Urgent Letter of Protest to
Federal Mental Health Agency from EdWatch
and a Coalition of Groups
December 12, 2005
Mr. Charles Curie
Office of the Administrator
Substance Abuse and Mental Health Services Administration
1 Choke Cherry Road
Room 8-1036
Rockville, MD 20857
Dear Mr. Curie,
This letter is a follow-up to the October 17th, 2005 meeting organized by
Michael Ostrolenk between you, members of your staff, and representatives
of the Alliance for Human Research Protection, EdWatch, Eagle Forum, The
International Center for the Study of Psychiatry and Psychology,
MindFreedom International, The Association of American Physicians and
Surgeons, and the American Psychoanalytic Association.
We appreciate the opportunity to share our concerns about the New Freedom
Commission (NFC) report and Federal Mental Health Action Agenda (FMHAA).
It is important that you hear from groups and individuals that have been
critical of these documents and the programs that they represent.
We also appreciate the clarification of the role of and the increased
emphasis on parental consent, as well as your willingness to make sure
that consent is truly active and informed, and that the requests for
grant applications emphasize parental consent.
We are, however, very distressed at what appears to us to be a
significant discrepancy between your statements and the reality of
SAMHSAs role in implementing the NFC report recommendations, as well as
other discrepancies between your statements and SAMHSAs actions.
For example, you stated, "The New Freedom Commission report is not
official Bush Administration policy, but rather the unofficial
recommendations of an appointed commission." You also stated that
the state incentive transformation grants are merely for infrastructure
for states to set up their individual transformation plans for a recovery
oriented system and that the Action Agenda is "not really a blueprint or
road map for implementing the NFC report." If all of this is true,
then:
- Why does the "SAMHSA Matrix brochure contain a bullet item that says,
SAMHSA is investing more than $517 million in transformation efforts,
including $47 million to fund the State Incentive Grants for
Transformation program to enable States to begin implementing the
Commissions findings?" [1]
- Why does the Agenda state "CMHS has contracted with a number of
national mental health organizations to provide technical assistance to
States in the development of activities and plans to implement the
New Freedom Commission
recommendations?" [2]
- Why has the Center for Mental Health Services (CMHS) within SAMHSA,
as part of the technical assistance program mentioned in the bullet
above, given taxpayer funds to contract with "the National Association of
State Mental Health Program Directors (NASMHPD) to coordinate this
project and to collaborate with six subcontractors: the Judge David L.
Bazelon Center for Mental Health Law, the Federation of Families for
Childrens Mental Health, the National Alliance for the Mentally Ill
(NAMI), the National Association of Mental Health Planning and Advisory
Councils (NAMHPAC), the National Council for Community Behavioral
Healthcare (NCCBH), and the National Mental Health Association (NMHA) to
deliver written analysis or on-site training and technical assistance on
a range of policy issues related to the implementation of the
recommendations of the Presidents New Freedom Commission on
Mental Health?" [3]
Every one of these organizations has a vested interest in expanding
the mental health system and has been a wholesale, uncritical supporter
of the screening and medication recommendations in the NFC report,
completely ignoring contradictory scientific and medical evidence.
There is also a large conflict between your statements above and the fact
that states have taken the NFC recommendations as official administration
policy that would have had or will have disastrous consequences. Illinois
and Indiana have passed legislation implementing child mental health
screening and other scientifically invalid mental health programs that
clearly reference the NFC report in their legislative language,
supporting documents or implementation plans. Texas and Minnesota
tried to do the same, but were stopped. Nineteen states have
applied for state incentive transformation grants[4] and
45 states received technical assistance from organizations paid by SAMHSA
to implement the NFC recommendations[5]
mental health screening of children, medication algorithms, and even in
the case of Missouri[6] using tax dollars to train
families to lobby for more tax dollars to pay for these scientifically
invalid programs as discussed below.
Medication Algorithms:
Another example of an apparent disconnect between your statements and
reality are your statements that: "The Action Agenda does not support
medication algorithms; Medication toolkits have been removed from
SAMHSA's other public materials;" and "Algorithms needed to be revisited
and revised on the basis of what science has taught us about these
drugs."
While we appreciate these statements, they do not exonerate SAMHSA from
having adopted illegitimate, scientifically invalid, prescription drug
practice guidelines based on fraudulent claims.
