National Coverage Analysis (NCA) View Public Comments

Screening for Depression in Adults

Public Comments

Commenter Comment Information
Bocchino, Carmella Title: EVP, Clinical Affairs and Strategic Planning
Organization: America's Health Insurance Plans (AHIP)
Date: 08/18/2011
Comment:

August 16, 2011

Louis B. Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Dear Mr. Jacques:

Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) proposed coverage decision memo for Screening for Depression in Adults (CAG-004259). America’s Health Insurance Plans

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Belnap, Dan Date: 08/18/2011
Comment:

August 18, 2011

Dr. Don Berwick, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memos for Screening for Depression in Adults (CAG-00425N) and Screening and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse (CAG-00427N)

Dear Dr. Berwick:

The Coalition for Whole Health is a broad coalition of

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Shern, David Title: President & CEO
Organization: Mental Health America
Date: 08/18/2011
Comment:

August 18, 2011

Dr. Don Berwick, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memos for Screening for Depression in Adults (CAG-00425N) and Screening and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse (CAG-00427N)

Dear Dr. Berwick:

Thank you for the opportunity to comment on the

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Covall, Mark Title: President/CEO
Organization: National Association of Psychiatric Health Systems
Date: 08/18/2011
Comment:

The National Association of Psychiatric Health Systems (NAPHS) supports the action of the United States Preventive Services Task Force (USPSTF) in recommending screening adults for depression when staff-assisted depression care supports are in place to assure accurate diagnosis, effective treatment, and follow-up. We also support the conclusion that the evidence is sufficient to determine that depression screening (under the circumstances defined in the Proposed Decision Memo) is

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Heim, MD, FAAFP, Lori J. Title: Board Chair
Date: 08/18/2011
Comment:

August 18, 2011
Donald Berwick, MD
Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
P.O. Box 8013
Baltimore, MD 21244–8013
Sent via email to CAGinquiries@cms.hhs.gov

Re: Proposed Decision Memo for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Berwick:

On behalf of the American Academy of Family Physicians (AAFP), which represents

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Longtin, PMHCNS - BC, Brent Date: 08/18/2011
Comment:

To whom it may concern:
I submit that current screening practices for Substance Abuse as well as Depression in primary care overall is not comprehensive in the United States. Even if screening is completed, there is documented evidence that there is lacking follow-up recommendations regarding determination of needed treatment, education and referral to available resources. This proposed standard also places for the first time a minimum competency standard and direction to help assure

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Bessen, MD, Laura Title: Vice President, US Immunoscience and Neuroscience
Organization: US Medical Affairs (Neuroscience) Bristol-Myers Squibb
Date: 08/17/2011
Comment:

August, 18, 2011

Madeline Ulrich, MD
Stuart Caplan, RN, MAS
Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: National Coverage Analysis for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Ulrich and Mr. Caplan:

Thank you for the opportunity to submit additional comments on the Centers for Medicare and Medicaid Services' (CMS') national coverage

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crozier, james Date: 08/17/2011
Comment:
This is a great start...BUT, only a start. I would recommend adding coverage for depression care/counseling in primary care while also adding Licensed Mental Health Counselors and Marriage and Family Therapists to the list of approved providers for Medicare.
Fitzpatrick, M.S.W., Michael J. Title: Executive Director
Organization: National Alliance on Mental Illness
Date: 08/17/2011
Comment:

August 18, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Attention: CAG-00425N
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Comments on Proposed CMS National Coverage Determination for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Jacques:

On behalf of the National Alliance on Mental Illness (NAMI), I pleased to submit the following

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Gitlow, MD, MBA, MPH, FAPA, Stuart Title: Acting President
Organization: American Society of Addiction Medicine
Date: 08/17/2011
Comment:

August 18, 2011

Donald Berwick, M.D.
Administrator
Centers for Medicare & Medicaid Services (CMS)
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memos for Screening for Depression in Adults (CAG-00425N) and Screening and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse (CAG-00427N)

Dear Dr. Berwick:

The American Society of

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Lovelace, John Title: President
Organization: UPMC Health Plan
Date: 08/17/2011
Comment:

August 18, 2011

Lawrence Schott, MD, MS
Lead Medical Officer, Division of Medical and Surgical Services The Centers for Medicare and Medicaid Services

Re: Proposed Decision Memo for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Schott:

The UPMC Insurance Services Division (“UPMC”) is pleased to have the opportunity to comment on the proposed coverage decision for “Screening for Depression in Adults” (CAG-00425N). UPMC

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Madara, MD, James L. Organization: American Medical Association
Date: 08/17/2011
Comment:

August 18, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Jyme Schafer, MD, MPH
Director, Division of Medical and Surgical Services
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re:  Proposed Coverage Decision Memorandum for Screening and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse; CAG-00427N
Proposed Coverage Decision Memorandum for Screening for

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Mays, Willard Date: 08/17/2011
Comment:

The proposed Medicare coverage for screening depression in adults in primary care (CAG-00425N) is extremely important and will be of great benefit to older adults. Many studies have found that because of stigma and other factors the majority of older adults are reluctant to admit that they have a mental health problem, including depression, and don't seek services. The majority of those that do seek services, access it through primary care rather than a qualified mental health professional.

