Cerebral CMO defends company’s prescribing practices


BOSTON – Cerebral Chief Medical Officer Dr. David Mou on Sunday defended the digital mental health company’s prescribing practices, but mistakes have been made, especially in the area of marketing, he admitted during the American Telemedicine Association Association’s Annual Conference & Expo in Boston.

Cerebral has gained press coverage over allegations it over-prescribes drugs for mental health and that its marketing targets teenagers and young adults.

Last week, a former vice president of the company filed a lawsuit against Cerebral claiming he was fired after voicing concerns about unethical prescribing practices and patient safety issues. Moderator Joe Kvedar, professor at the Harvard Medical School and board chair of the ATA, said the matter could not be addressed because it was an ongoing legal issue.

However, as the Q&A was billed as a “transparent conversation about the controversial press coverage swirling around the company and its potential implications for the industry,” Kvedar pressed Mou on allegations well aired in the press that Cerebral has over-prescribed drugs to treat attention-deficit/hyperactivity disorder (ADHD).

The idea is coming out that people are being pressured to prescribe, Kvedar said.

“At no point do we pressure clinicians to prescribe anything,” Mou said.

Mou walked Kvedar and the audience through Cerebral’s intake process. Patients fill out a screening form and have a 30-minute assessment, or a 60-minute assessment for an opioid intake. The north star for prescribing is a prescribing algorithm, Mou said. 

“We tell them, don’t rush that diagnosis,” Mou said. “That’s how careful we are.”

Clinical protocols are in place, he said. Every month, every clinician gets a monthly report on how their patients are doing. If patients that came in depressed remain depressed, the clinician is given actionable data and payment for education.

But the standard guideline, for instance, for bipolar disorders, is to treat with a mood stabilizer, Mou said. There are currently no objective measures for clinical quality for behavioral health, he said. 

“The first thing I’ll say, we do stand by our quality,” Mou said.

Before the news articles came out, Cerebral already had safety protocols in place, he said, and a dedicated clinical quality department and clinical safety department. 

“To your point, we’re not perfect,” Mou said to Kvedar.

Kvedar said several articles have addressed the company’s marketing practices and social media campaigns that target individuals 16 to 24 years old.

“This is your chance to respond to all that,” Kvedar said.

The 2-year-old company grew so quickly that some marketing was outsourced, and the material was no longer being reviewed by clinicians, Mou said. Now, the director of clinical quality is reviewing the marketing, he said.

In terms of the prescription monitoring program, Cerebral is thinking about having better detection for patients who may be substance seeking. 

“We have made mistakes, and I’ll admit we’ll continue to make mistakes and to learn,” he said.

Another part of the learning process is doing a better job of making accessible Cerebral’s published white paper on outcomes data, according to Mou.

When an audience member asked how he could see the white paper, Mou said it was hard to find and that the company was working to make it easier to locate on its website.

The long-term strategy is to move from fee-for-service to value, Mou said. For instance, to help prevent suicides, Cerebral pays clinicians to make a phone call to those at risk, as that touchpoint has been shown to make a difference.

“The eventual business model is to get paid for value, rather than being paid a fee-per-appointment,” Mou said. “We want to tailor time for clinical need.”

A law that could affect the business model is the current suspension of the Ryan Haight Act, which requires practitioners issuing a prescription for a controlled substance to conduct an in-person medical evaluation or conduct a video/audio communication in a Drug Enforcement Administration-registered facility at a minimum of once every 24 months, according to the National Association of the Boards of Pharmacy.

An audience member asked what would happen when the public health emergency (PHE) ends and the Ryan Haight Act is reinstated. The PHE is currently scheduled to end in mid-July. She’s in private practice, and many colleagues are concerned that there will be a flood of patients coming in asking about drugs they can no longer obtain through Cerebral.

Mou indicated that there is an effort to keep the Ryan Haight Act from being reinstated.

Cerebral gets more attention because it has to do with controlled substances, Mou said.

“There’s also a stigma against mental health and against telehealth,” Mou said. “We are doing things above the standard of care that brick and mortars don’t do; we’re getting the scrutiny.”


Matthew Truebe, Cerebral’s former vice president for product and engineering, is suing the digital mental health company, alleging he was fired after voicing concerns about unethical prescribing practices and patient safety issues.

In the suit, filed earlier last week in a California state court, Truebe alleged the virtual mental health startup began tracking the retention rate of ADHD patients who were being prescribed stimulants against those who weren’t. When it was determined those who were prescribed the drugs were more likely to remain users, Truebe said the company’s chief medical officer had told employees at a meeting “the CMO’s goal was to prescribe stimulants to 100% of Cerebral’s ADHD patients.”


Cerebral, a digital mental health and medication management company, advertises as being able to visit with an online therapist or prescribing provider fast, with online ADHD diagnosis and treatment available from the phone.

World-champion gymnast Simone Biles partnered with Cerebral as chief impact officer.



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