National Coverage Analysis (NCA) View Public Comments

Intensive Behavioral Therapy for Obesity

Public Comments

Commenter Comment Information
Gooodman, Gary Title: Clinical Psychologist
Organization: Geriatric and Family Mental Health Services
Date: 09/30/2011
Comment:

A proposal for Intensive Behavioral Therapy that excludes behavioral health providers. Does that make sense? Obesity is the perfect condition to show how medical and behavioral health professionals can work together to improve outcomes for Medicare beneficiaries.

Obviously medical professionals are necessary for the medical assessment and treatment of obesity. Behavioral Health providers are necessary for the assessment of and intervention in the behavioral and environmental

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Beck, Amy Date: 09/30/2011
Comment:
As a healthcare professional specializing in treatment of pediatric obesity, I am both horrified and frightened at the omission of mental health and behavioral specialists as reimbursable providers for obesity services for Medicaid-eligible patients. Successful treatment of obesity mandates significant, long-term behavior change, that psychologists, in particular, are trained and best qualified to provide. Additionally, obese children also often have other mental health barriers that must be

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Traetow, Laurie Organization: American Society of Bariatric Physicians
Date: 09/30/2011
Comment:

September 30, 2011

To Whom It May Concern:

On behalf of the 1,500 members of the American Society of Bariatric Physicians (ASBP), a national non-profit comprised of physicians dedicated to the medical management of overweight and obesity, I am pleased to provide the following comments regarding the Proposed Decision Memo for Intensive Behavioral Therapy for Obesity. ASBP agrees with the need for intensive counseling as part of a comprehensive obesity treatment program

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MacMillan, Harry Title: President
Organization: MEND Foundation
Date: 09/30/2011
Comment:

September 30, 2011

Centers for Medicare and Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Re: CAG-00423N

Dear Sir/Madam:

On behalf of the MEND Foundation, we appreciate the opportunity to submit our comments in response to the Centers for Medicare and Medicaid Services (CMS) proposed coverage decision for intensive behavioral therapy for obesity.

According to the proposed

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Richards, Thomas Title: Senior Manager, Public Policy
Organization: IHRSA: International Health Racquet & Sportsclub Association
Date: 09/30/2011
Comment:

On behalf of the International Health Racquet & Sportsclub Association - the trade association for commercial fitness centers - we are grateful for the opportunity to submit comments regarding the CMS proposed coverage decision for intensive behavioral therapy for obesity.

The proposed decision memo would require intensive behavioral therapy for obesity to occur in a primary care setting and be provided by primary care physicians or primary care practitioners.

We are

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Solomon, Zula Title: Health Systems Director
Organization: Colorado Department of Public Health and Environment
Date: 09/30/2011
Comment:

The Colorado Department of Public Health and Environment (CDPHE) is pleased to submit comments to the Centers for Medicare and Medicaid Services on the National Coverage Analysis for Intensive Behavioral Therapy for Obesity. We support this effort to expand Medicare coverage for preventive services to include effective interventions for obesity as recommended by the U.S. Preventive Services Task Force (USPSTF).

Colorado has the lowest adult obesity prevalence in the nation, but we

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Polensek, Natasha Title: MD, Assistant Professor
Organization: Oregon Health and Sciences University
Date: 09/30/2011
Comment:

As the Director of the Doernbecher Children's Hospital Healthy Lifestyles clinic, I provide the recommended services to children, and by extension, their families. I work with a multidisciplinary team that includes a nutritionist, physical therapist and child psychologist. Each member is a key component of the intensive behavioral treatment we perform. I am also a primary care pediatrician who struggles to provide a truncated version during office visits.

I strongly feel that

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Brennan, Cate Title: Associate Executive Director, Policy & Advoacy
Organization: National Athletic Trainers' Association
Date: 09/30/2011
Comment:

Sept. 30, 2011

Centers for Medicare and Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

RE: CAG-00423N

To Whom It May Concern:

The National Athletic Trainers’ Association (NATA) welcomes the opportunity to provide comment regarding the Centers for Medicare and Medicaid Services (CMS) proposed coverage decision for intensive behavioral therapy for obesity. By way of background, NATA is a

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Kaplan, MD, PhD, Lee Title: Director, External Affairs
Organization: Campaign to End Obesity Action Fund
Date: 09/30/2011
Comment:

September 30, 2011

Louis Jacques, MD
Director
Coverage and Analysis Group

Sarah McClain, MHS
Lead Health Policy Analyst
Division of Medical and Surgical Services
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Dear Dr. Jacques and Ms. McClain:

The Campaign to End Obesity Action Fund (CEOAF) is pleased to submit comments to the Centers for Medicare and Medicaid Services on the

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Gallagher, CHRIS Title: Director, Washington Office
Organization: American Society for Metabolic and Bariatric Surgery
Date: 09/30/2011
Comment:

September 30, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Blvd.
Baltimore, MD 21244

Dear Dr. Jacques:

On behalf of the American Society for Metabolic and Bariatric Surgery (ASMBS), the largest surgical society in the United States dedicated to the treatment of obesity and related diseases, I am pleased to submit the following comments regarding the Centers for Medicare &

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Johnson, Suzanne Title: Distinguished Research Professor
Organization: Florida State University College of Medicine
Date: 09/30/2011
Comment:
My expertise is in diabetes and obesity. I applaud CMS for including intensive behavioral treatment for obesity. However, I am concerned about the proposed limitation of the provider of such services to physicians, nurse specialists and physician assistants. Most of the evidence-based intensive behavioral interventions for obesity have been developed by psychologists and licensed psychologists are experts in behavior and behavior change. The psychologist on an interdisciplinary primary care

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Bedrosian, Richard Title: Director, Behavioral Health and Solution Developme
Organization: HealthMedia, Inc.
Date: 09/30/2011
Comment:

Louis B. Jacques, MD
Director, Coverage & Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C 1-09-06
7500 Security Blvd Baltimore MD 21244

Re: Proposed National Coverage Determination (NCD) for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Dr. Jacques:

On behalf of HealthMedia, Inc. (HMI), a Johnson & Johnson company, I am pleased to submit comments on the

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Dea, Francesca Title: Executive Director
Organization: The Obesity Society
Date: 09/30/2011
Comment:

September 30, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Blvd.
Baltimore, MD 21244

Dear Dr. Jacques:

On behalf of The Obesity Society (TOS), the leading scientific society dedicated to the study of obesity, I am pleased to submit the following comments regarding the Centers for Medicare & Medicaid Services (CMS) National Coverage Decision (NCD) memorandum regarding intensive

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Phillips, Steve Title: Director, Health Policy
Organization: Johnson & Johnson
Date: 09/30/2011
Comment:

Louis B. Jacques, MD
Director, Coverage & Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services

Comments Submitted Electronically Via CMS Web Site

Re: Proposed National Coverage Determination (NCD) for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Dr. Jacques:

On behalf of Johnson & Johnson’s Operating Companies, I am pleased to submit these comments and recommendations in response to the

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Nadglowski, Joe Title: President and CEO
Organization: Obesity Action Coalition
Date: 09/30/2011
Comment:

September 30, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Blvd.
Baltimore, MD 21244

Dear Dr. Jacques:

On behalf of the 27,000 members of the Obesity Action Coalition (OAC), I am pleased to submit the following comments regarding the Centers for Medicare & Medicaid Services (CMS) proposed National Coverage Decision regarding intensive behavioral counseling for the disease of

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Levi, Jeffrey Title: Executive Director
Organization: Trust for America's Health
Date: 09/30/2011
Comment:

September 30, 2011

Sarah McClain, MHS
Lead Analyst
Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Comments on Proposed Coverage Decision Memorandum for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Ms. McClain:

As a nonprofit, nonpartisan public health advocacy organization dedicated to making

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Wilson, Spence Title: Managing Member
Organization: Wilson Psychological Associates, PLLC
Date: 09/30/2011
Comment:

I am excited that CMS is proposing a mechanism for healthcare providers receive reimbursement for treating obesity in primary care, however, I have significant issues with psychologists not being included as eligible providers. As the movement towards integrated care continues, more and more psychologists are working in primary care to address medical, behavioral, and psychological issues of patients. Obesity is one particular health issue that specifically can benefit from a

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Shanbhag, Marnie Title: Psychologist
Date: 09/30/2011
Comment:
I simply do not understand. You describe a detailed intensive behavioral assessment and intervention program that psychologists are best designed to treat but exclude psychologists from the list of qualified providers. Why? We are the most highly trained professionals working in behavioral assessment and modification.
Brian, Tom J. Title: Director of COusenlign & Psychological Servcies
Organization: University of Tulsa
Date: 09/30/2011
Comment:

It is important to include psychologist as one of the categories under the definition as physician. Psychologists have prominent in designing and researching obesity treatment approaches that have strong research support for evidence based practice.
For example, see:

for example, see:

http://www.div12.org/PsychologicalTreatments/treatments/obesity_behavioral.html

Romano, Ph.D., Dr. David J. Organization: Barry University
Date: 09/30/2011
Comment:

There are a group of provider who have been left out of the categories of those identified as being able to provide behavioral therapy for obesity: Psychologists. Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity.

In relation to behavioral health, Psychologists provide the vast majority of health and behavior assessment and

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Brooks, Tricia Organization: Diabetes Advocacy Alliance
Date: 09/30/2011
Comment:

September 30, 2011

Donald Berwick, MD, MPP
Administrator
Centers for Medicare and Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue SW, Room 445-G
Washington, DC 20201

Dear Dr. Berwick:

The Diabetes Advocacy Alliance™ (DAA), a diverse group of organizations who have come together with the purpose of changing how the nation perceives and approaches the problem of diabetes, is pleased to submit comments to the

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Harris, Aaron Title: Clinical Health Psychologist
Organization: VHA
Date: 09/30/2011
Comment:
The concern I wish to voice revolves around the narrow definition of providers who ar eligible to provide these interventions. Specifically, we need to include psychologists among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. If we fail to do this, we deny beneficiaries access to psychological services that have been proven effective in treating obesity. Morover, psychologists have the most extensive training in behavioral interventions of all

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Howard, Robert Title: Managing Partner
Organization: Midtown Nutrition Care
Date: 09/30/2011
Comment:

Our Recommendation—RDs should be included a qualified providers BECAUSE the best interpretation of the USPSTF recommendation that “clinicians screen all adult patients for obesity and offer intensive counseling and behavioral interventions to promote sustained weight loss for obese adults” is one that interprets “clinicians” as including not only Primary Care Physicians (“PCPs”) as defined by Social Security Act §1833(u)(6), §1833(x)(2)(A)(i)(I) and §1833(x)(2)(A)(i)(II), but

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Wolf, MS,RD, Anne Title: Registered Dietitian and Researcher
Organization: Anne Wolf & Associates
Date: 09/30/2011
Comment:

As a clinical researcher who has been treating patients and doing obesity research for over 25 years, I am grateful that CMS is proposing coverage for treating obesity. I do have some concerns about the effectiveness, cost-effectiveness and outcomes of your proposal.

Effectiveness: First, the recognized provider (MD, NP, PA) in your proposal is not the same type of clinicians who delivered the interventions in the studies that the US Preventive Task Force reviewed (and which your

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Larzelere, Michele Organization: Louisiana State University Health Sciences Center
Date: 09/30/2011
Comment:
As a psychologist working in the primary care setting, I strongly encourage the inclusion of psychologists among the providers eligible to provide obesity treatment to patients with Medicare. Psychologists are recognized within the primary care community as the experts in patient behavior change. We are often tasked, within medical schools, with teaching behavior change interventions to physicians, therefore, it makes little sense to exclude psychologists from this activity at the patient

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Fischer, Pam Title: Director, Primary Care Mental Health
Organization: Veterans Affairs Medical Center
Date: 09/30/2011
Comment:
clinical Psychologists or health Service Provider Psychologists need to be included in the list of providers for these services. They are the ones who provide behavioral health care to these patients.
Johnson, Suzanne Title: Distinguished Research Professor
Organization: Florida State University College of Medicine
Date: 09/30/2011
Comment:
My area of clinical and research expertise is diabetes and pediatric obesity. I applaud your intent to include intensive behavioral intervention as an evidence-based approach for the treatment of obesity. However, I do not understand why the treatment profiders are specifically limited to physicians, nurse specialists, or physician-assistants; you have not included licensed psychologists despite the fact that psychologists have done some of the most important evidence-based work on developing

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Fitzpatrick, Stephanie Date: 09/30/2011
Comment:

As a recipient of a doctoral degree in clinical psychology with an interest in treatment for obesity I am concerned about the lack of language in the current policy proposal that allows clinical psychologist and behavioral specialist to be included among the list of covered providers for treatment of obesity. Clinical psychologist are well trained in the treatment of obesity and have been the primary driving force behind finding treatment techniques and concepts that work in weight mgmt.

