Minnesota Hospital Association

Policy & Advocacy

rules, regulations and comments

The Minnesota Hospital Association continually monitors state and federal rules and regulations to keep members informed and advocates on behalf of members regarding the impact of regulations on the state’s hospitals and health systems. MHA submits comment letters to share recommendations and feedback with the appropriate government organizations and health care stakeholders. Examples of rules and regulations that MHA addresses include those implementing federal or state health care reform efforts, changing payment methodologies, establishing community benefit or other standards for tax-exempt organizations, or modifying government oversight of health care activities.

August 16, 2011

Proposed Decision Memo for Screening for Depression in Adults

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 Association (MHA) thanks you for the opportunity to comment on CMS’ proposed decision memo for screening for depression in adults (CAG-00425N).

Along with the American Hospital Association (AHA), MHA fully supports CMS’ proposal to add alcohol screening and behavioral counseling, as well as screening for depression, to the package of prevention services offered to Medicare beneficiaries.

Minnesota’s hospitals and health systems helped implement the Institute for Clinical Systems Improvement’s (ICSI) DIAMOND model of depression treatment. MHA and our members have long been supporters of bringing evidence-based health care guidelines into practice. The CMS memo is an affirmation of the important work being done in Minnesota and now across the nation.   

MHA supports the use of the primary care setting for these screenings. In addition, MHA strongly supports the memo’s recommendation to provide treatment or support once the screening is completed. This next step is critical to successfully treating depression, behavioral conditions, and alcohol abuse.

Finally, MHA would like to recommend CMS expand its suggestion of what provider types are considered “clinical staff” in staff-assisted depression care support. Evaluations of DIAMOND have found certified medical assistants to be an important part of the successful DIAMOND model. Adding “certified medical assistant” to “nurse and physician assistant” as “clinical staff …in the primary care office who can advise the physician of screening results and who can facilitate and coordinate referrals to mental health treatment” will enable more individuals to receive coordinated care and successful treatment.

If you have any questions, please feel free to contact me at (651) 659-1405 or [email protected].

Sincerely,

Jennifer McNertney

Policy Analyst