY MENTAL HEALTH CENTER]{.mark} is an involved member
of The Association of Ambulatory Behavioral Healthcare (AABH) and I
strongly support the eleven (11) point response that was submitted by
our Board President regarding this matter. I [believe]{.mark} that these
points have been carefully researched and a plan has been thoughtfully
developed.

PHP programs have helped stabilize the lives of the chronically mentally
ill and mentally ill elders over the past 30 years. This benefit is the
delivery of four to seven days per week of intensive psychiatric
treatment to the mentally ill. These programs, delivered by hospital
outpatient departments and Community Mental Health Centers (CMHCs), are
designed specifically to keep these beneficiaries out of higher cost
institutional settings.

Over the past four years, the reimbursement to this level of care has
been cut. The effect of the last four year's cut has had a devastating
effect on the access to treatment by patients throughout the country.
This fact is notably demonstrated by the significant reduction in the
membership of the AABH over the past few years. Further cuts threaten
continued access to this cost-saving benefit for the mentally ill. We
are deeply concerned about the direct impact a fifth consecutive rate
reduction will have on partial hospitalization and hospital outpatient
services, as now access to care becomes a real issue .

We are requesting that CMS refrain from going forward with the proposed
CY 2009 rate cut for Partial Hospitalization (PHP) Services. Coupled
with last four year's rate reductions for PHP, the proposed rate will
make it difficult to cover the costs needed to provide an intensive
program. Any further reduction in rates will clearly impact access to
PHP services in our community.

We, too, have read the results of several studies done by other
professional organizations and find that the information contained in
these reports do not reflect our industry as we know it and are involved
in it. Our professional organization has also conducted several studies
on the state of our industry with completely different results.

In addition, we think that it is important to note that what is actually
done in the way of treatment for each patient in their "day of care" is
in no way reflected in what is submitted in billing for each patient per
day. We are required to provide certain services as regulated by our
Local Coverage Determination (LCD) as an intensive PHP program, but we
provide many hours of other services each day. Several examples of
additional services are: assisting patients in finding appropriate
housing, accessing other healthcare services, obtaining medications,
working through issues with family members, accessing transportation to
medical and other appointments, assisting with information and
appointments in Social Security and Medicare questions, accessing food
banks and food stamps, obtaining eye and dental services, and
integrating highly volatile and anxious patients into the milieu without
upsetting the environment, when at times they cannot tolerate the group
process and need one-on-one attention. Currently, there is no way to
show, through the billing process, that these events take place as there
are no billing codes that note these activities. To illustrate, there
are times that a patient is far too anxious to tolerate group therapy
the entire treatment day and a staff member must offer individual
attention in order to stabilize the patient. There is no way to reflect
these activities, as billing can not be submitted for that patient that
treatment day. It appears that the patient was absent the entire
treatment day, when, in fact, he was receiving intense and personal
treatment.

Please include additional information or your personal opinions here

We are asking CMS to allow time and resources to develop a reasonable
payment methodology by working with provider and community organizations
to develop a payment rate that is fair, consistent and predictable. [We
or I]{.mark} agree with the AABH proposal:

1.  Do not reduce the 2009 rate of reimbursement for the Level II
    Partial Hospitalization Services, but leave at the current 2008 rate
    of \$205.16.

2.  Implement the reduced rate of reimbursement for the Level I Partial
    Hospitalization Services as proposed.

3.  **[S]{.underline}**upport a legislative amendment to:

    a.  Remove PHP from the APC codes and have independent status
        similar to Home Health.

    b.  Establish a reasonable base rate for PHP such as the current
        2008 per diem.

    c.  Annually adjust the base rate by a conservative inflation factor
        such as the CPI.

    d.  Establish quality criteria to judge performance and that
        influences future rate reimbursement.

Thank you, for the opportunity to respond to this critical issue.

Respectfully,

YOUR NAME: Patricia Kay Drozdowski

TITLE: Psychotherapist

YOUR ORGANIZATION: FRIENDSHIP COMMUNITY MENTAL HEALTH CENTER