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PUBLIC SUBMISSION Tracking No. 809adafl 

Docket: TR S-2009-0008 

Request for lnfonnatiotl for Paul Wellstone and Pete norne~~ici Mental Health Parity and 

Addiction Equity Act of 2008 

Cumment On: IRS-2QU3:00U8-OOOoL 

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

and Addiction Equity Act of 2008 

Document: IR&2009-0008-0028 

Comment on FR Doc # E9-09629 

Submitter Information 

Name: Patricia A Dunsha 

Address: 

Gh, 

General Comment 

Cornrncnts regarding Regulatory Guidancc USCG-20U7-27022 

page I91 57, I1 B specific areas I and 4 

I am a mental health professional who supports EEG biofeedback treatment to 

individuals with Attention Deficit Hyperactivity Disorder and Mood Disorders. 

EEG biofeedback is an "cmpcrically validatcd" and widcly rccognizcd cffcctivc 

nun-medication treatment fur ADHD, as well as other cconditions. 

Unlike dangerous psychostimulants like Adderrall, EEG biofeedback has no side 

effects! There arc over 50 studies evaluating the effectivcness of EEG 

biofccdback in the treatment of ADHD, Substance Use disorders and Autism. A 

recent review of this literdturt: concluded "EEG bioiiiedba~k meets the American 

Academy of Child and Adolescent Psychiatry criteria for" Clinical Guidelines "for 

treatment nf ADHD." This means that EEG biofeedback meets the same criteria 

as medication for treating ADHD, and that EEG biofeedback "should always be 

considcrcd as an intcrvcntion for this disordcr by thc clinician". 

It is unfortunate that this service has been denied by Georgia Medicaid. Aetna, 

LJnited Rehavioral Health, Blue Cross, Cigna, and Amerigroup when the same 

insurance companies continue to pay for medication coverage that is dangerous 

and provides no cure or help for children with A IIHD. In fact, in my setting, the 

same kids have heen corning hack inonth after rnonth and year afier year to no 

avail. Medications have been changed back and forth nur-tierous times but of 
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course, this does nothing for the patient to move toward improvcmcnt in any 

way. 

The reasons given by the i~~surance cornpanics for this denla1 fell into two 

categories: 1 ) our company docs 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 fnr- more 

restrictive for mental health services than the criteria which arc used fur 

rnedical/surgi cal services. There are many rout inc mcd ical and surgical 

procedwes which havc far fewer contrulled studies about their efficacy than does 

EEG biofeedback. Thee medical and surgical procedures me generally not 

limitd because of concerns about how many controlled studies have been 

perFormed about them. 

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

statute should require that employers and plms pay for the same range and 

scope of services for Behavioral Treatments as they do for Med Surg benefits 

and that a plan cmmt be more restrictivc in 111cir managed carart .criteria and 

reviews for MH and SA disorders when cumpard tu Med Surg Today plans are 

bcing more restrictive in how they review evidenced-based Mental Health and 

Substance Abuse Treatments when compared to Med Surg treatments. 'lhis 

violates both the intent and letter of the parity statute and we hopc that thc 

regulatiaus will clarify that this can't continue.