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PUBLIC SUBMISSION As of: May 28, 2009 

Tracking No. g09aed3a 

Docket: IRS-2009-0008 

Request for Inforrnatiot~ for Paul Wcllstone and Pete Domenici Mental Healtl~ Parity atld 

Addiction Equity Act of 2008 

Comnlent On: IKS-X)NJ):Jj1)U8-(W 

Kequcst for Iniumation Regarding the Paul Wellstonc and Pelt: Domenici Mental Health Pa-rity 

and Addiction Equity Act nf 2008 

Document: lRS,2~.09~0008-0039 

Comment on FR Doc # E9-119629 

Su brnitter Information 

Name: Jams D Brown 

Address: 

Stuart, FL, 

Submitter's Reprcscntative: None 

Organization: Neurogenix 

Government Agency Type: Local 

General Comment 

JAMES D. BROWN 

1200 SW Dyer Point Road I Palm City, FL 34990 

Ph: (772) 283-9972 

Fax: (772) 22 1 -8042 

Comments regarding Regulatory Guidancc USCG-2007-27022 

page 191 57, TI B specific areas 1 and 4 

1 a rncntal health practitioner who provides EEG hiofcdback (neurokedback) 

treatm~nt to individuals with Attention Deficit Hyperactivity Disurdcr (ADI 1D) and 

Muod Disorders. EEG biofeedback has bccn empirical1 y validated and widely 

rwognized as an effective non-medicat ion, nun-invasive, treatment for ADHD, 

PTSD, brain depression, anxiety, and Inany othcr conditiuns. There are over SO 

studies evaluating the effectiveness of EEG biofccdba~k in the treatment of 

ADHD, substance abuse disorders and autism. . A rcccnt review of this literature 

wncltrcld "EEC biofeedback meets the Ammcan Academy of Child and 

Adolescent Psychiatry criteria for" Clinical Ciuidclincs "for tredtment of ADIID." 

This means that EEG biofeedback meets the same critcria ns medications. 
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Unfortunately for the peopIe who suffer from these disorders, F.EG biofeedback 

services have bccn denied coverage by Gcorga Medicaid, Aetna, Unitd 

Behavioral Health, Blue Cross, Cigna, Amerigroup m~d othcrs. This prevents in 

many cases access to m effective and valid treatment tiir mental health 

problems. 

The reasons givm by the insura~~cc companies for this denial of coverage fall into 

twu categories: 

- company policy docs not cvver EEG biofeedback fir mental health 

pmhlerns 

lack of suili~ient evidence for thc ellicacy of EEG hiofecdbac.k. 

Apparently, insurar~cc companies are using evidence-based criteria for authorizing 

coverage for EEG biofeedback treatmei.lts that art: Far more restrictivc than the 

criteria they usc tbr medicaL'surgica1 services. There are many I-out ine medical 

and surgical procedures which havc far fewer controlled studies about their 

efficacy than does EEG biofccdhack. These medical and surgicaI procedures are 

generally not limitcd bewuse of concerns about how many cc7ntmlled studim 

have been performed about them. 

I bclieve that parity regulntions are needed that should rcquire insurance 

cumpanies to pay for the same range and scope of sewiccs livr mental health 

treatments ns they do fbr medicaVsurgical strvices. It is blatantly biased that a 

medical plan bc more restrictive in their managed we criteria for mcntal health 

services. This violates both the intent and letter of the parity statute and we hope 

(hat regulations wilt corrcct his bias. 

lames D. Brown 

Neurogenix, Inc 

Stuart, FL