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Emery, Erin Date: 09/30/2011
Comment:
Psychologists are the most extensively and effectively trained professionals in dealing with behavioral issues generally, health behaviors more specifically, and in particular, obesity. The majority of research on behavioral interventions for individuals with obesity and related conditions have been conducted by psychologists. Given that CMS is invested in providing effective treatments to patients by those most equipped to provide those services, psychologists MUST be included as approved

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PARKER, ANN Title: Psychologist
Organization: Atlanta Psych Associates
Date: 09/30/2011
Comment:

As a psychologist who worked in rural health clinics to integrate behavioral care with primary care, I saw the efficacy of behavioral treatment on those with chronic illness which usually was a result of obesity. I ask CMS to reconsider this proposal and include those who know behavior best; psychologists.
thank you for your consideration.

Ann McKee Parker, Ph.D.

Lofits, David Date: 09/30/2011
Comment:
Note that to exclude psychologist from providers that treat this condition is to exclude professionals who have the most extensive training in behavioral health interventions. This seems to be an absurd notion with no rational basis.
thomas, peter Title: licensed psychologist
Organization: private practice
Date: 09/29/2011
Comment:
I believe psychologists should and must be included as eligible providers of Medicare beneficiaries with obesity.Failure to do so will deprive them of access to proven and effective psychological services for this malady.Psychologist have extensive training in behavioral interventions, more so than other health care providers.Furthermore, most of the the evidence supporting behavioral interventions in the treatment of obesity was developed by psychologists.Psychologist are well versed in

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LaHaise, Kim Title: Psychologist
Organization: Sanford Health System
Date: 09/29/2011
Comment:
Psychologists MUST be included among the providers listed in this policy as we have the behavioral therapy background, training, and expertise to deal with obesity issues. As a psychologist who specializes in eating disorders, as well as weight difficulties, confining behavioral services to primary care settings only would deprive beneficiaries with obesity the ability to receive integrated care with psychologists and access to the most effective treatments for this.
Alexander, MD, MPH, FACPM, Miriam Title: President
Organization: American College of Preventive Medicine
Date: 09/29/2011
Comment:

September 30, 2011

Donald Berwick, MD
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1503-P
P.O. Box 8013
Baltimore, MD 21244-8013

Dear Dr. Berwick,

On behalf of the American College of Preventive Medicine (ACPM) and the American College of Lifestyle Medicine (ACLM), we welcome the recent Centers for Medicare and Medicaid Services (CMS) proposal to provide eligible

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Anderson, Ph.D., Norman B. Title: Chief Executive Officer
Organization: American Psychological Association (APA)
Date: 09/29/2011
Comment:

September 30, 2011

Donald Berwick, M.D.
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attn: CMS-1524-P
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00432N)

Dear Dr. Berwick:

I am writing on behalf of the American Psychological Association (APA), the largest scientific and

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Blankenship, MS RD, Jeanne Title: Vice President, Policy Initiatives and Advocacy
Organization: American Dietetic Association
Date: 09/29/2011
Comment:

September 30, 2011

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1577-P
P.O. Box 8010
Baltimore, MD 21244-8010

RE: Proposed Coverage Decision Memorandum for Intensive Behavioral Therapy for Obesity

Dear Dr. Berwick:

The American Dietetic Association (ADA) appreciates the opportunity to submit comments to the Centers for Medicare and Medicaid Services

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Bocchino, Carmella Title: EVP, Clinical Affairs and Strategic Planning
Organization: America's Health Insurance Plans (AHIP)
Date: 09/29/2011
Comment:

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 Dr. Jacques:

Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) proposed decision memo for intensive behavioral therapy for obesity (IBTO) (CAG-00423N). America’s Health Insurance Plans (AHIP) is the national association

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Finan, Stephen Title: Senior Director, Policy
Organization: American Cancer Society Cancer Action Network
Date: 09/29/2011
Comment:

Sarah McClain, MHS
Joseph Chin, MD, MS
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

September 30, 2011

Re: Centers for Medicare and Medicaid Services Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Ms. McClain and Dr. Chin:

The American Cancer Society Cancer Action Network is pleased that the Centers for Medicare and Medicaid Services (CMS)

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Lemon, Stephenie Date: 09/29/2011
Comment:

Statement in Response to Centers for Medicaid and Medicare Services Proposed Coverage Decision Memorandum for Intensive Behavioral Therapy for Obesity from the Division of Preventive and Behavioral Medicine, University of Massachusetts Medical School

Dear:

Louis Jacques, MD
Director, Coverage and Analysis Group

Tamara Syrek Jensen, JD
Deputy Director, Coverage and Analysis Group

Jyme Schafer, MD, MPH
Director, Division

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Miller-Kovach, MBA, MS, RD, Karen Title: Chief Science Officer
Organization: Weight Watchers International, Inc.
Date: 09/29/2011
Comment:

September 30, 2011

The Honorable Donald Berwick, MD
Administrator, Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC

TRANSMITTED BY EMAIL

RE: Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Dr. Berwick:

With skyrocketing rates of obesity and weight-related chronic diseases like diabetes and cardiovascular

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O'Connell Ph.D., Patricia Date: 09/29/2011
Comment:

To Whom It May Concern:

It is imperative that psychologists be included as clinicians in treatment of obesity. Psychology has a long history of not only rigorous investigation into scientifcally sound treatments for obesity, but also have been premier clinicians working in this area for some time. I personally have had extensive training in dealing with this matter and offer services not offered by other clinicians.

Regards,

Patricia O'Connell Ph.D.

Taylor, MD, PhD, AGAF, Ian L. Title: Chair
Organization: American Gastroenterological Association (AGA)
Date: 09/29/2011
Comment:

September 30, 2011

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Coverage Decision Memorandum for Intensive Behavioral Therapy for Obesity (CAG-00423N)

Dear Dr. Jacques:

The American Gastroenterological Association (AGA) is the trusted voice of the GI community, representing 17,000 members from around the globe who are

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Kelly, Jennifer Date: 09/29/2011
Comment:

Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

  • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
  • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions

    More

  • Sawhney, Alok Title: Student
    Date: 09/29/2011
    Comment:
  • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
  • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
  • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions

    More

  • Pawlowski, Carey Title: Ph.D.
    Organization: VA Palo Alto Health Care System
    Date: 09/29/2011
    Comment:

    As a licensed psychologist, I am writing in response to behavioral therapy for obesity, which is consistent with the American Psychological Association's position. The key points are as follows:

    • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating

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    Hebblewhite, Ph.D., Mary Date: 09/29/2011
    Comment:

    Comment:
    Psychologists must be included as treatment providers in treatment of obesity for the following reasons:
    * Obesity has serious circular CAUSE-AND-EFFECT relationship with self esteem. Psychotherapists treat self esteem. Medication alone cannot.
    * Weight loss and weight loss maintenance, diet and exercise require serious self discipline. More than any other branch of mental health or general medical health, more than psychiatry, psychology is the discipline that has

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    Nystrom, Bruce Date: 09/29/2011
    Comment:
    Psychologists must be included as providers for behavior therapy for obesity. Psychologists are the trained professionals to administer and supervise behavior therapy whereas other medically trained professionals are not trained to administer behavior therapy.
    Merbitz PhD, Nancy Hansen Title: Owner/ Solo practitioner
    Organization: Merbitz Health & Wellness Services
    Date: 09/29/2011
    Comment:

    I am a psychologist in private practice, in central Illinois, a rural/small town region. I am quite surprised that the memo regarding proposed services to people with obesity excludes reimbursed service provision by psychologists. It seems very odd that the professionals who typically have the most training and experience with interventions related to health behaviors would be left out of this otherwise laudable proposal. I can only speculate as to why, but the result is certain: people

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    Verschell, Mark Title: Director, LExAyN Healthy Lifestyles Program
    Organization: United States Department of Defense
    Date: 09/29/2011
    Comment:
    With all due respect, clinical psychologists are an essential component of obesity treatment protocols and should be reimbursed in equivalent fashion to the other primary healthcare providers working with this disease. Obesity is best conceptualized as a biopsychosocial disease. In fact, most patients have appropriate knowledge with regard to the first-line intervention, namely eating a balanced diet and engaging in greater volumes of physical activity. ANY Provider who has worked with this

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    Loverich, Tamara Title: Associate Professor
    Organization: Eastern Michigan University
    Date: 09/29/2011
    Comment:
    Primary care physicians and nurse practitioners are not trained as experts in behavior therapy. In order for this policy to be implemented effectively to produce real changes for those receiving these benefits, behavior therapy should be provided by behavior therapists; that is, clinical psychologists with cognitive behavioral training. To not include psychologists in this group is to effectively negate this important policy change.
    Mangel, Howard Title: NJ Licensed Psychologist
    Organization: Howard Mangel, EdD, Somerset Neuropsychological
    Date: 09/29/2011
    Comment:

    I have 26 yrs experience as a psychologist in health settings and am distressed with the policy as written on several counts:

    — The limitation of behavioral services to primary care settings is inappropriate for a number of reasons, including community based long term follow up.
    — Since psychologists provide and have developed most of the interventions for this population, our exclusion is discriminatory and cuts the patients off from the best source of info and

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    Stump, Nannette Title: Licensed Clinical Psychologist
    Organization: St. Mary's Medical Center
    Date: 09/29/2011
    Comment:
    Psychologists provide a majority of health and behavior assessments and interventions for patients with chronic and acute medical concerns. With obesity rising, psychologists should not be excluded from the team approach necessary for successful outcomes.
    Carll, PhD, Elizabeth Title: Chairperson
    Organization: United Nations NGO Committee on Mental Health
    Date: 09/29/2011
    Comment:

    Obesity as it is becoming a worldwide epidemic. The prevention and treatment of obesity must be a health care priority. However, the interventions must be comprehensive and should include all appropriate professionals who treat obesity.

    The guidelines address the physical and behavioral aspects and treatment but overlook the important mental health component that is associated with individuals who struggle with obesity in attempting to change behavior.

    The World Health

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    Theroux, Sharon Title: Co_Owner
    Organization: South Florida Psychology
    Date: 09/29/2011
    Comment:

    I am a licensed psychologist, specializing in the treatment of individuals with eating problems (anorexia, bulimia, compulsive overeating). I am shocked that psychologists are not included in your list of authorized providers. Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating

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    Strosahl, Kirk Date: 09/29/2011
    Comment:
    The proposed decision to exclude properly qualified psychologists from providing intensive obesity services is ill conceived for a number of reasons:
    1) Psychologists increasingly are functioning as core members of medical teams in specialty and primary care settings, where the vast majority of obesity is recognized and treated;
    2) Psychological treatments for obesity have been shown to produce long terms benefits that easily are comparable to those produced by medical interventions

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    Scott, BJ Organization: Pacific University
    Date: 09/29/2011
    Comment:

    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.

    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

    More

    Spring, Bonnie Title: Director of Behavioral Medicine
    Organization: Northwestern University Feinberg School of Medicine
    Date: 09/29/2011
    Comment:

    CMS is to be commended for considering how to make evidence-based obesity treatment available to the population in need of it. It is excellent that number of covered sessions matches that needed for the intensive lifestyle interventions found effective by the NHLBI Obesity Guidelines Task Force and by the U.S. Preventive Services Task Force. However, there are a few provisions of the policy under consideration that fail to match the evidence base and that are counterproductive to

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    Williams, Adrienne Date: 09/29/2011
    Comment:
    I am writing to state that psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity. Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

    More

    Silva, Delia Title: Neuropsychologist
    Date: 09/29/2011
    Comment:

    Psychologists must be included in the list of providers of these types of behavioral services. Psychologists are the leading experts in the delivery of behavioral health interventions. Psychologists have produced most of the research pertaining to behavioral health and are uniquely qualified in providing efficacious treatments. Additionally, psychologists are experts in the assessment of personality and behavioral factors that can contribute to an individual's medical condition,

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    Cantrell, Peggy Date: 09/29/2011
    Comment:
    As Director of Clinical Training at a PhD clinical psychology program that specializes in training psychologists for practice in rural primary care settings, I am acutely aware of both the need for and competency of psychologists in providing behavioral therapy for the treatment of obestity in primary care settings. Psychologists, in fact, are the best grounded behavioral health professionals in behavioral treatment approaches since it is the science of psychology that generates and evaluates

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    Gorgens, Kim Title: Clinical Associate Professor
    Organization: University of Denver
    Date: 09/29/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity-related health problems. Failing to include psychologists will deny Medicare beneficiaries access to psychological services that have been proven effective in treating obesity—arguably the core component of every intervention. Psychologists, in fact, have the most extensive training in behavioral interventions relative to all other health care professionals and

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    McNeer, Ann Date: 09/29/2011
    Comment:
    As a clinical psychologist, I have provided obesity related behavioral counseling and support. Additionally, I have been involved in assessing and treating people who have undergone weight loss surgery.
    Physicians and their office staff do not have the training nor time to serve this population adequately. They do not tend ot have a full view of the needs - both psychological and physical - needed to tackle the problems associated with weight loss and maintenance. Psychology has

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    Shaffer, Laura Title: Pediatric Psychologist, Director of Psychology Ser
    Organization: Healthy for Life!, Pediatric Obesity Clinic
    Date: 09/29/2011
    Comment:

    I am pleased that CMS sees the value of behavioral intervention for obesity as “reasonable and necessary” for the early detection and prevention of chronic illness and disability. However, as a pediatric psychologist who specializes in treating obesity in children and adolescents, I have several concerns with the proposed decision memo (CAG-00423N).

