Docket: EBSA-2009-0010 

The Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 

Comment On: EBSA-2009-0010-0409 

Interim Final Rules Under the Paul Wellstone and Pete Domenici Mental Health Parity and 

Addiction Equity Act of 2008 

Document: EBSA-2009-0010-DRAFT-0688 

Comment on FR Doc # 2010-2167 

Submitter Information 

Name: Sharon Krieger 

Address: 

1249 Clays Trail 

Oldsmar, FL, 34677 

Email: sk@buildnewhorizons.com 

Phone: 727-781-1000 

Organization: Building New Horizons, Inc. 

General Comment 

I am very supportive of most of the provisions of the interim final rules under the Paul Wellstone 

and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. These rules address 

many of the inequities in health insurance coverage of mental health care when compared to 

medical/surgical care that I have observed in the course of my mental health practice. 

However, in my opinion, two areas have not been sufficiently clarified. I am quite concerned that 

unless these points are more clearly specified in the final regulations, loopholes will remain that 

will permit widespread violation of the legislative intent of the Paul Wellstone and Pete Domenici 

Mental Health Parity and Addiction Equity Act of 2008: 

1. In my opinion, the interim final rules do not define clearly enough the rules regulating the 

comprehensive scope of services parity between mental health/substance abuse services and 

medical/surgical services. Given the language of the Act and the positions already taken by the 

Departments in the interim final regulations, I request that the Final Rules clarify that benefits for 

MH/SUD must be comparable in scope to the benefits provided in medical/surgical care both 

across and within each classification. Unless parity in scope of services is required in the final 

regulations, the intent of the Act will not be achieved. 

2. I strongly support the application of parity requirements to both QTLs and NQTLs as being 

consistent with the Act and allowing for broad application of the parity requirement with regard to 

treatment limitations. However, in order to implement the intent of the Act, the regulations must 

specify more clearly that any NQTLs that are applied by plans must be comparable for MH/SUD 

PUBLIC SUBMISSION

As of: May 03, 2010 

Received: May 03, 2010 

Status: Pending_Post 

Tracking No. 80ae596a 

Comments Due: May 03, 2010

Submission Type: Web

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and medical surgical benefits, and that any NQTLs for MH/SUD must be no more restrictive than 

NQTLs that are predominant across the broad range of medical/surgical benefits.Thank you, 

Attachments 

EBSA-2009-0010-DRAFT-0688.1: Comment on FR Doc # 2010-2167

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Biofeedback in all Forms as a Treatment Modality

I also want to strongly support the coverage for Biofeedback. Biofeedback, as a treatment modality, has

proven to be extremely effective alone and with other treatment modalities.  There are now very good

studies to support Biofeedback, and it EMPOWERS the patient.  It is non‐invasive, relatively easy to

administer and cost effective.  Often a person will require no medication for their mental condition after

the EEG Biofeedback is completed.

I want to support assessment tools such as Quantitative Electroencephalogram (QEEG).   QEEG is a non‐

invasive measure that is inexpensive and easy to perform.  Through QEEG It is now possible to

determine what medications a person’s brainwaves will respond best to.  Instead of the patient being

tried on several medications with inherent potential for side‐effects.   ‐