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-0057 

Comment on FR Doc # E9-9629 

Submitter Information 

Name: Laurie Flynn 

Address: 

1775 Broadway, Suite 610 

New York City, NY, 10019 

Phone: 212-265-4453 

Organization: National Center for Mental Health Checkups 

General Comment 

The TeenScreen National Center for Mental Health Checkups is submitting 

comments to encourage the federal government to require health insurance plans 

as part of compliance with the Paul Wellstone and Pete Domenici Mental Health 

Parity and Addiction Equity Act of 2008 to cover annual mental health screenings 

for youth age 12 to 18 during the yearly well-child/annual exam visit. 

Attachments 

PUBLIC SUBMISSION 

As of: May 15, 2009 

Received: May 14, 2009 

Status: Pending_Post 

Tracking No. 80992016 

Comments Due: May 28, 2009

Submission Type: Web

EBSA-2009-0010-DRAFT-0057.1: Comment on FR Doc # E9-9629
May 14, 2009 

Centers for Medicare & Medicaid Services 

Department of Health and Human Services 

Attention: CMS–4137–NC 

P.O. Box 8017 

Baltimore, MD 21244–8010. 

To Whom It May Concern: 

As executive director of the TeenScreen National Center for Mental Health Checkups at 

Columbia University (National Center), I am submitting comments to the Centers for Medicare 

and Medicaid Services (CMS) with regard to the public notice for comment [CMS-4140-NC] on 

implementation of the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction 

Equity Act of 2008 (MHPAEA). I am writing to encourage the agency to incorporate into the 

MHPAEA regulations a requirement for insurance plans to cover adolescent mental health 

checkups for youth age 12 to 18. The National Center believes that this step is necessary to raise 

mental health care to the same level of importance as physical care for our nation’s young 

people. 

The National Center is a non-profit, privately funded mental health initiative. Our mission is to 

expand and improve early detection of mental illness by mainstreaming mental health checkups 

as a routine procedure in adolescent health care, schools, and other youth-serving settings. The 

goal of the National Center is to prevent adolescent suicide and reduce disability associated with 

mental illness. To achieve this goal, the National Center works to advance public policy and 

promote best practices to expand the availability and utilization of mental health checkups 

nationwide. The National Center provides voluntary mental health screenings in more than 500 

sites in 43 states. 

The MHPAEA was intended to ensure equitable access and coverage of mental health services 

for all American consumers. Specifically, it is intended to ensure that there are no separate costsharing requirements that are applicable only with respect to mental health or substance use 

disorder benefits. We believe that for youth age 12 to 18 this requirement should provide 

coverage of an annual mental health screen, or mental health checkup, during the yearly wellchild/annual exam visit. Incorporating an annual screen into the well-child/annual exam visit 

will ensure that for adolescents their mental health will be routinely monitored and that an 

additional visit to a medical professional to assess their mental health will not be required. This 

will promote equity in coverage and meet parity with regard to cost requirements. 

According to the National Institute of Mental Health ̧ 50 percent of all lifetime mental health 

disorders start by age 14. Yet, because the early signs of a disorder often are missed, the average 

diagnosis regularly occurs 10 years or more after the onset of symptoms. Missing the early 
symptoms can result in disorders that create a lifetime of disability or result in suicide. Suicide 

remains the third leading cause of death for Americans age 15 to 24 and mental illness is the 

leading cause of disability for Americans age 15 to 44. However, after decades of research, we 

now know that in youth up to age 21 there is a window of opportunity of two to four years, 

between the first symptoms and the onset of the full-blown diagnosable disorder, when treatment 

is most effective at reducing the severity of specific disorders. If mental health checkups are 

incorporated into the yearly well-child/annual exam visit for youth 12 to 18, the identification of 

mental illness at its earliest stages would be greatly increased and the cost to the individual and 

society – an estimated $247 billion annually – would be greatly reduced. 

The importance of early detection, through screening, and treatment of mental illnesses has been 

well documented through medical research and by governmental entities. In 2002, the 

President’s New Freedom Commission on Mental Health was developed to improve services and 

coordination for Americans suffering from mental illness. A key recommendation from the 

Commission’s report Achieving the Promise: Transforming Mental Health Care in America was 

the necessity to increase early identification efforts and engage primary care physicians in 

providing first-line detection of mental illness. Most recently, on February 13, 2009, the 

National Research Council and the Institute of Medicine (IOM) in their report Preventing 

Mental, Emotional, and Behavioral Disorders Among Young People: Progress and Possibilities

recommended that the federal government make preventing mental, emotional and behavioral 

disorders and promoting mental health in young people a national priority. 

The IOM states that screening in primary care settings offers the potential to intervene early and 

prevent fully developed disorders. The IOM also notes a number of programs are effective and 

promote mental health and should be implemented more broadly. The IOM conclusions include: 

1) Interventions before the disorder occurs offer the greatest opportunity to avoid the substantial 

costs to individuals, families and society that these disorders entail; and 2) Validated screening 

tools are available at little or no cost to primary care providers. Further, in April 2009, 

immediately following the IOM report, the influential U.S. Preventive Services Task Force 

(USPSTF) medical panel called upon doctors in primary care settings to screen all adolescents 

age 12 to 18 annually for Major Depressive Disorder. This recommendation is based on peerreviewed evidence that screening instruments developed for primary care accurately identify 

depression in adolescents. 

The medical professions also have spoken about the importance of using annual screenings to 

promote early identification of mental illness. In 2007, The American Academy of Pediatrics 

(AAP) called for annual, confidential screening and referral for behavioral health problems. 

Since that time, AAP has embarked on a multi-state effort to provide discussion guides to 

physicians to assist them in inquiring about adolescent mental health. This spring the Academy 

endorsed the USPSTF recommendations and called on families and children to have access to 

mental health screening, assessment and services to appropriately address mental health 

conditions in primary care. According to the AAP national pediatric practice guidelines, 

administering a mental health screening test is considered one of the most efficient ways for 

health care professionals to improve the recognition and treatment of psychosocial problems in 

children and adolescents. The AAP now recommends annual preventive health care visits for 

adolescents age 11 to 21 that include confidential screening and early illness identification. 
However, access to annual mental health screenings for America’s youth will only become a 

reality when insurers begin to compensate primary care physicians and pediatricians for the time 

they spend with a child at risk. Based on the National Center’s work in eight primary care sites 

located in eight states, we believe a mental health checkup can be adopted by primary care 

physicians into the yearly well-child/annual exam visit at little or no expense. However, for the 

approximately 14 to 20 percent of young people who will screen positive, insurers should be 

required to compensate primary care physicians for the time they spend further evaluating and 

treating the youth. To do otherwise will continue to place mental health on a lower priority level 

than physical health for young people age 12 to 18. 

Our nation stands at a crossroad. We can continue to treat mental illness as a substandard 

medical condition, resulting in a long term disability for millions, or we can choose to chart a 

new course by prioritizing identification and treatment of mental illness. If we take this new 

course and begin to screen for the warning signs in adolescence, we will identify those at risk 

when signs first present and treatment is most effective and least invasive. According to the 

IOM, doing so will improve the long term health of individuals and result in significant cost 

savings to the American health care system and America’s social safety-net. I urge the Centers 

for Medicare and Medicaid Services to require health plans to incorporate a mental health screen 

into the yearly well-child/annual exam visit and compensate providers for their time spent 

treating patients. 

Sincerely, 

Laurie Flynn 

Executive Director 

TeenScreen National Center for Mental Health Checkups