    First, I recommend expanding the definition of obesity to include the standard of practice for children and adolescents of a BMI at

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    Reviere, PhD, S.L. Date: 09/29/2011
    Comment:

    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity. Furthermore, and perhaps most important, psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral

    More

    Reid-Arndt, Stephanie Date: 09/29/2011
    Comment:

    I am concerned about this Policy and its exclusion of psychologists — psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity. Psychologists provide the vast majority of health and behavior assessment and

    More

    Caples, Heather Date: 09/29/2011
    Comment:

    I feel strongly that psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.

    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral

    More

    Nierenberg, Barry Title: Associate Professor
    Organization: Nova Southeastern University
    Date: 09/29/2011
    Comment:
    I am concerned that the rule as it is written would deny treatment by a licensed psychologist. Psychologists are specifically trained to appropriately assess and intervene in behavior change. Psychology's contribution to the literature on both assisting individuals in loosing weight and then maintaining the weight loss over the long term is considerable. Certainly other health care professionals (physicians, nurses, nutritionists etc) could play an important role but by not allowing

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    Banitt Duncan, Angela Date: 09/29/2011
    Comment:

    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

      More

    Padrone, Frank Title: Director, Inpatient Psychological Services
    Organization: Rusk Institute, NYUMC
    Date: 09/29/2011
    Comment:
    • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting

      More

    Tucker, Jeritt Date: 09/29/2011
    Comment:

    In reading the proposed CMS decision for intensive behavioral therapy for obesity, it makes little sense to me why licensed psychologists should not be included in the list of professionals who can provide such treatment.

    Not only is obesity as much an emotional and cognitive issue as it is a physical one, the field of counseling psychology has provided the majority of the evidence for the effectiveness of behavioral interventions for obesity. To not include psychologists in

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    Datz, PhD, Geralyn Date: 09/29/2011
    Comment:

    I applaud CMS for its attention to such a crucial public health issue. Obesity is a perfect example of a biopsychosocial issue that requires multidisciplinary treatment. However the exclusion of reimbursing psychologists on this proposed intervention troubles me greatly. Particularly health psychologists, and those that specialize in behavioral medicine, whom are psychologists that are explicitly trained in the brief delivery of health services for weight management and chronic disease

    More

    Wright, Stephen Date: 09/29/2011
    Comment:
    Excluding psychologists from this rule will prevent comprehensive treatment and the best standard of care for individuals!
    Valenzuela, Jessica Date: 09/29/2011
    Comment:
    Support for intensive behavioral therapy for obesity is important given the significant number of individuals affected and significant number of conditions associated with obesity. However, excluding psychologists as providers of these services will deny patients access to providers with the most extensive training in these services. While allowing for services in primary care is advantageous, limiting services to these settings is problematic. Patients need to also have access to these

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    Ferguson, Ph.D., Robert J. Date: 09/29/2011
    Comment:

    In all candor, it is stunning that the CMS decision memo for provision of intensive behavior therapy for obesity in primary care is proposing to exclude clinical psychologists from furnishing this service(CAG-00423N).

    Psychologists for decades have closely studied the neurobiologial, environmental, cognitive, behavioral and emotional factors that contribute to obesity and have designed and researched through many clinical trials behavior therapies that effectively change eating

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    Niemeier, Janet Title: Associate Professor
    Organization: Virginia Commonwealth University Health System
    Date: 09/29/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
  • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
  • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

    More

  • Schonitzer, Deborah Date: 09/29/2011
    Comment:
    Psychologists must be included as providers of these services. As a profession they have contributed to the development of evidenced based interventions for the treatment of obesity and have the most experience in implementing behavioral interventions.
    Brown, Kathleen Date: 09/28/2011
    Comment:

    Psychologists, as scientists that focus in part on behavior change, are ideally suited to work with individuals struggling with obesity. Psychologists should be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    Psychologists, of all health care professionals, have the most extensive training in behavioral interventions and have contributed most of the evidence supporting behavioral interventions for obesity. As many

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    Somers, Ph.D., Marsha Title: Licensed Psychologist
    Organization: Affiliated Psychologists, LLC
    Date: 09/28/2011
    Comment:

    It is CRUCIAL that psychologists be included in the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Psychologists have the MOST EXTENSIVE TRAINING in behavioral interventions OF ALL HEALTH CARE PROFESSIONALS and HAVE CONTRIBUTED MOST of the EVIDENCE SUPPORTING behavioral interventions for obesity. I have worked with obese patients during my career and have worked with the bariatric surgery population for 6 years. I have completed an extensive

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    Scherer, Dr. Marcia Title: Professor of PM&R
    Organization: U of Rochester Medical Center
    Date: 09/28/2011
    Comment:
    CMS wisely gives priority to consumer-centered assessment, personalized advisement, the collaborative selection of appropriate treatment goals and methods and assistance in behavior change. For this to be truly accomplished, it is essential to involve psychologists, occupational therapists and other allied health professionas and, most importantly, to adequately reward/reimburse for the necessary time to conduct an appropriate and collaborative, comprehensive assessment that focuses on (a)

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    Tomaselli, MD, FAHA, Gordon F. Title: President
    Organization: American Heart Association
    Date: 09/28/2011
    Comment:

    September 29, 2011

    Centers for Medicare and Medicaid Services
    Department of Health and Human Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Re: CAG-00423N

    Dear Sir/Madam:

    On behalf of the American Heart Association (AHA), including the American Stroke Association (ASA) and over 22.5 million AHA and ASA volunteers and supporters, we appreciate the opportunity to submit our comments in response to the Centers for Medicare and

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    Glueckauf, Robert Title: Chair
    Organization: Interdivisional Healthcare Committee
    Date: 09/28/2011
    Comment:

    This response to the CMS "Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00423N)" is provided by the Interdivisional Healthcare Committee (IHC). The IHC is an independent working group comprised of representatives from seven Divisions and Sections of the American Psychological Association that are dedicated to the practice of psychology in health settings (Clinical Geropsychology, Clinical Neuropsychology, Counseling Psychology, Family Psychology, Health

    More

    Welt, Aaron Date: 09/28/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
  • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
  • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

    More

  • Fishman, Linda Date: 09/28/2011
    Comment:

    I am writing to strongly express the necessity for including Psychologists as a provider class, to provide intensive behavioral treatment of obesity. Psychologists igsts are specifically trained as behavioral scientists and are the MOST qualified to provide these treatment services.

    Services should not be limited to primary care settings, which are geared to medical/physical treatment, and NOT to behavioral intervetions. Primary care swettings may be comfortable for some

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    Reno, Claudette Date: 09/28/2011
    Comment:
    It is imperative that psychologists be among the providers eligible to provide behavioral services to Medicare beneficiaries with obesity, as they have the most extensive training in behavioral interventions of all health care providers. Psychologists provide the majority of health and behavioral assessments and intervention services to assist patients with a variety of acute and chronic conditions. By failing to include psychologists Medicare patients will be denied access to psychological

    More

    Ainslie, Daphny Title: Psychologist
    Date: 09/28/2011
    Comment:
    Psychologists should be included among providers who deliver behavioral services to Medicare beneficiaries with obesity. Psychologists have contributed to and are trained in evidence based therapies for conditions such as obesity. Psychologists are increasingly working in primary care settings and seeing individuals with health/medical conditions in private office settings and are equipped to provide treatment in conjunction with medical providers for obesity.
    Carrizales, Sonia Organization: Texas Woman's University
    Date: 09/28/2011
    Comment:
    It is very disturbing that psychologists would be left out of this. Obese individuals do need access to medical care but they also need access to mental health care. Psychologists have extensive training in this that other medical healthcare providers do not. Please consider adding psychologists and other mental health care professionals to this policy. It would be a great disservice to those who suffer from obesity to be denied the proper mental health care.
    March, Vicki Title: Medical Director, The Lifestyle Program
    Organization: University of Pittsburgh Medical Center
    Date: 09/28/2011
    Comment:
    There is a glaring, bordering on outrageous and insulting omission here - I am a physician myself -- in fact, an internist and obesity specialist -- and although I provide some counseling, I am most definitely neither trained nor certified in behavioral modification techniques! However, psychologists, social workers, and other non-physician psychotherapists are extremely well-trained in the area of behavioral modification and are, in fact, the innovators and leaders within this very

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    Hutchison, Ashley Date: 09/28/2011
    Comment:
    The memo provided by CMS is insufficient in terms of who can furnish behavioral services to Medicare beneficiaries with obesity. This memo is lacking in including psychologists as providers eligible to deliver these services. If you fail to include psychologists in this, many recipients will not be able to obtain psychological services that have been shown to be effective in treating obesity. Of all the health professionals, psychologists have the most extensive training in intervening at the

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    Nicholas, Donald Date: 09/28/2011
    Comment:

    I am writing to comment on the importance of including licensed and appropriately trained psychologists in the behavioral treatment of obesity.

    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity. Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to

    More

    Russo, Dennis Title: Clinical Professor of Family Medicine & Psychology
    Organization: Brody School of Medicine, East Carolina University
    Date: 09/28/2011
    Comment:

    I am a licensed psychologist and Board Certified in Cognitive and Behavioral Psychology. The lack of inclusion of psychologists who have developed these techniques and who are trained for many years in their application is stunning. Please consider that:

  • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
  • Failing to include psychologists will deny beneficiaries access to

    More

  • Freeman, Kurt Date: 09/28/2011
    Comment:

    I strongly encourage CMS to allow reimbursement for services provided by psychologists to address behavioral health needs of individuals experiencing obesity. Psychologists are the best trained in behavioral health assessment and intervention approaches, have contributed the most to the scientific evidence regarding effective behavioral health approaches to obesity, and are prepared to collaborate effectively with medical and allied health professionals.

    Excluding psychologists

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    Jenkins, Amy Title: Dietitian
    Date: 09/28/2011
    Comment:
    The Registered Dietitian should be an approved practitioner working with these individuals.
    Bufford, Rodger Title: Professor of Psychology
    Organization: George Fox University
    Date: 09/28/2011
    Comment:
    Psychologists are an important group of provides who must be included among those eligible to furnish behavioral services to Medicare beneficiaries with obesity.
  • Psychologists provide the vast majority of health and behavior assessment and intervention services to assist patients with a variety of acute and chronic conditions.
  • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.

    More

  • DiMatteo, PsyD, Adriana Title: Psychologist
    Date: 09/28/2011
    Comment:

    I fully support Intensive Behavioral Therapy for Obesity, however, it is imperative that psychologists be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.

    Psychologists have the most extensive training in behavioral interventions of all health care professionals and

    More

    Berkovits, Michelle Date: 09/28/2011
    Comment:
    • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions

      More

    Jensen, Chad Date: 09/28/2011
    Comment:
    This proposed policy contains many accurate and important definitions regarding the intensive behavioral treatment of obesity. However, the proposed policy excludes psychologists from receiving reimbursement for obesity intervention services and does not attend to the reality that psychologists have the most extensive training in providing behavioral intervention generally and for obesity specifically. Moreover, psychologists have contributed the majority of the evidence regarding the efficacy

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    Tissot, Abbigail Title: Assistant Professor of Pediatrics
    Organization: Cincinnati Children's Hospital Medical Center
    Date: 09/28/2011
    Comment:

    I am writing to argue that the exclusion of clinical/health/pediatric psychologists from this proposed decision memo is unacceptable. Given that psychologists are the only doctoral-level providers with expert training in the techniques of behavioral modification/therapy, the exclusion of them as providers for Intensive BEHAVIORAL THERAPY for obesity is a remarkable oversight. Indeed, the determination that behavioral therapy for obesity is effective has been based largely upon research

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    Simon, Stacey Date: 09/28/2011
    Comment:
    I oppose this memo as psychologists are extremely important for providing effective behavioral interventions. Psychologists have the most extensive training in behavioral interventions and have contributed most of the evidence supporting behavioral interventions for obesity. Psychologists must be able to participate in these services in order to provide patients access to the best possible care.
    Bruns, Daniel Date: 09/28/2011
    Comment:

    There is a noteworthy omission in this document, which is that it leaves out psychologists. Please consider the following points:

    Psychologists have the most extensive training in behavioral interventions of all health care professionals. They are trained as scientist-practitioners, which I think is the kind of professional that you want doing these treatments.

