PUBLIC SUBMISSION 

.As of: May 28, 2009 

Tracking No. 809af788 

Comments Due: May 28,3009 

Dockel: 1RS-2009-0008 

Rquest lijr Information for Paul Wellstol~e and Pete Domenjci Mcntal Health Parity and 

Addiction Equity Acl of 2008 

Comment On: I.RS-20()c)-0UOX-O001 

Request for Information Regarding thc Paul W el lstnne and Pete Domenici Mental Health Parity 

oi~cl Addiction Equity Act of 2008 

Document: IRS-200.!1,0008-005.0 

Conlrnent on FR Doc # E9-09629 

Submitter Information 

Namc: Victoria Himison 

Addrcss : 

Houqton, TX, 

Organization: Family Health Services 

~oiernment Agency Type: Federal 

Government Agency: AHKQ 

General Comment 

Commel~ts regarding Regulato~ Guidance USCG-2007-27032. 

page 19157,ll B specific arem 1 and 4 

I am a psychotherapist (licmsed Social Worker & LMFT) & teacher whu uscs 

biofeedback and EEG with symptoms that jmpact health and reproduction 

(migraines, endometriosis, ovulatory dysfunction, PMS, me~~opausal pmblems, 

pelvic pain) as wcll for AIIHD, mood disorders, and anger rnanagcment md 

anxiety. Both biofeedback and EEG biofeedback are empirically validated and 

widely recognized e ffectivc non-medication treatments for many conditions. My 

own articles about this work hake been published iu Sterility & Fertility, Family 

Systems journal, Family Systems Fururn, and thu Annals of the NY Academy of 

the: Scimccs. You can find them on my website at www.~nsf.org. 

Biofcedl~ack and EEG services may be denied covcragi: or subject to restrictions 

that arc not based in outcome data or research. It is ironic sulcc both promote n 

pmonrs nhi l i ty to inanage the impact of anxiety rind improvc medication 

elTectivcncss and reduce medication necessity. Health carc costs decline when a 

symptomatic person and their family members pradicc sclf-regulatioi~. 

This is limitation of effective and validated treatmenis f'ur a mental health and 
health problems. The reasons given by the insurance companies for this denial Tell 

into two categories: 1 ) nur company does not wvcr biofeedback for Mer~tal Health 

problems or 2) there is not yct sufficient evidence for the efficacy of EEG 

biofeedback. As such, they are using evjdm~cc-bmed criteria that are far more 

restrictive for ment nl health services than the crileria which are used for 

meriicallsurgical services. There are many routine medical and surgical 

procedures which havc far fewer controlled studies about their cfficacy than does 

EEG biofeedback. Thest: medical arid surgical procedures are ge~lerally riot 

limited because of concerns about how illany controlled studies have been 

pcrfornled about them. 

The training required for practice and certification in biokedback and EEG is 

extensive. The continuing education and research involved in practice is 

impressive. This is a profession dedicated tu substantiate the scientific basis for 

its cffcctive~~ess and to applications based un outcoi~~e effectiveness. We 

collaborate with physicians and medical treatment on a routinc basis. 

W c bcl ieve that the parity regulations, bascd on legal reviews of the parity stalutl: 

shuuld rcquire that elnployers and plans pay for thc same range and scope of 

services: for Behavioral Treatments as they do for Md Susg benefits and that a 

plan cannot be morc rcstrictive in their managed care crileria and raliews for MH 

and SA disorders when cvrlrpared to Med Surg. Today plans are being Inore 

rcstrictive in how they review evidenccd-based Mental Health and Substance 

Abusc Treatments when compared to Med Surg treatments. This violates both the 

intent and lcttcr of the parity statute and we hope that the regulations will clarify 

that this can't continue. 

Thank you for doing what you can to assurc par~ty for mental health services, i'ur 

behavioral trcatmait, for biofeedback and EEG whm~ provided by licensed 

professionals. 

Victoria Harrison, MA, LMF'I', LCSW 

Director, Family Ilealth Smvlccs 

Houston, Texas