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Byer, Michael Title: Project Director
Organization: M3 Information
Date: 08/17/2011
Comment:

Routine screening for depression and anxiety in primary care with an endorsement for reimbursement is a welcome development. Mental health screening is the most feasible and affordable way to measurably improve every health metric. The PHQ9, and its forerunner, the PRIME-MD, were developed in the 1990's and have achieved much. However, an instrument that includes modern understandings such as bipolar disorder, anxiety and PTSD will lead to better customized and measurable care for the

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Certner, David Title: Legislative Counsel & Legislative Policy Director
Organization: AARP
Date: 08/17/2011
Comment:

August 17, 2011

Donald M. Berwick, M.D.
Administrator, Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue,
S.W. Washington, D.C. 20201

Re: Proposed Coverage Decision Memorandum for Screening for Depression in Adults, Administrative File: CAG-004275N

Dear Dr. Berwick:

AARP commends the Center for Medicare and Medicaid Services (CMS) for recognizing the important role that

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Mickow, Brenda Organization: Mayo Clinic
Date: 08/17/2011
Comment:

Mayo Clinic strongly supports Medicare coverage for screening of depression. We also believe coverage for screening does not go far enough in addressing depression in adults. In addition to screening, Mayo Clinic encourages CMS to cover care coordination of Medicare beneficiaries diagnosed with depression. Coordinated care management by registered nurses may include office visits, phone calls, or other correspondence with patients diagnosed with depression to decrease emergency room

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Greden, MD, John F. Title: Founding Chair
Organization: National Network of Depression Centers (NNDC)
Date: 08/17/2011
Comment:

The National Network of Depression Centers (NNDC) is a collaborating network of 21 leading academic Centers of Excellence (www.NNDC.org) with more than 450 clinicians and investigators. The NNDC strongly endorses the Center for Medicare and Medicaid Services (CMS) recommendation to reimburse screening for adult depression.

Furthermore, we strongly recommend screening and brief intervention for all patients. An estimated 1 in 6 Americans suffer from depressive illnesses and the

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Walker, Drew Organization: Michigan Office of Services to the Aging
Date: 08/17/2011
Comment:

While so many of the medical and psychological reasons stated to support the funding of such screenings indicate this move would be a step forward, social scientific knowledge suggests that possible adverse effects of this decision could very likely outweigh the benefits to older Americans.

There are two significant reasons, yet unexamined by CMS in their analysis, to defer the decision on Medicare’s support of screening for depression among older adults, as the proposed policy is

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Cline, Laura Title: Sr. Director, Federal Government & External Affair
Organization: Takeda Pharmaceuticals North America, Inc
Date: 08/16/2011
Comment:

August 17, 2011
Submitted via Email:
CAGinquiries@cms.hhs.gov

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Attention: CAG-00425N
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Comments on Proposed CMS National Coverage Determination for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Jacques:

Takeda Pharmaceuticals North America, Inc. (Takeda) and

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Scully, M.D., James H. Title: Medical Director & CEO
Organization: American Psychiatric Association
Date: 08/16/2011
Comment:

August 17, 2011

Donald Berwick, MD
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Rules for Screening for Depression in Adults (CAG-00425N) and Screening and Behavioral Counseling Interventions in Primary Care to Reduce Alcohol Misuse (CAG-00427N)

Dear Dr. Berwick,

The American

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McNertney, Jennifer Date: 08/16/2011
Comment:

August 16, 2011

Mr. Donald M. Berwick, M.D., M.P.P.
Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

Submitted electronically

RE: Proposed Decision Memo for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Berwick:

On behalf of our 145 member hospitals and 17 member health systems, the Minnesota Hospital

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Erickson, Jill Date: 08/15/2011
Comment:
To whom it may concern,
I would just like to offer my support of the initiative to inlcude screenings for depression in the annual medicare visits. I work with elderly as part of an Area Agency on Aging and more recently also as part of the California Mental Health Serices Act Prevention & Early Intervention programs. I can tell you depression afflicts many older adults and can greatly effect their quality of life. Physicians can be very helpful in helping identify depression and to

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Anderson, Ph.D., Norman Title: Chief Executive Officer
Organization: American Psychological Association
Date: 08/15/2011
Comment:

August 15, 2011

Centers for Medicare and Medicaid Services
Attn: Stuart Caplan, RN, MAS and Lawrence Schott, MD, MS
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memo for Screening for Depression in Adults (CAG-00425N)

Delivered electronically via www.cms.gov

Dear Mr. Caplan and Dr. Schott:

