Docket: IRS-2009-0008 

Request for Information for Paul Wellstone and Pete Domenici Mental Health Parity and 

Addiction Equity Act of 2008 

Comment On: IRS-2009-0008-0001 

Request for Information Regarding the Paul Wellstone and Pete Domenici Mental Health Parity 

and Addiction Equity Act of 2008 

Document: IRS-2009-0008-0068 

Comment on FR Doc # E9-09629 

Submitter Information 

Name: GARY JOSEPH SCHUMMER 

Address: 

TORRANCE, CA, 

Submitter's Representative: Jane Harmon 

Organization: ADD TREATMENT CENTER 

General Comment 

Comments regarding Regulatory Guidance USCG-2007-27022, page 19157, II B 

specific areas 1 and 4 

It is clear that, with governmental support, the insurance industry picks and 

chooses what it will or will not pay for without any attempt to treat disease fairly. 

They do it in a way that maximizes profit to the detriment of the American 

populace. An excellent example can be illustrated in EEG Biofeedback, which is 

what I do as a career. I’m a licensed psychologist in California who has chosen to 

provide this type of therapy because it is effective in the treatment of ADD/ADHD 

and totally not harmful (unlike drug therapy). In an $11M NIH study called the 

MTA Study completed at the University of Buffalo, drug therapy was shown to be 

ineffective after two years. Yet the insurance industry will pay for children and 

adults to be on drug therapy for as long as the patients wants. EEG Biofeedback, 

on the other hand, has lasting improvement in brain activity, essentially 

remediating the disorder. In spite of over 40 years of research studies proving the 

efficacy of EEG Biofeedback, the insurance industry continues to assert that it 

is “experimental”. 

The subjective evaluation of insurance company executives in order to maximize 

profit should not replace this issue of parity. Mental health issues take a huge toll 

on our economy and many studies have proven that when mental health issues 

PUBLIC SUBMISSION 

As of: May 28, 2009 

Tracking No. 809b74c8 

Comments Due: May 28, 2009

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are not remediated properly, patients turn to the medical establishment to help 

them. This increases medical costs and you have untrained medical professionals 

attempting to treat mental disorders. Any physician will tell you that they lack the 

tools to treat mental illness. 

I believe that the parity regulations, based on legal reviews of the parity statue 

should require that employers and plans pay for the same range and scope of 

services for Behavioral Treatments as they do for Medical and Surgical benefits 

and that a plan cannot be more restrictive in their managed care criteria and 

reviews for MH and SA disorders when compared to Med Surg. Today plans are 

being MORE restrictive in how they review evidenced based Mental Health and 

Substance Abuse Treatments when compared to Med Surg treatments. This 

violates both the intent and letter of the parity statute and I hope that the 

regulations being considered will mandate that this disparity can not continue. 

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