    As researchers, psychologists have contributed most of the evidence supporting behavioral interventions for

    More

    Junger, Amy Title: RN
    Date: 09/28/2011
    Comment:
    This proposed change in Medicare that would restrict psychologists (the experts in behavioral treatments for obesity) from providing intensive behavior therapy for obesity to Medicare patients is unacceptable. This proposal would only allow this treatment to be offered by MDs, nurses, and PAs who may, or more likely, may not have specialized skills in this area. This means that Medicare patients will be denied access to the best care, likely compromising health outcomes. I feel those specially

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    janicke, david Date: 09/28/2011
    Comment:
    I strongly urge CMS to include psychologists in those professional eligible for reimbursement for treatment of obesity. The interventiosn for obesity with the most empirical support documenting its efficacy are behavioral lifestyle interventions. Psychologists have extensive expertise in this area, more so than the other practitioners listed. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    Downey, Morgan Title: Editor and Publisher
    Organization: Downey Obesity Report
    Date: 09/28/2011
    Comment:

    Sarah McClain, MHS
    Lead Analyst
    Coverage and Analysis Group
    Centers for Medicare and Medicaid Services
    Mail Stop C1-09-06
    7500 Security Boulevard
    Baltimore, Maryland 21244-1850

    Dear Ms. McClain,

    The proposed coverage of intensive behavioral counseling of adults for obesity is both indicated by its endorsement by the United States Preventive Services Task Force , subsequent literature, and two studies published in the last month.

    The Look

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    Guion, Kim Date: 09/28/2011
    Comment:
    It is critical to consider including psychologists and behaviorally trained mental health professionals in the list of providers who may be covered for services. Behavioral health specialists are specifically trained to enhance the effectiveness of health behavior change efforts for patients who are obese or overweight. In addition, pediatric patients with overweight or obesity often require behavioral health support, as adult family members need education and specific guidance to support

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    Funderburk, Beverly Title: Associate Professor of Research
    Organization: Department of Developmental and Behavioral Pediatrics
    Date: 09/28/2011
    Comment:

    I urge you to include provision of intensive behavior therapy for obesity by licensed clinical psychologists. Psychologists are major providers of behavioral health interventions, have extensive training in behavioral intervention and have contributed most of the evidence supporting behavioral interventions for obesity.

    It would be a serious oversight to deny services by psychologists in the treatment of this behaivoral health condition.

    Martin-Halpine, Loretta Date: 09/28/2011
    Comment:

    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity to ensure access to care that has been proven to be effective in treating obesity. Behavioral services should not be limited to primary care settings for the same reason. Maximizing access to these services will positively impact the costs associated with other health effects associated with obesity.

    Psychologists have the most extensive training in

    More

    Porter, Jerry Date: 09/28/2011
    Comment:
    Please reconsider this proposal and do some more research. All existing research in this area is being executed by professionals with PHDs and not MDs. This includes research being done by the NIH. This proposal would be a monumental setback for treatment in the field of Obesity Treatment. You will be denying millions of medicare recipients from receiving treatment from the most, and in some cases, only qualified, practitioners of Behavioral Therapy for Obesity. Please include

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    Leonhard, Christoph Title: Professor
    Organization: The Chicago School of Professional Psychology
    Date: 09/28/2011
    Comment:
    As a behavior therapist who is board certified in Behavioral Psychology by the American Board of Professional Psychology (ABPP), I am encouraged to see the inclusion of Intensive Behavioral Therapy for Obesity. I am shocked, however, that reimbursability will be limited to physicians or other medical primary care providers. I have trained dozens of individuals in behavioral techniques over the past 20 years - including physicians. It is my firm conviction that, to be effective, Behavioral

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    Dreyer, Meredith Date: 09/28/2011
    Comment:
    I have several concerns regarding this proposed legislation. First, psychologists were not included as providers eligible to provide Medicare beneficiaries with intensive behavioral therapy for obesity. Psychologists are the health care professionals who have the most experience and training in changing patient behaviros. Failing to include psychologists would be detrimental to patients who have shown improvement through inclusion of psychologists on multidisciplinary teams providing

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    Junger, Katherine Title: O'Grady Resident in Clinical Psychology
    Organization: Cincinnati Children's Hospital
    Date: 09/28/2011
    Comment:

    To Whom it May Concern:

    I support funding for intensive behavioral treatments for the prevention and treatment of obesity, as backed by a substantial and growing base of scientific research.

    My extreme concern about this policy stems from the proposal to restrict psychologists from providing these services. A review of the literature in behavioral treatments for obesity plainly shows that the vast amount of this work has been done by psychologists. This is appropriate

    More

    House, Amy Organization: Georgia Health Sciences University
    Date: 09/28/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity.

    More

    Belar, Cynthia Date: 09/28/2011
    Comment:
    The bulk of the scientific literature on behavioral treatments for obesity was conducted by psychologists who integrated science and practice. To have a system where psychologists are not eligible to provide the services they developed would be more than incredible, but absolutely unjust.
    Beck, Judith Title: President
    Organization: Beck Institute for Cognitive Behavior Therapy
    Date: 09/28/2011
    Comment:
    I believe that it is crucial that Medicare include psychologists among the providers eligible to furnish behavioral services to beneficiaries with obesity. Failing to do so will deny beneficiaries access to psychological services that have been proven effective in treating obesity. Furthermore,psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity.
    Hamil, Wade Title: Clinical/Neuropsychologist
    Organization: Millennium Medical Services
    Date: 09/28/2011
    Comment:
    I urge CMS to add Psychologists as eligible providers. I continue to question why CMS excludes behavioral practitioners in favor of prescribers who have minimal behavioral training, spend minimal time with patients, and opt for pharmacological solutions. As a citizen of Oklahoma, a state with one of the highest national obesity rates, I appreciate CMS adressing this health risk. Please add Psychologists as eligible providers.
    Nelson, Melanie Date: 09/28/2011
    Comment:
    Please include psychologists as service providers for intensive behavior therapy for obesity. Psychologists receive more training in conducting behavior therapy than any other discipline. Although other porfessionals may be able to give basic advice on changing behavior, many who struggle with obesity are likely to need more intensive treatment, which is well within psychologists' expertise.
    Sogg, Stephanie Title: Staff Psychologist
    Organization: MGH Weight Center, Massachusetts General Hospital
    Date: 09/28/2011
    Comment:
    I am a licensed, doctoral-level clinical psychologist working at a subspecialty obesity medicine practice at Massachusetts General Hospital. In addition to strong general academic and practical training and experience in behavior change techniques, I also have over 8 years of experience in psychosocial assessment for obesity and delivering empirically-validated behavioral treatment for obesity. Psychologists are experts in behavior change, and in fact the gold standards for behavioral weight

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    Gillaspy, Stephen Title: Associate Professor
    Organization: University of Oklahoma Health Sciences Center
    Date: 09/28/2011
    Comment:

    Although I am excited that CMS is proposing a mechanism for healthcare providers receive reimbursement for treating obesity in primary care, I have significant issues with psychologists not being included as eligible providers. As the movement towards integrated care continues, more and more psychologists are working in primary care to address medical, behavioral, and psychological issues of patients. Obesity is one particular health issue that specifically can benefit from a

    More

    Biggs, Bridget Date: 09/28/2011
    Comment:
    As a professional who treats individuals with obesity, I am gravely concerned that the proposal, as it now stands, will neither be beneficial to patients nor a cost effective use of tax payer dollars. Whereas I applaud the recognition that behavioral interventions are a standard of care for the treatment of obesity that shall be reimbursed, psychologists must be included among the providers eligible to furnish behavioral services to individuals with obesity. Psychologists have the most

    More

    Quinlan, Nicole Title: Pediatric Psychologist
    Organization: Geisinger Health System
    Date: 09/28/2011
    Comment:

    As a clinician who works directly with children and families who struggle with overweight and obesity, I applaud the CMS’ effort to provide intensive behavioral therapy to Medicare beneficiaries. As noted in the proposal, evidence shows that intensive behavioral therapy for obesity is necessary for the prevention or early detection of illness or disability. I also agree wholeheartedly with the CMS’ definition of intensive behavioral therapy as

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    Schoffner, Kindell Title: Licensed Psychologist
    Organization: Marcus Autism Center at Children's Healthcare of Atlanta
    Date: 09/28/2011
    Comment:
    As a psychologist working with children with feeding issues, including obesity, I have gained first hand knowledge of the importance and effectiveness of behavioral treatment for this issue. Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity. Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting

    More

    Gorman, Mark Date: 09/28/2011
    Comment:
    As specialists in helping people change behavior, Psychologists are uniquely qualified to treat obesity. Psychologists have the most extensive training in behavioral interventions and, more specifically, provide the majority of empirically-validated behavioral interventions to treat obesity (and related medical and psychological co-morbidities). We ought not limit behavioral services to strictly primary care settings, particularly as the field of obesity medicine grows and specializes into

    More

    LoPresti, Vanessa Title: Psychologist
    Organization: Meridian Health - Jersey Shore University Medical Center
    Date: 09/28/2011
    Comment:

    I am a psychologist with specialization in treating individuals with physical illness and disability. I have also done research in the treatment and management of obesity. I would STRONGLY oppose excluding psychologists from the list of eligible providers to furnish behavioral services to Medicare beneficiaries with obesity.

    Psychologists are specifically trained, more than any other discipline, to effect behavior change. Obesity is largely connected to one's mental health,

    More

    White, B Title: Research scientist
    Organization: public university
    Date: 09/28/2011
    Comment:

    We need to include licensed psychologists as providers of behavioral health services to Medicare beneficiaries with obesity. Psychologists are the ones who developed our empirically supported behavioral interventions for obesity and arguably have the best training and experience in providing behavioral assessment and treatment for obesity and related conditions. Excluding them among the listed providers would be a serious disservice to the public.

    Furthermore, limiting obsesity

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    Wilbert, PhD, Jeffrey Title: Clinical Psychologist
    Organization: Jeffrey R. Wilbert, PhD
    Date: 09/28/2011
    Comment:
    Psychologists must be included in the list of providers eligible to provide intervention for obesity. I have specialized in the treatment of emotional overeating and obesity for almost 20 years. Psychologists are the most highly trained professionals in the area of behavioral intervention and to exclude them as providers would be a disservice to subscribers. It is also inapprorpiate to limit the intervention to primary care sites because a psychologist's office is a reasonable location for

    More

    Yoman, Jerome Title: Clinical Psychologist
    Organization: Life Skills Resource
    Date: 09/27/2011
    Comment:
    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity. It is a disservice to effective practice and the advance of research in this area to exclude them from Intensive Behavioral Therapy for Obesity. Such problems are best addressed by a team of professionals and psychologists are essential members of such teams.
    Goertz, MD, MBA, FAAFP, Roland A. Title: Board Chair
    Organization: American Academy of Family Physicians (AAFP)
    Date: 09/27/2011
    Comment:

    September 28, 2011

    Donald Berwick, MD
    Administrator
    Centers for Medicare & Medicaid Services
    Department of Health & Human Services
    P.O. Box 8013
    Baltimore, MD 21244.8013
    Submitted via email to CAGinquiries@cms.hhs.gov

    Re: Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00423N)

    Dear Dr. Berwick:

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

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    Wyatt, CJ Date: 09/27/2011
    Comment:

    I urgently and respectfully request that psychologists be included as providers in providing intensive behavioral therapy for obesity. Psychologists are the MOST highly trained providers of behavioral interventions and have provided much of the research about this topic. Their inclusion in this treatment modality is essential.

    Benson, Stacey Title: President and CEO / Psychologist
    Organization: Benson Psychological Services, PC
    Date: 09/27/2011
    Comment:

    I think it is important for Psychologists to be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    To fail to do so will deny beneficiaries access to psychological services that have been proven effective in treating obesity.

    Are you aware that Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral

    More

    Barry, Martha Title: Lic Psychologist
    Date: 09/27/2011
    Comment:
    I have been a Medicare provider as a psychologist in Maine for approximately 15 years and many of my clients have health problems related to acute and chronic conditions. The field of psychology has much to offer all health-related behavioral therapies, including those for obesity, and is at the forefront of related research and treatment designs. As a psychologist practicing in the area of health psychology: it is imperative that psychologists be included in the list of specialties fo

    More

    Darden, Paul Date: 09/27/2011
    Comment:
    The evidence seems to support and it would be wise to allow licensed clinical psychologist to bill for the provision of intensive behavioral therapy for obesity.
    Dacey, Marie Title: Associate Professor of Psychology
    Organization: Mass College of Pharmacy and Health Sciences
    Date: 09/27/2011
    Comment:

    Psychologists should be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Psychologists have the most extensive training in behavioral interventions of all health care professionals. They have also conducted the most research and contributed most of the evidence supporting behavioral interventions for obesity.

