Docket: IRS-2009-0008 

Request for Information for Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 

2008 

Comment On: IRS-2009-0008-0001 

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

Equity Act of 2008 

Document: IRS-2009-0008-0108 

Comment on FR Doc # E9-09629 

Submitter Information 

Name: Linda Ann Yegge-Brannon 

Address: 

Newberg, OR, 

General Comment 

I am a clinical social worker who specializes in pain management. As our 

population ages, we need to have robust treatment options for individuals with 

chronic pain. There is empirical evidence that chronic pain and mental health 

conditions are often comorbid conditions. The ability to use various methods of 

biofeedback and neurofeedback (also evidence based treatment protocols) provide 

ways for patients to gain control of their mental health emotions and physical 

response that without viable options leads to pain and the high cost of pain 

medications and continual rehabilitation treatments. In an era when we need to 

reduce healthcare costs and still provide the coverage people need for mental 

health conditions (lets remember, the mind and emotional neurological response 

are still body medicine) it seems much more cost effective to teach people to 

manage their symptoms through biofeedback and neurofeed than to provide a 

lifetime of chronic medication use and accept that they will have lower to no 

productivity because chronic pain. 

Biofeedback and Neurofeedback provide patient tools that are time limited in 

learning and cost and a lifetime of benefit. 

Many of the insurance carriers which patients utilize provide little or no coverage 

for bio/neurofeedback treatment. It appears they are just uninformed about the 

cost containment that such treatment provides for patients who have mental health 

disorders and get hurt as well as individuals with chronic pain whose source is 

injury and poor adaptive mental health skills. 

PUBLIC SUBMISSION 

As of: May 29, 2009 

Tracking No. 809bcaf7 

Comments Due: May 28, 2009
Please make a place in the regulation of the parity act for treatment that is 

effective and cost containing and will help our younger and older populations to self 

manage their own symptoms on a long term basis after short term treatment. 

Also, I know that you are focused on the enforcement of the statute for mental 

health equity and that this addresses only those members who have group policy 

coverage. However, I am also highly concerned that the parity act did not address 

mental health treatment parity for persons with individual policies, treating those 

who do not have group policies as if their mental health is separate from their 

physical health. We've started down the correct road. Now we need to go back 

and pick up the pieces the statute left behind. For example, a 17 year old child 

with OCD, obtaining an individual policy because she is not out of school and her 

parents do not have the income for or access to a group policy pays for individual 

healthcare coverage, who can't get coverage to speak to a doctor about her status 

use of mental health medications that allows her to go to school and become a 

productive member of society. Why? 

I support the work being done now by the regulations development group and 

challenge us to continue to make it better for all citizens of the USA by supporting 

more statute development in this area. 

Thank you for reviewing my comments. Linda Yegge-Brannon, LCSW in Oregon