Unlike standard documentation required to justify insurance reimbursements, Medicare reimburses ECT “providers who failed to report quality data.”21 In other fields of medicine, if a procedure is not documented with quality data, it is denied. Yet the reimbursement rate for fiscal year 2021 for “providers who fail to report quality data” is more than the reimbursement rate for properly documented ECT in FY 2020.22
Given ECT’s national reimbursement practices, it is unsurprising that the Substance Abuse and Mental Health Services Administration’s National Directory of Mental Health Treatment Facilities ECT provider list jumped from 335 clinics in 2018 to 449 in 2020.23 The 34% increase in US hospitals providing ECT24 since device reclassification may reflect what happens when hospitals identify an unregulated income source.
Regulating ECT is challenging without an accreditation process to monitor providers. No one knows how many Americans receive ECT each year, let alone how many treatments each individual receives or how closely providers space treatments. This is a troubling dilemma considering Thymatron’s regulatory update lists the number of treatments received, and closely spaced treatments as 2 of the 7 independent risks, recognized by the APA, as being related to “permanent memory loss or permanent brain damage.”10
The United Kingdom
The third author of this piece (Cunliffe) has also undergone ECT. She was a doctor until 2005 when she suffered devastating brain damage from ECT. She has improved over the last 15 years, but she reports disabling neuronal fatigue. She can never work again, and she has lost her independence. Nonetheless, Cunliffe feels fortunate, as she is the only ECT patient she knows who received has neurorehabilitation. She has dedicated herself to preventing the distress of others.
After being admitted to the hospital following coercive abuse, Cunliffe was persuaded to undergo 20 sessions of ECT. Her medical notes clearly demonstrate a lack of monitoring. To the contrary, the notes document her complaints about deteriorating memory, speech slowing down, feeling continuously sedated, and having issues with motor and coordination skills. Instead of reviewing the treatment plan, the dose was increased from 90 millicombs (mCs) to 700 mCs.
Cunliffe spent 10 years researching ECT practice and the UK’s ECT Accreditation Service (ECTAS), which is run by the Royal College of Psychiatrists (RCP). She found a 2015 ECTAS patient survey showed that 19% of patients who received ECT treatment were affected by permanent memory loss; however, this figure is never quoted and ECTAS continues to accredit units that are neither offering informed consent nor monitoring for side effects.25 In the UK, units can continue to operate without accreditation and without meeting the minimum ECTAS standards. Cunliffe has spoken publicly about her story, including at one of the famous Maudley debates at the Institute of Psychiatry, proposing the motion “ECT has No Place in Modern Medicine.”26,27
According to Cunliffe, the RCP’s response to her recent letter outlining the serious flaws in the ECTAS accreditation service shows that they have no intention of improving standards of care or consent. She added that RCP President Adrian James, FRCPsych, MSc, refused to meet with her and other victims.
A UK coalition of 40 ECT survivors and family members, mental health professionals (including psychiatrists), and researchers have written the health minister calling for an independent enquiry into the practice of ECT.28 The call has been endorsed by many members of Parliament, the National Counselling Society, the Association of Clinical Psychologists UK, the Council for Evidence-based Psychiatry, and, importantly, Headway, the brain injury association. The UK’s largest mental health charity, Mind, stated29:
At Mind, we back calls for a comprehensive review into the use of ECT, a potentially risky physical treatment that is still used to treat mental health problems in rare cases. We know that some people have found it effective for improving symptoms of mental health problems—particularly depression—when nothing else has worked. However, we still don’t know why it works or how effective it is. Some people who have had ECT may have found they experience adverse side effects that are worse than the symptoms of the problem they’re trying to treat, including short term or longer term memory loss.
Concluding Thoughts
We recognize that ECT advocates have their patients’ best interest at heart. However, an evidence-based approach to psychiatry dictates that this controversial treatment be suspended pending research that meets 21st century standards to determine whether there are any benefits to offset the proven adverse effects in comparison to placebo. At the very least, to comply with the ethical principle of informed consent, the minority of psychiatrists who continue to use ECT must tell potential ECT recipients that: there is no evidence that it is better than placebo beyond the end of the treatment period, there is no evidence that it saves lives, and studies have found that it causes persistent or permanent memory loss in 12% to 55% of patients, with particularly high rates among women and older individuals.
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