    Also, psychologists provide the vast majority of health and behavior assessment and intervention services to

    More

    Christiansen, Heather Date: 09/27/2011
    Comment:
    Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective for treating obesity. Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions of obesity.
    Talen, Ph.D., Mary R. Title: Director, Primary Care Behavioral Health
    Organization: Northwestern University's Family Medicine Residency Program
    Date: 09/27/2011
    Comment:

    I urge you to include psychologists as primary care providers for obesity intervention. Psychologists receive extensive training in behavioral interventions, such as family therapy, motivational interviewing and cognitive behavior therapy to address chronic disease disorders such as diabetes. They should be included in the CMS PHI policy as providers and not be denied as approved providers for treating this epidemic.

    Psychologists must be included among the providers eligible

    More

    Goldman, Rachel Title: Bariatric Psychologist
    Organization: Bellevue Center for Obesity & Weight Management
    Date: 09/27/2011
    Comment:
    It is imperative that Psychologists be included among the providers elgible to provide behavioral services to individuals who are struggling with obesity and/or other weight related issues. Psychologists study human behavior. Doctors in primary care settings can make medical recommendations to individuals, but psychologists are trained in, and experienced in, helping individuals take those recommendations and make them individualized; we help implement the changes and assist in the actual

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    Illig, Dr. David Title: Psychologist and Health care author
    Organization: RightMind Programs
    Date: 09/27/2011
    Comment:
    Psychologists are the experts on behavior and emotions related to obesity and its treatment. Psychologists need to be in the forefront of treatment, not shut out from it. It would be a great disservice to the public if psychologists and mental health counselors are not included. Much of what goes on in obesity is psychological and emotional in nature. Its not mostly physical. Its emotion and behavior, and less about the body. Who are the experts on psychology and emotion and behavior???? I

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    Goodrick, George Title: Adj Assoc Prof
    Organization: Baylor College of Medicine
    Date: 09/27/2011
    Comment:

    Anyone familiar with the literature on behavioral treatment of obesity will see that psychologists dominate the field. They must be included as Medicare providers for obesity.

    G K Goodrick, Psychologist, Fellow of the Obesity Society

    Zamudio, Ph.D., Anthony Date: 09/27/2011
    Comment:
    As a psychologist providing clinical services and teaching in a major medical setting, I strongly believe that behavioral services should not be limited to primary care settings. Making access to behavioral services more convenient and available will encourage beneficiaries with obesity to utilize these services. Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    Anthony Zamudio, Ph.D.
    Director,

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    Teeter, Wes Date: 09/27/2011
    Comment:

    Limiting the provision of Intensive Behavioral Therapy to the list of CMS approved providers such as you have is not consistent with a policy of providing evidence based services for patients under the care of the most thoroughly trained practioners. Psychologists, as part of their graduate training, get much more exposure to and practice in the methods of Behavior Therapy both prior to graduation and certainly during the course of their subsequent clinical practice than medically trained

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    Boober, Becky Title: Program Officer
    Organization: Maine Heatlh Access Foundation
    Date: 09/27/2011
    Comment:

    The proposed rule promotes the worthy interventions of:

    1. “Screening for obesity in adults using measurement of BMI calculated by dividing weight in kilograms by the square of height in meters (expressed in kg/m2);
    2. Dietary (nutritional) assessment; and
    3. Intensive behavioral counseling and behavioral therapy to promote sustained weight loss through high intensity interventions on diet and exercise.”

    While #1-2 in the above list are best

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    Cushing, Christopher Date: 09/27/2011
    Comment:
    The decision to exclude psychologists from the proposed memo (CAG-00423N) on intensive behavioral care for obesity is baffling and inconsistent with the large literature base on effective treatments for overweight and obesity. Competent practice of behavioral therapy is not within the purview of the approved practitioners listed in CAG-00423N. Surely, physicians, nurse practitioners, and physician assistants play an important role in the screening and assessment of overweight and obesity and

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    Greenberg, isaac Title: Clinical Psychologist
    Organization: Mount Auburn Hospital, Cambridge, MA
    Date: 09/27/2011
    Comment:
    Behavior Therapy for obesity must include trained Psychologists.
    There is no evidence that MD's or any other discipline is as qualified as Psychologists to provide behavioral care.
    A quick review of the obesity treatment literature will show that the vast majority of the research and treatment has been carried out by Psychologists, not MD's, not nurses.
    Why in the world were Psychologists not included in the caregiver mix?
    Simonian, Susan Title: Professor /Licensed Clinical Psychologist
    Organization: College of Charleston/Medical University of South Carolina
    Date: 09/27/2011
    Comment:
    CMS recently proposed a rule for obesity treatment in primary care that excludes psychologists from billing for these services. This exclusion is contrary to data which support the key role of psycholigists in treatment and treatment effectiveness/outcome research in populations with obesity.Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity for several reasons. First, failing to include psychologists will deny

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    Davidson, Paul Title: Behavioral Director
    Organization: Tufts Medical Center Weight and Wellness Center
    Date: 09/27/2011
    Comment:
    As the Behavioral Director of the Tufts Weight and Wellness Center, and an Assistant Clincial Professor of Psychiatry at Tufts School of Medicine, I would suggest that your definition of approved providers be expanded to include licensed psychologists. The extent of behavioral training that clinical psychologists in particular may have is at the highest level within the mental health field. In order to qualify to become a center of excellence in bariatrics, there are extensive requirements

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    ODonnell, Ronald Title: Director, Behaivoral Health
    Organization: Arizona State University, Doctor of Behavioral Health
    Date: 09/27/2011
    Comment:
    I am the director of a new doctoral degree program at Arizona State University, the Doctor of Behavioral Health. This is an upgrade for master's degree behavioral clinicians interested in an applied doctorate specializing in integrated behavioral care (www.dbh.asu.edu) that was developed by Nicholas A. Cummings, a leader in integrated care. I recommend that our new DBH degree, as well as Ph.D., Psy.D., and LCSW licensed psychologists and social workers be added to the list of eligible

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    Keenan, Margaret Title: Director, Health Psychology (PhD)
    Organization: Christiana Care Health System, Delaware
    Date: 09/27/2011
    Comment:
    I urge you to include psychologists among the providers eligible to provide behavioral services to Medicare beneficiaries with obesity. As someone who has worked with this population for many years, I can say that our extensive training in behavioral interventions can support the provision of quality evidenced-based treatment. These services should not be limited to pirmary care settings. My expertise is used to train family medicine residents in using the 5-A framework for interventions, so

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    Driscoll, Ph.D., Kimberly Title: Licensed Psychologist and Assistant Professor
    Organization: Florida State University College of Medicine
    Date: 09/27/2011
    Comment:
    Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity. It would be irresponsible to exclude psychologists from being able to provide (and be reimbursed for) these services as they are the behavioral experts. Excluding psychologists is damaging to a true multidisciplinary approach and such services should not be limited to the primary care setting.
    Lawrence, Joshua Date: 09/27/2011
    Comment:
    Include psychologists! Psychologists have been involved in the research related to behavioral change and obesity for decades, and have more experience and training for the intensive treatment of obesity than any other professional. The exclusion of psychologists takes away essential resources and expertise for individuals suffering from obesity. An examination of the literature related to obesity will clearly demonstrate the necessity for including this group. Not including psychologists

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    Wallston, Kenneth Title: Professor of Nursing
    Organization: Vanderbilt University Medical Center
    Date: 09/27/2011
    Comment:
    Although I, myself, no longer work with overweight or obese clients on Medicare, I am very troubled by the fact that psychologists are not included in the list of providers who can be reimbursed for providing intensive behavioral therapy for obesity. Psychologists have been and continue to be at the forefront of developing and delivering behavioral therapies for weight management, and the research has shown that they do so on a cost-effective basis.
    Coatley, Megan Title: Founder & Coach
    Organization: SPARK Behavior Solutions, LLC
    Date: 09/27/2011
    Comment:

    Greetings -

    I am a master's level psychologist and Board Certified Behavior Analyst and I currently provide behavior therapy and coaching to help others initiate and maintain healthy habits. I recently learned about the new NCA on Intensive Behavior Therapy for Obesity and appreciate this opportunity to comment on the frequency and credentials necessary for effective service.

    Frequency: With intensive behavior therapy, BCBAs typically teach clients to track data on

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    Rose, Jonathon Title: Director, Outpatient Spinal Cord Injury Psychology
    Organization: Dept. of Veterans Affairs
    Date: 09/27/2011
    Comment:
    Psychologists are the health care professionals with the most training and experience in behavioral intervention, yet they are inexplicitly excluded from reimbursement as providers for weight loss intervention procedures in this proposal. The MOVE! program highlighted in the literature review was developed by VA Psychologists. Primary care physicians are well-trained to assess obesity and to educate patients about associated health risks and options. They typically lack training in

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    Martin, David Title: Chief Psychologist, Professor
    Organization: Harbor-UCLA Medical Center, Geffen School of Medicine
    Date: 09/27/2011
    Comment:
    Psychologists should be included as providers of behavioral interventions for obesity. Much of the research conducted on behavioral interventions to reduce obesity has been in the realm of psychological services; restricting this service to physicians, nurse practitioners, and physician assistants denies patients care that is frequently provided by psychologists. Psychologists actually provide behavioral interventions for health and health improvement across a spectrum of health behaviors,

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    Bourdeau, Teri Title: Clinical Assistant Professor
    Organization: Oklahoma State University Center for Health Sciences
    Date: 09/27/2011
    Comment:
    • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions

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    Hutchings, Philinda Date: 09/27/2011
    Comment:
    Professional Psychologists should be included as covered providers of behavioral counseling for obestity. Psychologists are some of the major providers of both the research proving efficacy of behavioral counseling for obesity, and some of the most effective providers. Failure to include psychologists as approved providers will restrict patients' access to the needed and effective service, and deny them the benefits of psychological treatment to reduce mobidity and mortality. We train our

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    Power, Stephanie Organization: Tufts Medical Center
    Date: 09/27/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Failing to include psychologists will deny patients access to psychological services that have been proven effective in treating obesity. Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for obesity.
    Greeson, Jeffrey Title: Clinical Psychologist
    Organization: Duke University Medical Center
    Date: 09/27/2011
    Comment:

    Dear CMS Leadership,

    For a numebr of reasons outlined below, psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Psychologists are trained in human behavior and specialize in understading and promoting healthy, lasting behavior change, which is necessary to treat & prevent obesity. Compared to psychology, current biomedical training includes a much more limited focus on behavioral therapy interventions,

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    Clark, Molly Date: 09/27/2011
    Comment:

    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.

    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral interventions for

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    Stewart, Karen Title: Assistant Professor
    Organization: Virginia Commonwealth University Health Systems
    Date: 09/27/2011
    Comment:

    Psychologists are uniquely qualified to treat obesity. As specialists in human behavior, we have a strong evidence base that documents the success of behaviorally based interventions. Further, it is well documented that engagement in such interventions is a strong predictor of successful outcomes. We have a strong evidence base showing that motivational interviewing (MI) approaches enhance such engagement. Psychologists have the unique combination of clinical and research training that

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    forsythe, Laura Date: 09/27/2011
    Comment:
    • Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity.
    • Failing to include psychologists will deny beneficiaries access to psychological services that have been proven effective in treating obesity.
    • Psychologists have the most extensive training in behavioral interventions of all health care professionals and have contributed most of the evidence supporting behavioral

      More

    Freeman, Kurt Date: 09/27/2011
    Comment:
    I strongly urge CMS to ensure that patients have access to psychologists to asssit with behavioral health care related to obesity. Psychologists provide the vast majority of behavioral health care, have contributed the most to the evidence base on behavioral health interventions for obesity, and are most prepared to address the complex needs of patients with obesity by addressing boht psychosocial and behavioral health challenges. Not covering access to psychologists for treatment of obesity

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    Lagges, Ann Title: Asst Prof. of Clin. Psychology in Clin, Psychiatry
    Organization: Indiana University School of Medicine
    Date: 09/27/2011
    Comment:

    I am a psychologist with a multi-disciplinary pediatric obesity program and would like to comment on the exclusion of doctoral level psychologists as providers of behavioral interventions for obesity in this proposed rule.

    Psychologists are currently heavily integrated into both primary care and specialty care settings to provide behavioral interventions related to a variety of chronic illnesses, including obesity. Excluding psychologists will limit access to behavioral

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    Renn, Brenna Title: Doctoral Student, Clinical Psychology
    Organization: University of Colorado, Colorado Springs
    Date: 09/27/2011
    Comment:
    Psychologists must be included among the providers eligible to furnish behavioral services to Medicare beneficiaries with obesity. Psychologists have the most extensive training in evidence-based behavioral interventions of all healthcare professionals; therefore, failing to include psychologists would deny Medicare beneficiaries access to these services. Additionally, these services should not be limited to primary care settings. Obesity is an epidemic in the U.S. and we should make

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    Glaros, Alan Title: Associate Dean
    Organization: Kansas City University of Medicine and Biosciences
    Date: 09/27/2011
    Comment:
    The proposed regulation is an important step forward in the care of obese individuals. It could be improved by ensuring that appropriately licensed health care providers, including clinical health psychologists, are among those who may provide services.
    Reichbaum, Lee Title: Licensed Psychologist
    Organization: University of Pittsburgh teaching faculty; Private Practice
    Date: 09/26/2011
    Comment:

    I hope to keep my comment brief and focused related to the breadth of approved providers of behavioral interventions for obese patients. I am a Ph.D psychologist who assesses patients related to many types of medical procedures: readiness for device implants, organ transplants, bariatric surgery and subsequently psychological symptoms that result from those procedures.

