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PUBLIC SUBMISSION Tracking No. 809ad6Ya 

Docket: IRS-?..09-0008 

Request for lnformatjon for Paul Wellsronc and Pete Domenjci Mental Health Parity and 

Addictinn Equity Ad of 2008 

Comment On: I_R_S-?~~~-~-DOOX-O0_9.~ 

Rquest for Information Regarding the Paul Wellstune ar~d Pete Domenici Mental Health Parity 

and Addiction Equity Act uf 2008 

Document : 1K S-2W~9.~.WOS(j024 

Comment on FK Doc # E9-09629 

Submitter Information 

Name: Jnhn B. McGarey MA, [.PC 

Address: 

Phoenix, AZ, 

Organization: Life C'oping Consults 

General Comment 

Cummcnts regarding Regulatory Guidarlce IJSCG-2007-27022 

page I91 57,11 R specific areas 1 and 4 

1 am a licensed profcssionol counselor, in practice with a licensed clinical socnl 

worker. We provide EMG, GSR and temperature training to individuals with PTSU, 

Anxiety (Generalized Anxicty Disorder)and Panic Disorders.These foms of 

biofeedback, along with EEG biofeedback, have extensive empirical validation and 

are widely recognized clinically as ell'ective non-ii~edication treatrntmt for these 

disorders, as well as: ~(hcr condi tinns. There are numcrous studies evaluating thc 

cffcct iveness nf biofeedback in the treatment of Gereral Anxiety Disorder, and 

Post Traumatic Stress Disordt~. 

If the extm~sivc literature regarding biofeedback indicates that it it's: cffcctivzl~ess 

meets the same criteria as medication for treating thcsc disorders, then it should 

always be considerd as an intervention for this disurdcr by the clinician. 

This senice has beun denied by Georgia Medicaid, Aetna, United Dehaviuml 

Health, Blue Cross, Cligna, and Amerigruup. 

This is limitation of slri effective and validalcd trcatment for a mental hcal th 

problem. The rcasons given by the insurance companies for this denial fell into 

two categories: 1) our company does nut covcr biofeedback for Mental Hcalth 
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problems or 2) thcrc is not yet sufficient evidence for the efficacy of biofeedback. 

Using such a statement would indicate: I. they arc using evidence-based criteria 

that are far mort; restrictive for r~lental health services than thc critcria which are 

used for medicallsurgical services. 2. 'Cheir information is autdatd bad on the 

wcalth of literature that is available that speaks to the contrary. 

There are many routine medical and surgical procedures which have far fewer 

controlled studies about thcir efficacy than does biofeedback. Thcsc medical and 

surgical procedures are generally r~ot limited because of concerns about how 

many controlled studies have been performod about them, nor by evidence which 

might lcad to a different conclusion about their effectiveness. 

We believe that the parity regulations, based on legal reviews of thc parity statute 

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

saviccs for Behavioral Treatments as they do for Med Surg benefits and that a 

plan cannot bc more restrictive in their mmagcd care criteria and reviews for MH 

and SA disorders when compared to Med Surg. Today plans arc being tmre 

restrictive in how they review cvidcncecl-baed Mental Ilealth and Substance 

Abuse <Treatinents when cornpard to Mod Surg treatments. This violates both the 

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

that this cim't continue. 

It also seems unjust that many patients seeking services for these, and sevwal 

other dcbiljtmting problems are dmid an cffcctive nnd comparatively benign 

treatment Su'os their problem only to receive a treatment IIO more objectively 

evaluatd than Bioi'tedback, but often fiaught with extensive sidc cffects, 

sometimes inore debilitating than the origional problem. I would appreciate your 

wnsidcratjon of "First, do no harm." 

Sincerely, 

John B. McGarey MA, LPC, BCIAC,