Comment on FR Doc # E9-09629

Pursuant to 45 CFR Parts 144 and 146, I'm submitting the following information regarding MHPAEA, Mental Health Parity and Addiction Equity Act of 2008. From twenty-five years of professional experience as an administrator and executive for a variety of private behavioral health service provider organizations, I also speak as a consumer with over thirteen years of continuous sobriety and recovery from addiction and major depressive disorder. It is vital that "best practices" are sought from current, successful business and clinical model. Immediate access, cost-effectiveness and successful clinical outcomes should be the primary indicators when assessing best practices. Third party payors (including HMO's), behavioral health organizations (MCO's), utilization review and administrative service organizations, and treatment provider organizations should be surveyed to determine what business and clinical models render the best results. Medicare, TriCare and Medicaid should be allowed to purchase behavioral health facility-based services from the private sector without the "hospital model" which severely escalates cost. Hospital based addiction treatment is disproportinately more expensive than treatment rendered in non-hospital but State-certified/ licensed settings. I would greatly appreciate an opportunity to assist or testify in this effort.