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PUBLIC SUBMISSION 

Docket: IRS200Y4.008 

Request iir lnl'ormation for Paul W ellstone and Pete Domenici Mental I-Iealth Parity and 

Addiction Equity Act of 2008 

Conimcnt On: IRS-2OQ9~000~-000! 

Request for Tnfotlnation Regarding the Paul Wellslone and Pctc Do~neliici Mental Health Parity 

and Addiction Equity Act of 2008 

Document : I KS-2009-0008T0.Q4.0 

Commcnt otl FR Doc # E9-09629 

Submitter Information 

Name: Krystal S Angevinc: 

Addrcss: 

Pekin, IN, 

Organkatiun: Biofeedback Counseling Center 

Government Agency Type: Fcdcral 

C;ovcrnment Agency: HHS 

General Comment 

Comrncl~ts regarding Regulatory Guidance USCG-2007-27022 

page 1 91 57, I1 B spccific areas 1 and 4 

I am writing this letter because currcnt insurance non-coverage policies deny 

biofeedback. a proven beneficial treatment Kur headaches, anxiety, and pain 

rnanagcment for children and adults. Therefore, it is my ethical responsibility 

to bring to your allention a disparity in treatment options. Currently, it is 

only those persons with the financial means to pay privately that me able to 

receive the effective treatment that all should bc able to receive. 

A metn-analysis of biofeedback for tension headaches publisllcd in the 1 ronsult 

Clrn Psycho1 (2008) 76: 379-96 studied 53 outcome studies. Biofccdback was 

shown to bc efficacious. Effects were particularly large in children arid 

dulescents. 11 was concluded that biofeedback constitutes an evidence-based 

trcatrncnt option for tension-type headache. Another meta-analy sis of biofccdback 

for mig-ainc headaches pub I ished in 2007 found biofeedback to be an 

cvidcncc-based treatment option for migraine headache. 

In fact, Biof'ccdhack has bee11 shown through scientifically rigorous wntrollcd 

studics to bc crnpirical ly supported for the following conditions: 

1. Anxicty 

2. Atlcntion DcGcit Disorder 
3. Headache 

4. Hypertension 

5. Temporomandibular Disorders 

6. Alcoholism/Substmct: Abusc 

7. Arthritis 

8. Chronic Pait1 

9. Epilepsy 

10. Insomnia 

1 1. Traumatic Drain Injury 

12. Asthma 

1 3. Chronic Obstructive Pulmonary Disease 

14. D~prcssivc Disorders 

1 5. Diabetes Mellitus 

1 6. Fihromyalgia 

17. Foot Ulcers 

18. Hand Llystonia 

19. Imtabll: Bowcl Syndrome 

30. Myocardial Ini'arction 

2 1 . Post Traumatic Stress disorder 

22. Raynaud's Disease 

23. Strokc 

Why thm are insurance colnpanies denying payment fir lhcsc treatment options, 

yet will pay for any FDA approvcd medication with less efficxy than the 

biofeedback? We believe that the parity regulations, bawd on legal reviews of 

the parity statue should require that emplcycrs and plans pay for the same range 

and scope of se~iccs for Behavioral Treatments as they do for Med Surg benefits 

and that a plan cannot bc more restrictive in their managtrl mc criteria and 

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

Inore ~estrictive in how they review cvidcnced hnsed Mental Health and Subslancc 

Abusc 'l'reat~nents when compared to Mcd Surg treatments. This violates both the 

intent and letter of the parity statute and we hope that lhc regulations will 

clarjfv that this can't continue. 

 hank you for your cunsidaation, Krystal Angevine, LCSW,