    The assessment of the obese and bariatric surgery candidate is meant to be contextual and add to the success of

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    Mickow, Brenda Organization: Mayo Clinic
    Date: 09/26/2011
    Comment:

    The NCA states "For the purposes of this proposed decision memorandum a “primary care physician” and “primary care practitioner” will be defined consistent with existing sections of the Social Security Act (§1833(u)(6), §1833(x)(2)(A)(i)(I) and §1833(x)(2)(A)(i)(II))." We propose to expand the list of practitioners to include appropriately trained staff, such as registered nurses, who are part of the health care team and billing "incident to" the physician or nonphysician

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    Saules, Karen Date: 09/26/2011
    Comment:
    The literature cited to suppport the Decision Memo for Intensive Behavioral Therapy for Obesity is largely research conducted by behavioral scientists, but they are being exluded from providing services (or, more specifically, denied being reimbursed for them). It is behavioral health providers who have developed these interventions and who have been trained to deliver them. Therefore, they are best equipped to provide high quality behavioral therapy for obesity, yet under this Decision, it

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    Rasin-Waters, Donna Title: President
    Organization: New York State Psychological Association
    Date: 09/26/2011
    Comment:
    We urge CMS to add clincial psychologists to the proposed regulations. Psychologists are trained in assessment, behavioral intervention and outcome data collection critical to the treatment of obesity.
    Donna Rasin-Waters, PhD
    Psychologist
    Blazier, Heather Title: Clinical Dietitian
    Date: 09/26/2011
    Comment:
    I am so pleased to see medicare realizing the importance of covering intensive therapy for obesity. Although there are specific guidelines that it would be a physician led program, I don't see additional guidelines as to the members of an effective multi-disciplinary team. I would suggest that certain disciplines (such as a Registered Dietitian, Licensed Counselor, etc) should be included in order to be reimbursed fully.
    Koch, Ellen Title: Associate Professor
    Organization: Eastern Michigan University
    Date: 09/26/2011
    Comment:
    Although providing coverage for obesity treatment is essential, health psychologists or licensed psychologists who are trained in behavior therapy have the training necessary to provide this service most effectively and should be included on the list of providers. Individual who struggle with obesity need both emotional and motivational issues addressed in treatment. Only health psychologists or behavior therapists are trained and qualified to provide this type of assistance in facilitating

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    Strahan, Esther Date: 09/26/2011
    Comment:

    It seems a real omission that behavioral health providers are not listed with this NCA. Why not have behavioral health interventions done by those who have the greatest expertise in the area of designing and implementing treatments for behavior change (e.g. clinical psychologists)?
    Thanks for your time,

    Esther
    Larkin, Kevin Date: 09/26/2011
    Comment:
    Given the dramatic increase in obesity in the US and around the world, I am glad to see CMS paying attention to the evidence-based approaches for assessing and treating patients who meet criterion for obesity and those at risk for becoming obese. However, it is disconcerting to learn that behavioral health psychologists, those who are trained best in this evidence-based practice and who were responsible for generating the evidence base upon which it is founded, are excluded from the list of

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    Blount, Alexander Title: Professor of Family Medicine and Psychiatry
    Organization: University of Massachusetts Medical School
    Date: 09/26/2011
    Comment:

    While all of us applaud the attempt to offer coverage for evidence based treatment for obesity, this proposal flies in the face of enlightened steps taken by ARHQ, HRSA, SAMHSA and even elsewhere in CMS to make behavioral health services (mental health, substance abuse, and health behavior change) available to patients in primary care by supporting the addition of properly trained behavioral health clinicians to the primary care team. The idea that the physician will add these services to

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    Mirsky, Jeremy Title: Clinical psychologist, behavioral medicine
    Organization: Fallon Clinic
    Date: 09/24/2011
    Comment:

    The omission of clinical health psychologists from the proposal is surprising and unfortunate. Speaking as a health psychologist, we have extensive knowledge and training in assessment of eating behaviors and in behavior modification/lifestyle change. Please revise the proposal to include clinical/health psychologists.

    Jeremy E. Mirsky, PhD

    King, MA, BCBA, Jennifer Date: 09/23/2011
    Comment:

    I am writing about intense behavior therapy for obesity in seniors. This type of treatment should be delivered by a behavior therapist, such as a Board Certified Behavior Analyst or a clinical psychologist trained in cognative behavioral psychology. An inter-disciplinary approach with a nurse, physician and dietician would be best. However, this problem is not just about nutrition, but about behavior and psychology, and that discipline should be highly involved. Behavioral psychology is a

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    Lenssen, Polly Date: 09/23/2011
    Comment:

    Proposed Decision Memo for the Intensive Behavioral therapy for Obesity by CMS it is wonderful to see Medicare supporting intensive therapy for treatment of obesity which we expect will lower health care costs associated with the multitude of co-morbidities. I have two comments:
    1. Why are not registered dietitians with training and experience in motivational change, cultural competency in food and eating habits, and expertise in nutritional content of food included as qualified

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    Cobb, Alison Date: 09/23/2011
    Comment:
    I am a psychologist who regularly provides empirically-supported cognitive and behavior therapies for obesity. It is important that behavioral health providers be included in this coverage policy.
    Duff, Johnathan Date: 09/23/2011
    Comment:
    Considering the behavioral nature of the treatment for obesity, it seems absurd not to include psychologists on the list of providers for this type of intervention. Psychologists are an invaluable resource to assess and treat individuals struggling with issues related to obesity, particularly those of a behavioral nature.
    Davis, Catherine Title: Professor of Pediatrics
    Organization: Georgia Health Sciences University
    Date: 09/23/2011
    Comment:

    It is bizarre that this proposed policy recommends intensive behavioral therapy for obesity based on substantial evidence provided by studies of interventions implemented primarily by behavioral specialists (e.g., psychologists, dieticians, certified exercise experts) while limiting coverage to primary care providers (physicians, NP, CNS, PA) and not permitting coverage of treatments provided by behavioral specialists. A primary care practitioner must be able to refer to qualified

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    Williams, Dr. Lynn Title: Clinical Health Psychologist
    Organization: Mind Health, PLC
    Date: 09/23/2011
    Comment:
    As both an MSN and a clinical health psychologist I could not agree more about the need for intensive behavioral therapy for obese patients. I have and do hundreds of psychological evaluations for bariatric surgery. I also treat non-surgical obese patients. However, I am appalled that the CMS stance has excluded psychologist from "behavioral therapy". Surely, this is an unfortunate oversight. That said, I am also in school at age 61 for my Post-Master's Certificate as a Family Psychiatric

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    Corsica, Joyce Date: 09/23/2011
    Comment:
    Why aren't psychologists on the list of covered providers? The recommendation is for intensive behavior therapy and counseling, which is what psychologists, particularly those specializing in obesity, are trained to do, In fact, psychologists who have specialized in weight management are the most qualified to administer these interventions. Psychologists MUST be added to the covered health providers.
    Peterson, Michelle Title: Behavioral Psychologist
    Organization: Eastern Virginia Medical School
    Date: 09/23/2011
    Comment:
    Please strongly consider adding behavioral health providers to the list of qualified professionals who can provide treatment for obesity. These providers, such as health psychologists, are extremely qualified in the area of behavior change and have contributed to tremendous gains in the field.
    Sydeman, Ph.D., Sumner Date: 09/23/2011
    Comment:
    The exclusion of licensed psychologists, as behavioral health care providers, for treatment of obesity, which is caused in large part by lifestyle behavior factors, should be changed to include psychologists. The research on effectiveness of psychological/behavioral intervention clearly indicates the effectiveness of such interventions. See any work by Kelly Brownell. --Dr. Sydeman
    Pagoto, Sherry Title: Chair, Obesity and Diabetes Policy Action Group
    Organization: Society of Behavioral Medicine
    Date: 09/23/2011
    Comment:

    Dear:

    Louis Jacques, MD
    Director, Coverage and Analysis Group
    Tamara Syrek Jensen, JD
    Deputy Director, Coverage and Analysis Group
    Jyme Schafer, MD, MPH
    Director, Division of Medical and Surgical Services
    Sarah McClain, MHS
    Lead Health Policy Analyst, Division of Medical and Surgical Services
    Joseph Chin, MD
    Medical Officer, Division of Medical and Surgical Services

    These comments are submitted on behalf of The Society of Behavioral

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    Cline, Monica Date: 09/22/2011
    Comment:
    While this appears to be a great policy, psychologists should be included in the providers included for coverage. Psychologists play an extremely important role in providing behavior therapy for obesity, many times delivering this service in clinical settings, and should be covered.
    Czech, Stephanie Date: 09/20/2011
    Comment:
    It is important that psychologists are covered for this service, given that they are often the professionals delivering it in clinical settings.
    starbird, dannel Title: psychologist
    Organization: Behavioral Care Center
    Date: 09/18/2011
    Comment:
    Dear Sirs: It is gratifying to find that behavioral therapy may be made available to obese patients as a Medicare covered service. I strongly support that effort. But psychologists must be made providers in any such offering. Psychologists developed behavioral therapy, are its greatest experts, do the research on what works, and are central in primary care delivery of behavioral health in integrated systems. Include the experts too.
    Jenkins, Danielle Date: 09/15/2011
    Comment:
    This is great news and a wonderful proposal EXCEPT that psychologists, who invented behavior therapy for obesity and are often the professionals delivering the treatment in clinical settings do not appear to be included in the coverage, only “physicians.” It is SO important for psychologists to be covered to provide the necessary treatment which is within their scope of training and practice.
    Peyerl, Naomi Title: PhD
    Organization: Sanford Health
    Date: 09/15/2011
    Comment:
    I am writing to express my enthusiasm for this proposal and also my concerns. As a mental health professional, I think that taking behavioral therapy into account when treating obesity is a step in the right direction. However, my concern with this proposal is that only physicians are listed as covered under treatment. Psychologists and other mental health professionals are highly trained in behavioral techniques and treatments and could provide valuable services for obesity. Especially, as

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    Butler, Mary Date: 09/15/2011
    Comment:
    I have no authority to be talking about such things. However, my mother has been struggling with obesity for most of her life. Our family doctor has spoken with her about her weight and talked with her about steps she could take to lose it. However, my mother's weight issues have surpassed the medical definition. She knows that she is unhealthy, she knows she should lose weight but has extreme difficulty overcoming the psychological challenges involved in fighting obesity. Her weight is

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    Gordon, Kristina Date: 09/14/2011
    Comment:
    This is a wonderful, much needed policy. However, it should also include psychologists as well as physicians. Psychologists, particularly health psychologists, are specifically trained to help patients make the kinds of behavioral changes necessary to address obesity, thus they should be included in this initiative.
    GALLEHER, PHD, ABPP, DR. GAY Title: Board Certified Clinical Psychologist
    Date: 09/14/2011
    Comment:
    The American Psychological Association defines psychology as " the study of the mind and behavior. The discipline embraces all aspects of human experience-from the functions of the brain to the actions of nations, from child development to the care of the aged. In every conceivable setting from scientific research centers to mental care services,'the understanding of behavior is the enterprise of psychologists'." Include psychologists in the plan to treat obesity. Gay Galleher, PhD, ABPP Board

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    Magnuson, Elise Date: 09/14/2011
    Comment:
    Given the wide range of emotional and behavioral issues that are associated with obesity it seems strange not to allow psychologists to be reimbursed for working in this area. I strongly urge you to include psychologists among those who are reimbursed for this work. Elise
    Moore, Geoffrey Title: Director of Clinical Services
    Organization: Cayuga Center for Healthy Living
    Date: 09/14/2011
    Comment:

    While I am in favor of this, particularly so for persons with type 2 diabetes, CMS should also cover such services when the PCP desires to refer the patient to an integrated weight-loss / lifestyle modification program. In the area of central New York where I practice, less than 5% of PCP's are prepared to do this kind of work within their practice and most don't feel competent to do so. As an internist / sports medicine physician deeply involved with the American College of Sports Medicine

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    Thorpe, Geoffrey Title: Professor
    Organization: (I am not writing as a representative of the university.)
    Date: 09/14/2011
    Comment:
    It is not clear from what I read where psychologists fit into this. Behavior therapy for obesity was largely pioneered by psychologists. I applaud encouraging primary care physicians to include behavioral interventions in their plans of care, but I wonder if all physicians are themselves qualified in behavior therapy? It is not "counseling;" it can be a scientific-clinical specialty to which a professional may devote his or her entire career.
    I am a psychologist, board certified in

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    Ryan, Katherine Title: Clinical Psychologist -- Program Manager
    Date: 09/14/2011
    Comment:
    This is a very important proposal. Behavioral therapy for obesity is an evidence based practice that leads to significant health improvement. Of concern, this proposal does not include psychologists as providers. Behavioral therapy is best practice for a psychologist working with someone to manage weight and the evidence to suggest behavioral therapy has some efficacy for obesity comes largely out of the psychology world. To excluse the psychology profession from providing coverable

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    Matranga, Ph.D., ABPP, Jeff Date: 09/13/2011
    Comment:

    Psychologists need to be included in this.