The TMAP algorithm guidelines for psychotropic drugs are not backed by
scientific evidence, but rather on self-interested opinion. Indeed the
scientific evidence contradicts all claims made about the superiority of
the drugs recommended by TMAP as first line treatmentthese drugs have
not been shown to be either more effective or safer than non-drug
interventions or existing, cheaper, old drugs. TMAP guidelines were
formulated by a consensus panel whose opinions were solicited by
pharmaceutical companies that sponsored TMAP. The TMAP formularies
recommend the drugs manufactured by those companies that are all on
patent, very expensive, and have no better safety or effectiveness
profiles than older, cheaper drugs that themselves are not very safe or
effective.
In light of the validated scientific evidence, your statements were the
only reasonable ones to make. Here is a small sample of that
scientific evidence demonstrating:
- All drugs on the TMAP formulary are under some sort of black box
warning, the FDAs most serious warning short of a ban, for fatal side
effects[7];
- The CATIE trials by NIMH showed that new expensive antipsychotics
have as many or more side effects than older, inexpensive
ones[8];
- The Oregon Drug Effectiveness analysis of 2,287 studies showed no
long-term effectiveness or safety of ADHD
drugs[9];
- The JAMA study on suicide rates remained unchanged despite a huge
increase in treatment with those drugs under black box warnings for
causing suicidal thoughts and behavior in
children [10];
- And the WHO studies found that schizophrenics in developing countries
without drugs do much better than those in countries with those drugs
that cause debilitating, sometimes fatal, neurological and metabolic side
effects [11].
We are truly appalled and alarmed that the New Freedom Commission
recommended TMAP and that SAMHSA was directly funding it until recently
without ever examining the scientific validity of the recommendationsor
the underlying conflicts of interest behind the recommendations. NFC
recommendation and funding by SAMHSA helped TMAP spread from Texas to
about a dozen other states where thousands of mental patients and
children trapped in government programs such as juvenile justice,
welfare, and foster care[12] are forced to take these
drugs, when most are not approved for use in children. They are given in
unstudied cocktails of up to sixteen drugs, starting as young as age
three. The State Incentive Grants for Transformation and the
Garrett Lee Smith Suicide Prevention law are both funding TMAP-style
"integrated treatment" administered by SAMSHA.
We also remain deeply concerned about items in the Action Agenda that are
not backed by scientific evidence. For example, the fact that
psychotropic medications are at the top of the list of so-called
evidence-based treatments, and the plan to: "Synthesize available
knowledge about clinical and rehabilitation practice in each of four
understudied areas, including information on ... The long-term positive and
negative effects of psychotropic medications for maintenance treatment of
mental disorders, particularly for children with serious emotional
disturbances." The evidence is in. The studies have been done.
Psychotropic drugs are not safe or effective for children.
There should be no recommendation by, funding from, or administration
of ANY mental health program by SAMSHA, whether in the Agenda or not,
that is not backed up by solid, independent, peer reviewed scientific
research clearly demonstrating safety and efficacy of any screening or
treatment modality.
Screening for Mental Illness:
Screening for suicide has no scientific validity. Indeed, the US
Preventative Services Task Force found that suicide screening in general
is not effective in preventing suicide or lowering suicide
rates[13]. At our meeting you indicated that
TeenScreen is not a model program in the Action Agenda; that parental
consent for screening must be truly informed and active; and that you
will take back information to improve parental consent in the requests
for grant applications.
Again, while we appreciate these statements, we are deeply disappointed
and concerned about the announcement, just days after our meeting, that
SAMHSA gave $9.7 million dollars in grants to Arizona, Nevada, New Mexico
and New York to implement TeenScreen[14]. TeenScreen
purports to be a suicide prevention initiative without evidence to back
it up.
- Is SAMSHA informed about the predictive unreliability of TeenScreen?
According to the published findings of Dr. David Shaffer, TeenScreens
chief developer, TeenScreen has a predictability rate of only 16%:
TeenScreen would result in 84 non-suicidal teens being referred for
evaluation for every 16 suicidal youths correctly
identified.[15]
Thus, it is inconceivable that SAMHSA would even consider continuing
to promote this ineffective and dangerous program.
Infant and Preschool Mental Health Programs:
One example of a non-pharmacological mental health program discussed in
the Action Agenda that has no scientific evidence of safety and efficacy
is the "5-year research effort [launched by HHS and ED] to find the best
ways to prepare preschool children for later success in school."
This effort is to include preschool curricula, teacher training, and
parental involvement.
