From: ehjpsych@aol.com [mailto:ehjpsych@aol.com] 

Sent: Wednesday, May 27, 2009 9:50 PM 

To: undisclosed-recipients 

Subject: Comments regarding Regulatory Guidance USCG-2007-27022 

Comments regarding Regulatory Guidance USCG-2007-27022 

page 19157, II B specific areas 1 and 4 

From: Edward Jacobs, Ph.D., BCIAC 

RE: Request to require reimbursement for Neurofeedback, an 

innovation in mental health treatment 

EEG biofeedback or Neurofeedback implements special technology as an 

effective non-medication treatment for ADHD, Autism, and chronic 

depression, anxiety and other mental health disorders. It also speeds 

up treatment for trauma, such as many returning Iraqi vets have 

suffered. No other treatment is as broadly effective. Yet it’s 

unavailable to most people who need it. 

 REIMBURSEMENT REFUSED 

As one of the few effective treatment options to medications- one few 

reported side effects, it should be reimbursed by insurance plans and 

Medicare. Reimbursement is usually refused. As a result, only clients 

who can afford to pay cash usually have access to this treatment. 

 Neurofeedback is increasingly prescribed by doctors, psychologists and 

mental health therapists who deal with these problems. That’s because: 

1) Medications often are incomplete treatment, leaving symptoms 

that reduce performance in school or work – with huge unseen 

productivity losses. 

2) Medications can create increasing side effects over time. 

 These two issues INCREASE MENTAL HEALTH CARE COSTS over time. In 

addition, it contributes to huge 

hidden costs related to millions of 

people struggling to perform in school, in work, or in managing their 

lives. 

 REDUCED MENTAL HEALTH COST 

Neurofeedback is an innovation that uses technology to REDUCE mental 

health treatment over time. 

 AMERICAN PSYCHIATRIC ASSOCIATION 

For the last 6 years, the American Psychiatrist Association has 

sponsored a course on neurofeedback at their annual conference to help 

educate more psychiatrists about its implications in treatment. 

There’s still very little funding of this modality as well as 
reimbursement, which tremendously inhibits exposure to the broader 

psychiatric community. 

 RESEARCH BASED 

There are over 50 studies evaluating the effectiveness of EEG 

biofeedback in the treatment of ADHD, Substance use disorders and 

Autism. A recent review of this literature concluded “EEG biofeedback 

meets the American Academy of Child and Adolescent Psychiatry criteria 

for” Clinical Guidelines “for treatment of ADHD.” This means that EEG 

biofeedback meets the same criteria as to medication for treating ADHD, 

and that EEG biofeedback “should always be considered as an 

intervention for this disorder by the clinician”. 

 REIMBUSMENT DENIED. 

This service has been denied by Medicaid, Medicare, Aetna, United 

Behavioral Health, Blue Cross, Cigna, Harvard Pilgrim Medical 

Associates, Tufts Health Plans, and Amerigroup. 

 This is limitation of a 

n effective and validated treatment for a 

mental health problem. The reasons given by the insurance companies 

for this denial fell into two categories: 

1) our insurance company does not cover biofeedback for Mental Health 

problems or 

2) there is not yet sufficient evidence for the efficacy of EEG 

biofeedback. 

 As such, they are using evidence-based criteria that are far more 

restrictive for mental health services than the criteria which are used 

for medical/surgical services. There are many routine medical and 

surgical procedures which have far fewer controlled studies about their 

efficacy than does EEG biofeedback. These medical and surgical 

procedures are generally not limited because of concerns about how many 

controlled studies have been performed about them. 

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 Med Surg 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 statue and we hope that the 

regulations will clarify that this can't=2 

0continue. 

Sincerely yours, 

Edward Jacobs, Ph.D., BCIAC 

Edward Jacobs, Ph.D. & Associates 

Psychological Services -- Neurofeedback 

Testing -- Learning Disabilities Services -- Tutoring 
12 Parmenter Road 

Londonderry, NH 03053 

Phone: (603) 437-2069 ext. 10 

Fax: (603) 437-5588 

www.JacobsAssociates.org