    Psychologists have probably been the main developers of empirically-grounded interventions and are a major provider of such services.

    Thank you very much,

    Jeff
    Antonacci, Paula Title: RD, LD
    Organization: Nutrition Spectrum, LLC
    Date: 09/13/2011
    Comment:

    It is exciting to see that Intensive Behavioral Therapy is being considered as a covered benefit for the treatment of obesity. I have worked in a private practice setting for 20 years treating emotional eating issues, and a significant number of my clients are on SSI disability, with Medicare as their insurance. There is no question that their weight is affecting their immediate health, quality of life, mobility, and long-term morbidity. While I try to make the service affordable to this

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    Tipping, Ph.D., Lenore Title: Psychologist
    Organization: sole practitioner
    Date: 09/13/2011
    Comment:
    The treatment recommendations for obesity omit the fact that Psychologists are the providers trained to do cognitive-behavioral therapy, and that includes working with obesity issues. The counseling portion of this treatment, and management of the behavioral aspects would best be managed by licensed psychologists rather than physicians. The proposed plan limits the providers to physicians and other medical providers who are not specifically trained in behavioral counseling. This omission

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    Greenspan, Marie Title: Psychologist
    Date: 09/13/2011
    Comment:
    As a doctoral-level psychologist with decades of clinical experience, I am incredulous that an initiative entitled "Intensive Behavioral Therapy for Obesity" could possibly be expected to be successful without the inclusion of the uncontested experts in behavioral therapy, psychologists. This proposal, excluding psychologists as it does, defies logic.
    Prescott, David Title: Assistant Professor, Director of Healthcare Studie
    Organization: Husson University
    Date: 09/13/2011
    Comment:
    I strongly support CMS' intention to provide behavioral therapy for obesity. As a psychologist who has worked in bariatric surgery for the past decade, I would suggest that psychologists be included as eligible providers for this benefit. Our experience at Eastern Maine Medical Center in Bangor, Maine has been that physicians are able to provide this in some cases, but in others they prefer to refer to a provider with more training in behavior modification.
    Kahn, Psy.D., Monique Date: 09/13/2011
    Comment:
    As a psychologist in private practice, I routinely provide behavioral health services to individuals struggling with obesity. Because of the advanced training psychologists have in this area, it puzzles me that as a profession we would be excluded from delivery of this service under this current proposal, and I urge you to reconsider. With obesity being at epidemic levels, qualified and highly skilled professionals must be made available to those in need of these services. I routinely hear

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    King, Danielle Date: 09/13/2011
    Comment:
    I am strongly in favor of providing intensive behavioral therapy to address obesity. I would like to advocate for primary care pyschologists to be approved to provide this service.
    Loudermilk, Sara Title: Behavioral Health Consultant
    Date: 09/13/2011
    Comment:
    It is imperative for psychologists to be covered for the treatment of obesity because many times psychosocial issues are often underlying barriers to health behavior change and weight management.
    johansen, kara Title: Clinical Psychologist
    Organization: Cherokee Health Systems
    Date: 09/13/2011
    Comment:
    This is good news EXCEPT that psychologists, who invented behavior therapy for obesity and are often the professionals delivering the treatment in clinical settings do not appear to be included in the coverage, only “physicians.” it is essential that psychologists be covered to provide the necessary treatment which is within their scope of training and practice.
    Prescott, Ph.D., Diana L. Title: Clinical Psychologist
    Organization: Hampden Psychological Consultation, PLLC
    Date: 09/13/2011
    Comment:
    It would be important to include psychologists in the coverage for this service. My colleagues and I work in the obesity field and understand the importance of our significant training in behavioral health, including assessment, in improving health outcomes for patients. Please assure the psychologists providing these important behavioral health services are covered. Thank you.
    Khatri, Parinda Date: 09/12/2011
    Comment:

    Psychologists should be approved providers for this important intervention. A significant amount of the literature on management of obesity has been conducted and developed by psychologists. Moreover, psychologists have substantial training in a wide scope of health behavior change areas and are well suited to this intervention.

    Talen, Mary Title: Director, Primary Care Behavioral Health
    Organization: Northwestern Family Medicine Residency
    Date: 09/12/2011
    Comment:

    Please include licensed psychologists in your list of providers for intensive behavioral therapy for obesity. Psychologist have the required knowledge base, clinical skills and professionalism to effectively and efficiently deliver this form of treatment. Their training far exceeds the training that physicians receive in behavioral treatments for obesity.

    Mary R. Talen, Ph.D.
    Director, Primary Care Behavioral Health
    Psychologist
    Northwestern University Family

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    Hegarty-Roach, Mia Date: 09/12/2011
    Comment:
    I am excited for the recognition of cognitive behavioral methods as effective and essential in the treatment of obesity. I am disappointed to see that this is only a covered service for physicians to provide and does not include psychologists. Psychologists are certainly qualified, cerainly as much as physicans, to be providing this type of service. Please include psychologists as providers of this very important and worthwhile service.
    Ruddy, Nancy Title: Faculty
    Organization: Mountainside Family Practice Residency
    Date: 09/12/2011
    Comment:
    Thrilled that CMS is creating a mechanism for this problem to be addressed directly with evidence based care. Confused as to why this care, as per the policy in its current form, limits the providers of this care to physicians? While some physicians have specific training in this area to develop these competencies, all health psychologists have these competencies in their training. Please revisit the provisions regarding who can provide these services to include appropriately trained

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    Baca, Louise Title: Dr.
    Organization: Argosy University/Phoenix
    Date: 09/12/2011
    Comment:
    I am a psychologist who knows the value of being part of the team treating obesity. Please include psychologists as providers.
    Bean, Melanie Title: Assistant Professor of Pediatrics
    Organization: Children's Hospital of Richmond/ Virginia Commonwealth Universit
    Date: 09/12/2011
    Comment:
    This proposal is an excellent advancement in furthering the medical communities ability to care for patients with obesity. Psychologists appear to be excluded from this proposal- it is the psychologists who are trained in and who perform the behavioral interventions for patients with overweight and obesity. It is extremely important that these trained specialists are also reimbursed for their important role in addressing this public health issue.
    Barnes, Diane Title: Registered Dietitian
    Date: 09/12/2011
    Comment:
    Everything is right about this plan except that the provider is a physician. Physicians do not have the training, time, sensitivity or patience to follow the very well-thought out 5-A framework. This process is what registered dietitians, counselors and certified health coachs already do. Unfortunately, reimbursement is minimal and often must come out of an individual's pocket. Physicians WILL NOT take the time to follow this process; they will, however, be more than willing to collect the

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    Norton, Margo Title: Psychologist
    Date: 09/12/2011
    Comment:
    I would like to suggest that licensed clinical psychologists be considered as providers who might administer behavioral obesity treatment. As a VA psychologist currently, where psychologists are involved with the weight loss program, and a former clinician at an eating disorder clinic, I am very well aware of how beneficial psychologists trained in cognitive and behavioral therapies are as part of any comprehensive weight loss program.
    O'Neill, George Title: clinical psychologist
    Organization: Knowlton, O'Neill & Assoc., PC
    Date: 09/12/2011
    Comment:
    It is appropriate to cover behavior therapy (BT) for obesity. To do so has broad positive health implications. But to not cover psychologists providing this service borders on the ridiculous. Psychologists developed BT; psychologists have published most of the research on BT, including most of the research on BT for eating disorders. Psychologists are the experts on BT. Medical schools hire psychologists to teach BT to medical students and residents. Why would you not cover those with

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    Cavett, Angela Title: Psychologist
    Organization: Knowlton, O'NEill and Associates
    Date: 09/12/2011
    Comment:
    Behavioral therapy was created by psychologists and is within psychologists' domain of practice. Yet this does not include psychologists as possible providers. This confuses me as many who currently offer the service and have been trained in the approach are psychologists. I believe this should be reconsidered.
    De Young, Kyle Title: Assistant Professor of Psychology
    Organization: University of North Dakota
    Date: 09/12/2011
    Comment:
    The likely benefits to the public of this proposal would be substantially strengthened if clinical psychologists, who are most often trained in behavioral therapy, were to be reimbursed for the delivery of behavioral therapy for obesity in addition to PCPs. It is not sufficient to reimburse for services found to be efficacious. One must ask by whom such services were delivered when they were found to be efficacious. The extant literature for the behavioral treatment of obesity would point

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    Doerner, Ph.D., Mark Date: 09/12/2011
    Comment:
    This is a prime example of why Psychologists should be included in the Physician definition under Medicare/Medicaid. Psychologists are the known experts of behavioral therapies; in fact, Psychologists are the originators of behavioral therapy for obesity and myriad other health problems! Why are the experts in a proven field of treatment being excluded? How does it serve the public to leave effective treatment in the hands of providers who are less knowledgeable and more expensive? I

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    Parkhouse, Nichole Date: 09/12/2011
    Comment:
    Given that psychologists developed behavioral therapy treatment, psychologists should be covered to provide the therapy.
    Ertelt, Troy Date: 09/11/2011
    Comment:
    It is certainly a positive step forward for Medicaid and Medicare to cover Intensive Behavioral Therapy for Obesity; however, an obvious problem exists in that psychologists are not listed among the providers who would be allowed to provide this service and be reimbursed for it. The behavioral techniques developed for the treatment of obesity were, by and large, developed by psychologists, and psychologists should be included among providers who can be reimbursed for this service.
    Powers, Randy Date: 09/11/2011
    Comment:
    Behavioral therapy is very effective for obesity. I had implemented it into my practice of pharmacy in a retail setting and have had many patients with great results. I think having weekly visits for the first 3 months would work better to help the patient establish new healthy habits. A pharmacist is trained in consulting and traing patients in a number of disease states that are secondary to obesity. It was a natural fit to have behavioral thearpy for obesity in my paractice. Pharmacist can

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    Witte-Bakken, Jan Title: Clinical Director
    Organization: SOLUTIONS Behavioral Healthcare Professionals
    Date: 09/11/2011
    Comment:
    I would suggest that Licensed Psychologists be approved providers. For example, my master's degree is in Behavior Therapy. I believe psychologists in general, and particularly individuals with specific training such as mine would be considered highly trained for the provision of this type of therapeutic service. Thank you for your consideration
    Miller, Katie Date: 09/11/2011
    Comment:
    This proposal is a good idea, but it should also cover psychologists. They are highly qualified to deliver this type of treatment.
    Bradley, April Title: Associate Professor
    Organization: University of North Dakota
    Date: 09/11/2011
    Comment:
    PCPs are not trained to provide behavioral treatments for obesity, psychologists are. For a PCP to learn to provide behavior therapy they would need to be trained by a Psychologist. Seems a HUGE oversight that psychologists are not included as providers for this service.
    Kolstoe, Paul Date: 09/10/2011
    Comment:

    Behavior therapy has been created by, researched by, improved by, and best delivered by Clinical Psychologists as the research literature shows. Failure to include clinical psychologists - in fact, perhaps noting they are generally MORE QUALIFIED IN SPECIFIC TRAINING than most physicians - is notable as a systematic methodology to prevent patients from receiving actually QUALIFIED services in favor of wasting taxpayer/patients' money for more billable services from under-qualified

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    Adams Larsen, Margo Date: 09/10/2011
    Comment:
    I am very excited at the proposal, as individuals with obesity have significant needs and limited resources available to meet those needs. I find it interesting, however, that that proposal is suggesting that primary care physicians and primary care providers have the expertise to provide BEHAVIOR THERAPY as it is defined within the proposal AND in the frequency/manner in which it is defined in the proposal. In many states, these individuals would find themselves violating practice laws that

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    Dill, Carla Title: WellPlan Director
    Organization: Comcare
    Date: 09/09/2011
    Comment:
    My interpretation of this proposed CMS coverage makes it clear that only primary care physicians and primary care practitioners (NP’s, PA’s, or nurse specialists) will be authorized to provide obesity counseling to receive reimbursement under this proposal. RD’s should be the professional to provide this service. RD's have studied the science of nutrition and of behavior change for at least 5 or more years. They truly are the nutrition professionals and should be eligible for reimbursment