The FMHAA also describes HRSA's State Maternal and Child Health Early
Childhood Comprehensive Systems (SECCS) Grants that "will bring in other
Federal partners to plan for and develop statewide systems of care to
support the healthy social and emotional development of children. These
grants enable States to plan, develop, and implement comprehensive,
collaborative systems to improve childhood outcomes," including "mental
health and social-emotional development interventions, early child care
and educational supports, and parent education and family support."
Besides both preschool and government mental health intervention in the
lives of young children violating parental roles evidenced by hundreds of
years of historical and court precedent[16], the
results of a University of California Berkley/Stanford study confirmed
earlier NICHD[17] research showing that increased
preschool attendance has negative effects on childrens social and
emotional development[18]. This is
continued confirmation of research from as far back as the
1960s[19]. Preschool education is harmful
to social and emotional development, the very realms that the FMHAA
agenda is trying to improve. Widespread expansion of these programs
is in large part responsible for the rampant, though unscientific use of
psychotropic drugs in young children[20] and the
high rate of preschool expulsions for behavior
problems[21].
The federal government should not be promoting more wasteful, ineffective
government preschool programs that are paid for by higher taxes that
force more mothers to join the workforce and put their children in the
very programs that are harming them. We would want to see the
language supporting preschool curricula and federal involvement in that
realm taken out of the Action Agenda on paper as well as out of the
grants that SAMHSA, ACF, MCHB, HHS, and the Department of Education, in
implementing the Action Agenda, fund and support.
Even more disturbing than the promotion of harmful and ineffective
preschool education and mental health programs, is the targeting of
infants by programs directly mentioned in the Action Agenda or their
documents. For example:
"SAMHSA's Prevention and Early Intervention Grant Program is a Targeted
Capacity Expansion (TCE) grant designed to develop mental health
promotion and early intervention services targeted to infants, toddlers,
preschool, and school-aged children, and/or to adolescents in mental
health care settings and other programs that serve children and
adolescents."
The SECCS program mentioned in the Action Agenda references a document
that discusses Universal/Preventive Services that are aimed at
improving child development, parenting, knowledge and behavior, and
infant mental health for all families within their service range. The
first service listed under that category is screening.[22]
Given the inaccuracy of psychiatric diagnosis and the lack of proven safe
and effective treatments in preschool aged children, the NFC reports
discussion of mental health in that age group was terrible enough, but
for the FMHAA to involve the infant age group is unconscionable. In 2001,
Dr. Benedetto Vitiello, director of Child and Adolescent Treatment and
Preventive Interventions Research Branch for the National Institutes of
Mental Health, acknowledged the diagnostic uncertainty surrounding most
manifestations of psychopathology in early
childhood [23]. The 1999 Surgeon Generals report
on mental health[24] and the 2001 World Health
Report[25] on mental health contain similar
statements.
Any programs involving infants should be completely dropped.
Since the Agenda reflects plans of dozens of agencies and departments and
is to lead to "wholesale transformation of the mental health service
system," we think that it is essential to have accurate language.
Therefore, we also thank you for being willing to change the language of
the Agenda to reflect concerns raised at the meeting and other concerns.
However, we also believe that unless the actions of SAMHSA and the other
agencies involved in the Agenda agree with your positive statements
during the meeting and the improved language in the FMHAA on parental
consent, that working on the Agenda language will merely be symbolism
over substance.
In summary, the encouraging comments we heard from you at our meeting and
in the Action Agenda have been and continue to be contradicted by the
actions of your agency. Please let us know how we can interpret the
evidence any other way. Those contradictions require us to raise an alarm
to the public, Members of Congress, the media, and all of the
organizations that oppose the NFC recommendations.
We urgently await your response to this letter.
Sincerely,
Association of American Physicians and Surgeons (AAPS)
International Center for the Study of Psychiatry and Psychology
(ICSPP)
Alliance for Human Research Protection (AHRP)
MindFreedom International
Liberty Coalition
EdWatch
Citizens for Health
[1]
http://www.samhsa.gov/Matrix/brochure.aspx , emphasis added
[2]
http://www.samhsa.gov/Federalactionagenda/NFC_FMHAA.aspx, emphasis
added
[3]
http://www.nasmhpd.org/targeted_ta.cfm , emphasis added
[4]
http://www.nasmhpd.org/general_files/publications/tta_pubs/NASMHPD/IDIQ%20II/Mental%20Health%20Transformation%20Survey%20070105.doc
[5]
http://www.nasmhpd.org/general_files/CPT%20Final%20Report%20justin%20revisions.pdf
[6] Ibid, p. 4
[7] Strattera and the antidepressants are under black
box warnings for increased risk of suicide in children and are under
investigation for increased risk of suicide in adults. The old and
new antipsychotics are under black box warnings for increased death rates
in the elderly. See
http://www.fda.gov/cder/drug/DrugSafety/DrugIndex.htm to find the
warnings on individual drugs.
