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-0217 

Comment on FR Doc # E9-9629 

Submitter Information 

Name: Dominic Hodgkin 

Address: 

Institute for Behavioral Health, Heller School 

MS 35, Brandeis University, 415 South St 

Waltham, MA, 02454 

Email: hodgkin@brandeis.edu 

Phone: 781-736-8551 

Organization: Institute for Behavioral Health 

General Comment 

Statement on comparative effectiveness research in behavioral health care 

To: The Federal Coordinating Council for Comparative Effectiveness Research 

From: The Workgroup on Comparative Effectiveness in Behavioral Health, Institute 

for Behavioral Health, Heller School for Social Policy and Management, Brandeis 

University 

Date: April 13, 2009 

We welcome the new administration’s initiative to expand funding for comparative 

effectiveness research. This initiative has particular relevance to behavioral 

health care, the area where our own research is focused. It is relevant because 

behavioral health care (which includes mental health and alcohol and drug abuse 

treatment) has been particularly prone to some of the problems that comparative

PUBLIC SUBMISSION 

As of: May 28, 2009 

Received: May 28, 2009 

Status: Pending_Post 

Tracking No. 809bb294 

Comments Due: May 28, 2009

Submission Type: Web
effectiveness research is intended to address. These problems include: 

- Rapid provider adoption of costly new psychotropic medications, often in the 

absence of any head-to-head trials demonstrating their superior effectiveness 

over existing, less costly medications. 

- Slow dissemination of certain other effective medications that are mainly used 

in public sector settings, e.g. naltrexone for alcoholism. 

- Under-utilization of approaches with a strong evidence base, such as cognitive 

behavioral therapies. 

- Persistence of non-evidence based practices, such as sub-therapeutic dosing of 

methadone. 

We therefore encourage the Coordinating Council to make sure that some of the 

new federal funding is directed toward comparative effectiveness research in 

behavioral health care. 

At the same time, we note that these studies will need to go beyond merely 

measuring ‘average’ effectiveness of a medication or treatment across the whole 

population treated. Previous studies have found that a given medication can have 

widely different effects across patients, which might be masked by an average 

effect. We are pleased to note that the enabling legislation takes account of 

this and calls for studies of subpopulations. 

Targeting federal funding for comparative effectiveness research also offers the 

chance to compare treatments that have been relatively less studied, for example 

some psychotherapies that are less easily standardized across providers. In 

some cases this might involve comparing different ways of delivering a given 

treatment, e.g. web-based treatment versus traditional treatment with counselors. 

Many behavioral health care purchasers and providers are frustrated with the 

current lack of knowledge, and eager to learn more about what works to help 

patients. They would be likely to act upon the findings that would result from 

future comparative effectiveness research, for example by disseminating 

information, removing institutional barriers, and redesigning incentives. In 

conclusion, behavioral health care may be an especially fruitful area for 

finding results with policy implications. 

Members of the Workgroup on Comparative Effectiveness in Behavioral Health: 

Dominic Hodgkin, Associate Professor (chair) 

Constance Horgan, Professor and Director, Institute for Behavioral Health 

Elizabeth Merrick, Senior Scientist 

Gail Strickler, Senior Research Associate 

Eve Wittenberg, Senior Scientist