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    Waite, Mary Date: 09/09/2011
    Comment:
    The Intensive Behavioral Therapy (IBT) program targeting obesity would benefit greatly from the skills that Registered Dietitians possess. Registered Dietitians are trained to translate diet recommendations into actual foods, and help clients prepare those foods so that they will be tasty and nourishing, resulting in permanent change of eating habits. I respectfully ask that Registered Dietitians be included in the list of qualified healthcare providers of IBT for Obesity.
    Butz, Renee Title: Owner
    Organization: Anytime Fitness
    Date: 09/09/2011
    Comment:
    I am sorry to remind everyone of this but these people choose NOT to exercise and no matter what free programs you continue to propose, including counseling, BMI measurements, etc, they will choose to eat more and move less, and let YOU take care of their medical problems (and have ME pay for it all)
    Shay, Kathleen Title: Clinical Psychologist
    Organization: Chelsea Community Hospital
    Date: 09/09/2011
    Comment:
    Behavioral treatments for obesity should be delivered by psychologists rather than physicians or nurses. The medical professions are not sufficiently prepared in behavioral techniques to effectively implement them. Since psychologists are not currently covered by Medicaid, that needs to be addressed if these treatments are to be implemented.
    Forman, Evan Title: Associate Professor
    Organization: Drexel University
    Date: 09/09/2011
    Comment:
    The proposal reads "counseling is furnished by a qualified primary care physician or other primary care practitioner and in a primary care setting." As such, it would leave psychologists uncovered despite the fact that gold standard behavioral counseling for obesity was developed by psychologists, the efficacy of behavioral counseling is best demonstrated in cases in which psychologists are the interventionists, and behavioral counseling for obesity is most frequently provided by

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    surwit, Richard Title: Professor and Vice Chairman, Chief, Med Psych
    Organization: Dept of Psychiatry, Duke Univ. Medical Ctr
    Date: 09/08/2011
    Comment:

    Thank you for the opportunity to make a comment on the proposed coverage of behavioral therapy for obesity. Specifically, this comment is in reference to the “Proposed Decision Memo for Intensive Behavioral Therapy for Obesity” (CAG-00423N). A key part of this decision proposes that only certain health care providers would be eligible to provide this important service with reimbursement. The relevant section defining eligible staff (i.e. the primary care practitioner) reads as

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    Verbrugge, Dot Title: Medical Director
    Organization: Altius Health Plans
    Date: 09/08/2011
    Comment:
    As a Physician and Medical Director of a Health Insurance Company for Commercial and Advantra members, I support this additional coverage, particularly since similar coverage is mandated for commercial insurance without cost sharing. However, rather than creating a whole new definition of what should be covered, it would be very helpful if the coverage guidelines more closely mirrored the USPSTF guidelines for the treatment of obesity in adults, which is "A formal multi-component intensive

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    Page, Anna Date: 09/08/2011
    Comment:
    I strongly encourage the use of registered dietitians in obesity treatment. Dietitans were in the fore-front of behavioral therapy in the 1980's and are unique in having educational background not only in nutrition, but also in behavioral therapy and a strong science background. I have been a registered dietitian for 28 years. I'm currently an instructor for nutrition for primarily nursing students. Note that this is for nurses becoming BSNs and for most of them will be their only nutrition

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    Wetzler, PsyD, C.BSM, ABPP, Ryan Date: 09/08/2011
    Comment:
    I am pleased to see that treatment of overweight and obesity is being taken more seriously. I am also pleased to see the recommended intervention strategy is intensive behavior therapy. What is missing is a representation of the role of psychologists in providing this service. Psychologists developed many of the existing behavior therapy based weight loss programs. Psychologists are also experts in behavior change with the most training and experience in the delivery of behavior therapy.

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    Smith, RPh, CGP, Linda M Title: Independent Pharmacy Consultant
    Date: 09/08/2011
    Comment:
    I do not understand why pharmacists are not included as providers. All you have to do is review the published data from the American Pharmacists Association (APhA) Ten City Challenge or the Maryland P3 program through the University of Maryland to see the value of pharmcist consultative services working as coaches with patients and can also help with the medication aspect.
    Leisring, Penny Title: Professor of Psychology/Licensed Psychologist
    Organization: Quinnipiac University
    Date: 09/08/2011
    Comment:
    Covering Behavioral therapy for obesity is a huge step in the right direction. However, psychologists should be able to administer the behavioral therapy as well as PCP's.
    Price, Karin Date: 09/08/2011
    Comment:
    I applaud CMS for the proposal to cover behavior therapy for obesity. However, I STORNGLY encourage the inclusion of licensed psychologists as eligibile providers of these services.
    Psychologists have expertise in behavior modification that many primary care physicians do not.
    Thank you.
    Bensadon, Benjamin Organization: Oklahoma University College of Medicine, Dept. of Geriatrics
    Date: 09/08/2011
    Comment:
    Hi, this is a wonderful development and I appreciate the opportunity to post a comment here. I'm just curious, I didn't notice that psychologists were included in the proposed memo. Given that behavioral therapy, and change more broadly, fit well within the purview of their scope of practice & expertise, I'm a bit puzzled as to how/why they could be omitted. Thanks.
    Gordon, Tamar Title: Clinical Psychologist
    Organization: NYU School of Medicine
    Date: 09/08/2011
    Comment:
    I am deeply concerned by the omission of psychologists from the covered professionals who can provide obesity treatment. Psychologists invented, researched, and validated behavior therapy; they are among the only truly qualified people to administer appropriate behavioral treatment. In contrast, medical physicians (MDs, not Phds), have little behavioral training, and are only occasionally trained in the necessary communication and motivational skills needed to effectively interact with this

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    Pells, Jennifer Title: Licensed Clinical Psychologist
    Organization: Structure House LLC / Member of CRC Health Group
    Date: 09/08/2011
    Comment:

    I cannot urge you enough to include psychologists in this proposal as covered providers of behavior therapy for obesity. Behavior therapy for obesity was developed by psychologists, they receive the most rigorous training in delivering this treatment to obese individuals, and they comprise the largest group of professionals implementing this empirically-based treatment for obesity.

    The proposal is for coverage of "intensive behavioral therapy"—this is what psychologists w/

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    Babb, Marvin Title: Marketing Director
    Organization: Take Charge Nutrition/Cherokee Pharmacy & Medical Supply, Inc.
    Date: 09/08/2011
    Comment:
    Why are pharmacists not being considered in the fight against obesity and the co-morbid conditions associated with this condition. Go to www.takechargerx.com and you will find that we are positioning and empowering Community Pharmacists to be a hands on Lifestyle Modification Coach to their patients. Go to our pharmacy website http://cherokeepharmacy.com, and you will see that we have had a Take Charge Clinic in our store for over 12 years now. With your help and consideration we can make

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    Havran, Maribeth Date: 09/07/2011
    Comment:
    Comment: Please include registered dietitians/licensed dietitians as a qualified practitioner. We have more expertise and education in the nutrition field than nurses, doctors, nurse practitioners, physician or assistants. We have been providing medical nutrition therapy for diabetes and chronic renal disease since 2001 and prior to that. Eighty to ninety percent of all Type 2 diabetics are overweight and a large percentage of chronic renal disease is due to diabetes, therefore dietitians are

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    Coleman, Mary Title: Director Community Health
    Organization: Louisiana State University
    Date: 09/07/2011
    Comment:
    According to proposed CMS guidelines, reimbursement will not be allowed for hospital outpatient settings. This should be modified so that hospital based primary care clinics are not excluded and can be reimbursed.
    Martin, Susan Date: 09/07/2011
    Comment:
    The Intensive Behavioral Therapy (IBT) that is proposed for Obesity is part of what Registered Dietitians (RDs) are trained for and are already providing. I respectfully ask that you include RDs in the list of qualified healthcare providers to implement the IBT for Obesity. RDs screen for obesity in adults using measurement of BMI; we conduct nutrition assessments and we are trained to provide intensive behavioral counseling and behavioral therapy to promote sustained weith loss through high

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    Randle, Tara Date: 09/07/2011
    Comment:
    The Intensive Behavioral Therapy (IBT) that is proposed for Obesity is part of what Registered Dietitians (RDs) are trained for and are already providing. I respectfully ask that you include RDs in the list of qualified healthcare providers to implement the IBT for Obesity. RD's screen for obesity in adults using measurement of BMI; we conduct nutrition assessments; and we are trained to provide intensive behavioral counseling and behavioral therapy to promote sustained weight loss through

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    Sacchetti, Peter Organization: ALCOR Scientific Inc
    Date: 09/07/2011
    Comment:
    Total population weight in SNF's needs to be considered when assessing required caregiver headcount. We cannot ignore the fact that mounting wave of obese residents will require more labor.
    McQuire, H Date: 09/06/2011
    Comment:

    The Intensive Behavioral Therapy (IBT) that is proposed for Obesity (CAG-00423N) is part of what Registered Dietitians (RDs) are trained for, capable of and are already providing. RDs have more expertise and education in the nutrition field than nurses, doctors, nurse practitioners, physician or assistants. RDs are required to have 15 hours of continuing education yearly all of which could be focused on weight control/obesity if that was the RDs area of interest. I respectfully ask that you

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    Lukwago, Susan Date: 09/06/2011
    Comment:
    The Intensive Behavioral Therapy (IBT) that is proposed for Obesity is part of what Registered Dietitians (RDs) trained for and are already providing. I respectfully ask that you include RDs in the list of qualified healthcare providers to implement the IBT for Obesity. RDS screen for obesity in adults using measurement of BMI; we conduct nutrition assessments; and we are trained to provide intensive behavioral counseling and behavioral therapy to promote sustained weight loss through high

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    Greenleaf, Diane Title: Nutrition and Wellness Consultant
    Date: 09/06/2011
    Comment:
    Please include registered dietitians/licensed dietitians as a qualified practioner. We have more expertise and education in the nutrition field than nurses, doctors, nurse practioners, physician or assistants. We have been providing medical nutrition therapy for diabetes and chronic renal disease since 2001. Eighty to ninety percent of all Type 2 diabetics are overweight and a large percentage of chronic renal disease is due to diabetes, therefore dietitians are already counseling

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    Ikeda, Joanne Title: Nutritionist Emeritus
    Organization: University of California, Berkeley
    Date: 09/06/2011
    Comment:
    I was on the faculty of the Nutritional Sciences Department at the University of California for over 32 years. Much of my work was in the area of obesity.
    In light of the Wildman NHANES study (2008, ArchIntMed) showing that almost half of overweight people and a third of people are metabolically healthy, it appears that many people do not need intensive, costly treatment. Mann's article published in (April 2007 American Psychologist) showed that calorie restricted dieting is not a cure

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    Lyons. RN MA, Pat Date: 09/06/2011
    Comment:
    As a public health nurse for over 40 years in Afican American and American Indian communities where obesity prevalence is greatest I STONGLY OBJECT to wasting scarce Medicare dollars on useless weight loss counseling. This is exactly the kind of wasteful policies that should be corrected, not instituted! No methods of weight loss last long term and do damage to health. STOP THIS INSANITY! Please: DO NO HARM
    Logue, Everett Date: 09/06/2011
    Comment:
    You should consider expanding reimbursement for dietitians working with primary care physicians and nurse practitioners. Dietitians can work with patients in a more focused manner without being distracted by the many health issues that must be addressed by primary care physicians and nurse practitioners.
    Burgard, PhD, Deb Title: Psychologist
    Date: 09/03/2011
    Comment:

    Why is CMS reversing its own policy and saying it always was in favor of this?

    You say, "since 2003, the USPSTF has recommended screening for obesity in all adults and then offering intensive counseling and behavioral interventions to promote sustained weight loss.” Go to the USPSTF website (http://www.uspreventiveservicestaskforce.org/uspstf/uspsobes.htm) and read the summary of statements. This is your 2003 statement (which appears to be the most current statement): “The

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    Bliss, Kelly Title: Director
    Organization: Lifestyle Watchers, Inc.
    Date: 09/03/2011
    Comment:

    Medicare coverage for obesity counseling for seniors is NOT good for the health of seniors and not good for the taxpayer.

    With the proposed minimum 17 doctor visits at $100 per visit, it would cost $257.57 to $154 per pound for temporary weight loss.

    Statistically, seniors who lose weight have WORSE morbidity and mortality. So taxpayers would be paying for worsening the health of seniors.

    There is NO currently known method of weight loss that is long term.

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    Goodrick, Ken Title: Adj Assoc Professor, Fellow of The Obesity Society
    Organization: Baylor College of Medicine
    Date: 09/02/2011
    Comment:
    "Physician" definition should include "licensed psychologist with training in behavioral treatment of obesity." Most of the work and advances in such treatment has been done by psychologists.
    Jones, PhD, Kenneth R. Date: 08/31/2011
    Comment:

    Re: Proposed Decision Memo for Intensive Behavioral Therapy for Obesity (CAG-00423N)

    Two of the references cited in this decision reference the program which I direct, the MOVE! Weight Management Program for Veterans.

    In VA, we have not found that physicians can and do carry out behavioral interventions for weight management. In fact, I would estimate that less than 1% of MOVE! patients have had care primarily provided by the primary care physician.

    Rather, we

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