Docket: CMS-2009-0040 

The Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 

Comment On: CMS-2009-0040-0048 

Interim Final Rules under the Paul Wellstone and Pete Domenici Mental Health Parity and 

Addiction Equity Act of 2008 

Document: CMS-2009-0040-DRAFT-0070 

John P. Casey, Administrator 

Submitter Information 

Name: John Casey 

Address: 

Helena, MT, 59604 

Organization: Shodair Children's Hospital 

General Comment 

Attachments 

PUBLIC SUBMISSION 

As of: April 28, 2010 

Received: April 27, 2010 

Status: Draft 

Category: Hospital - HPA35 

Tracking No. 80ae15de 

Comments Due: May 03, 2010

Submission Type: Paper

CMS-2009-0040-DRAFT-0070.1: John P. Casey, Administrator

Page 1 of 1

file://C:\Documents and Settings\gelman.beth\Local Settings\Temporary Internet Files\OL... 4/28/2010
Shodair 

CHILDREN'S HOSPITAL - 

Monwna's premier 

proyrder of medical gewtic services 

ad psychiutric care 

for children and 

adolescents. 

406-444-7500 

800-447.66 I4 

FAX: 406~444-7.5 30 

275.5 Colonial Drive 

P.O. Box 5539 

tielena, MT 59604 

\\~zzv.shodairhosl~ital.org 

April 22,20 10 

Centers for Medicare & Medicaid Services 

Department of Health and Human Services 

Attention: CMS-4 140-IFC 

P.O. Box 801 6 

Baltimore, MD 2 1244- 1 850 

Re: Interim Final Rule on Mental Health Parity 

Like every decision we make, there are always intended and unintended 

consequences. The same holds true to the passage of the Paul Wellstone 

and Pete Domenici Mental Health Parity and Addiction Equity Act of 

2008. The intended consequences were to eliminate the disparities in 

health plans between coverage for the treatment of medical conditions and 

the treatment of mental and substance abuse conditions. However, the 

unintended consequences have been the elimination of certain mental 

health service categories from coverage by many health plans in Montana. 

For example, New West Health, the 3" largest private health insurance 

company in Montana announced in January 20 10 that all its health plans 

would be eliminating the residential treatment coverage for children's 

mental health services. Another example involves a recent conversation 

with a consultant from Western States Insurance which gives advice to 

many of the larger self-insured health plans in Montana. They are advising 

some of their clients to eliminate residential treatment coverage for 

children's mental health services as well. Other clients are being advised 

to drop all mental health benefits and then parity is not an issue. Two 

TPS's in Montana are also advising new self-insured groups to drop their 

mental health benefit so that parity is a non issue. 

Our concern at Shodair Children's Hospital, a non-profit children's 

psychiatric facility, is that children in Montana will have one less crucial 

treatment option availed to them as part of the continuum of care. Many 

of our children come from small rural communities lacking in outpatient 

mental health services. As a result their mental condition is allowed to 

deteriorate until it becomes an acute situation requiring intensive (and 

expensive) inpatient services to diagnosis and stabilize their mental health 

condition. But once this process is completed the most appropriate next 

step might be an admission to our psychiatric residential treatment facility 

for 60-90 days to help the child improve histher social and developmental 

skills and learn to how to properly cope with a mental illness. But without 

insurance coverage, most parents or guardians will opt out this step 

because of the cost to them. Sadly, the cycle often repeats itself once the 
child is discharged from the hospital and there are no supportive or 

therapeutic outpatient services available in the community. We believe 

having a strong continuum of care for the treatment of a child's mental 

health promotes both better outcomes and lower overall costs, especially 

when you consider the social and economic costs to supporting an 

untreated child that progresses into adulthood. 

Since children's mental health services do not fall neatly into one or more 

of the six categories of benefits identified in the parity bill, we are 

requesting CMS clarify in its final rules that coverage for children's 

mental health services includes the whole continuum of care from acute 

inpatient services, residential treatment, group home therapy to outpatient 

counseling. 

Thank you for your consideration.