The American Psychological Association (APA), the professional organization representing 154,000 members and affiliates

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Rose, Ahniwake Date: 08/12/2011
Comment:

Dear Dr. Schott and Mr. Caplan,

Thank you for the opportunity to provide comments to Centers for Medicare and Medicaid Services (CMS) regarding the national coverage analysis on depression screenings. The National Congress of American Indians (NCAI) – the nation’s oldest, largest, most representative national tribal organization made up of American Indian and Alaska Native tribal governments – supports the decision of CMS to cover depression screening under Parts A and

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bradley, wendy Title: Improvment Advisor
Organization: Southcentral Foundation
Date: 08/10/2011
Comment:
We are in support of this policy. However with the move toward behavioral health integration into primary care it is imparative any behavioral health professional licensed by the state or authorized by the tribal health authority working under the auspices of a primary care physician be eligible for this reimbursement.
Pollack, Rick Title: Executive Vice President
Organization: American Hospital Association (AHA)
Date: 08/08/2011
Comment:

August 9, 2011

Donald M. Berwick, M.D., M.P.P.
Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

RE: Proposed Decision Memo for Screening for Depression in Adults (CAG-00425N)

Dear Dr. Berwick:

On behalf of our more than 5,000 member hospitals, health systems and other health care organizations, and our

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Beckett, DC, APRN, NP-C, PMHNP-BC, Randall Title: Advanced Practice Nurse
Date: 08/04/2011
Comment:
I support adding Depression screening in primary care as a preventive service. Proper identification and treatment has broad affects on other chronic illnesses.
Epp, Lawrence Title: Program Manager
Organization: GUIDE Program
Date: 08/04/2011
Comment:

I am concerned that new Medicare Primary Care reimbursement for depression screening excludes this service taking place in assisted living facilities and nursing homes. I feel this is terribly short-sighted as it excludes the subsection of the senior community most at-risk for depression. The literature is very clear that institutionalized elderly are at high risk for depression, which exacerbates their somatic conditions. Regrettably, the progressive thinking of integrated care has not

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Totten, Julie Title: President
Organization: Families for Depression Awareness
Date: 08/03/2011
Comment:

We enthusiastically support that there be annual screening for depression for Medicare recipients. We also feel that it is important to screen for both major depression and bipolar disorder at the same time so that a proper diagnosis and the correct type of treatment can be provided. Our nonprofit organization, Families for Depression Awareness (www.familyaware.org) helps families recognize and cope with depressive disorders to get people well and prevent suicides. Many people we help find

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Edelson, Lori Title: CEO, Owner, Clinical Social Worker
Organization: Birmingham Maple Clinic
Date: 08/02/2011
Comment:
As CMH considers the addition of updates to coverage by Medicare and Medicaid to cover Screening for Alcohol Abuse and Screening for Depression in Adults, it seems quite reasonable that the Eligible Provider list also include LMSWs and PhDs. Behavioral health care and medical health care are both critical, inter-woven components of wellness and total health. Therefore, the inclusion of behavioral health care specialists as EP seems necessary and reasonable.
Muramoto, Kim Title: Director Trauma Program
Organization: Centura Health, Littleton Adventist Hospital
Date: 08/02/2011
Comment:
I support having SBIRT and a depression screen available in all healthcare settings. We know that both have a profound impact on mental and physical issues and healing. It is well documented that patients that may be suicidal see a healthcare practitioner in the preceeding weeks with vague or multiple complaints, but not necessarily indicating depression or suicide. We need to take solid steps to truly get to the root of caring for patients and this screening and referral process would

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Kruckenberg, Sheree Title: Vice President Behavioral Health Services
Organization: California Hospital Association
Date: 07/28/2011
Comment:

Subject: Medicare Proposes Coverage for Screening and Counseling for Alcohol Misuse and Screening for Depression (00427N)
Dear Colleagues,
On behalf of the California Hospital Association (CHA) and our 400 member hospitals and health systems, we wish to express our support for the Centers for Medicare & Medicaid Services (CMS) proposal to add alcohol screening and behavioral counseling, and screening for depression to the package of preventive services for Medicare

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RHODES, JEAN Date: 07/26/2011
Comment:
Re: Primary Care Depression Testing This is way overdue! Please support this much needed assessment of depression! Thanks...
Jones, Vivian Title: M.D.
Date: 07/25/2011
Comment:
I believe that the proposed interventions will have a positive impact for primary care physicians and patients.
Pubillones, Manuel Organization: Strategic Health Solutions
Date: 07/20/2011
Comment:

First paragraph where it says: is reasonable and necessary for the prevention or early detection of illness or disability. I suggest that instead of “or”, use “and” as prevention is different from early detection.

Where it says: At a minimum level, staff-assisted depression care supports consist of clinical staff (e.g., nurse, physician assistant) in the primary care office who can advise the physician of screening results and who can facilitate and

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