[8]
http://content.nejm.org/cgi/content/abstract/353/12/1209; See also
Carey, B. (9/20/05) New York Times, p. F-1; see also
http://www.ahrp.org/infomail/05/09/20.php
[9]
http://www.ohsu.edu/drugeffectiveness/reports/documents/ADHD%20Final%20Report.pdf
[10]
http://jama.ama-assn.org/cgi/content/abstract/293/20/2487; see also
http://www.ahrp.org/infomail/05/06/09.php
[11] Leff, J (1992). The international pilot study
of schizophrenia: Five-year follow up findings. Psychological Medicine,
22, 131-145 and Jablensky, A. (1992). Schizophrenia: Manifestations,
incidence and course in different cultures, a World Health Organization
ten-country study. Psychological Medicine, supplement 20, 1-95.
[12] Over 60% of foster children in Texas
(
http://www.ahrp.org/infomail/04/11/13.php), nearly two-thirds in
Massachusetts
(
http://www.ahrp.org/infomail/04/08/11.php), and 55% of foster
children in Florida
(
http://www.ahrp.org/infomail/03/09/24.php) are on as many as 16
different psychiatric drugs, starting as young as age 3.
[13] US Preventative Services Task Force (5/18/04)
Screening for Suicide Risk
http://www.ahrq.gov/clinic/3rduspstf/suicide/suiciderr.htm#clinical
[13]
http://www.newsrx.com/article.php?articleID=274144
[15] David Shaffer et al. (2004). The Columbia
SuicideScreen: Validity and Reliability of a Screen for Youth Suicide and
Prevention. Journal of the American Academy of Child and Adolescent
Psychiatry, 43(1), 71-79; p. 77
[16] E.g. Pierce vs. Society of Sisters and
Meyers vs. Nebraska
[17] Children who experience long hours of
child care over the first four years of life are more at risk for showing
behavior problems, particularly aggression. Not only were these
children more likely to engage in assertive, defiant, and even
disobedient activities, but they were also more likely to bully, fight
with, or act mean to other children. - The NICHD Early Child Care
Research Network as quoted on the Society for Research on Child
Development website at
http://www.srcd.org/pp1.html
[18]
http://pace.berkeley.edu/summary_23DA10_new.doc
[19] Moore, R. and Moore, D. (1975) Better Late
Than Early, Readers Digest Press, pp. 88-99
[20] Zito, J., et al. (2/23/00) Trends in the
prescribing of psychotropic medications to preschoolers. Journal of the
American Medical Association, 283:1025-1030
[21]
http://www.fcd-us.org/PDFs/NationalPreKExpulsionPaper03.02_new.pdf
[22]
http://www.healthychild.ucla.edu/Publications/Documents/IMH%20executive%20summary%2012.pdf
, p. 7 Emphasis added.
[23] Vitiello, B. (2001) Psychopharmacology for
young children: clinical needs and research opportunities. Pediatrics.
108: 983-990.
[24] Childhood and adolescence being developmental
phases, it is difficult to draw clear boundaries between phenomena that
are part of normal development and others that are abnormal. - World
Health Organization (2001) World Health Report Mental Health: New
Understanding, New Hope, p.50 of pdf,
http://www.who.int/entity/whr/2001/en/whr01_en.pdf
[25] The science is challenging because of the
ongoing process of development. The normally developing child hardly
stays the same long enough to make stable measurements. Adult
criteria for illness can be difficult to apply to children and
adolescents, when the signs and symptoms of mental disorders are often
also the characteristics of normal development. - (1999) Surgeon
Generals Report on Mental Health, p. 7 of pdf,
http://www.surgeongeneral.gov/library/mentalhealth/pdfs/c3.pdf
For more background, read:
Federal Mental Health Agency Responds to EdWatch and Other
Groups
Sounding the
alarm: Infant mental health
Bias as Mental
Illness