Docket: EBSA-2009-0010 

Request for Information Regarding the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction 

Equity Act of 2008 

Comment On: EBSA-2009-0010-0001 

Request for Information Regarding the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction 

Equity Act of 2008 

Document: EBSA-2009-0010-DRAFT-0214 

Comment on FR Doc # E9-9629 

Submitter Information 

Name: Maureen Theresa Hennessey 

Address: 

1229 W. 62nd St. 

Kansas City, MO, 64113 

Email: maureenhennessey@mac.com 

Phone: 816-332-1749 

Organization: Gardener Health Systems Consulting & Univ. of Mo.- Kansas City 

General Comment 

May 21, 2009 

My thanks to the Departments of The Treasury, Labor and HHS for the opportunity to comment on the Paul 

Wellstone and Pete 

Domenici Mental Health Parity and Addiction Equity Act of 2008. I am a healthcare executive and consultant, 

licensed psychologist 

and certified coach. My experience includes development of behavioral health care networks for most states in our 

nation and 

leadership for mental health parity preparation and administration with two health plans. 

One comment I would make is that the development of an audit program to promote compliance with this 

legislation presents the 

opportunity to promote the health care improvement aims of the Institute of Medicine (health care should be Safe, 

Effective, Patientcentered, Timely, Efficient, Equitable) through inclusion of audit items and provision of compliance education that 

simultaneously 

PUBLIC SUBMISSION 

As of: May 28, 2009 

Received: May 27, 2009 

Status: Pending_Post 

Tracking No. 809ba3ad 

Comments Due: May 28, 2009

Submission Type: Web
facilitates regulatory compliance and the aims described in the IOM’s Crossing the Quality Chasm report (2001) 

and its related 2005 

report, Improving the Quality of Health Care for Mental and Substance-Use Conditions: Quality Chasm Series. 

One observation I would offer is that resources that are available and covered under a medical/surgical benefit are 

too often unavailable 

through the behavioral health benefit. For example, skilled nursing facilities and home health care, adept at 

managing the 

medical/surgical patient, are less available for behavioral health patients and their families. Other times, if the 

facility or agency offers 

services for behavioral health patients and families, the staff often lack training in evidence-based care for patients 

with chronic 

behavioral health conditions. Many of these patients have co-morbid psychiatric, substance abuse and medical 

conditions that could 

benefit from evidence-based care. These circumstances create gaps in the continuum of care, increase 

hospitalizations, morbidity and 

mortality, and decrease consumer and family autonomy. This problem may be found in both urban and rural areas, 

but is more common 

in rural communities. 

One recommendation I would make is that compliance audits of health plans aggregate data regarding gaps in the 

care continuum by 

region and nationally. It would be beneficial to provide state and federal resources to develop new or improved 

programs to address 

these gaps in care. Addressing these gaps will empower patients, preserve families, decrease care costs, and 

provide new 

opportunities for employment for citizens staffing these programs. 

Please contact me at maureenhennessey@mac.com if additional information is desired. 

Respectfully submitted, 

Maureen Hennessey, PhD, CPCC 

President & CEO 

Gardener Health Systems 

Clinical Assistant Professor 

University of Missouri-Kansas City 

School of Medicine-Department of Psychiatry