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PUBLIC SUBMISSION As of: May 28,2009 

Tracking N o. 809ae602 

Docket: IRS-2004-0008 

Request for Information for Paul Wellstone and Pete Domenjcj Mental Health Parity and 

.4ddiction Equity Act ;tf2208 

Comment On: IRS_2009-0OoQ8,00@l 

Request for Information Regarding the Paul Wellstonc and Pete Dommici hlental Health Parity 

and Addiction Equity Act of 2008 

Document: IR S-2009-0003-0035 

Comment on FU IJoc # E9-09629 

Submitter Information 

Name: Joscph Anthuny West 

Address: 

Palm City, 

General Comment 

Joseph A. Wcst, M.S.,LMHC MHz 1 06 Licensed Psychotherapy 

901 S.E. Monterey Commons Suite 200, Stuart, Florida, 34990-4705 Office: 

(772) 287-6042 Fax: (772) 287- 

6045 

Cornmcnts regarding Regulatory Guidance USCG-2007-27022 

pagc 191 57, I1 B specific areas 1 and 4 

I am a clinical psychotherapist who providcs E EG and peripheral biofeedback 

treatment to individuals with Attention Deficit Hyperactivity Disorder, Headache, 

Chronic Pain arld Mood Disorders, EEG and autonomic biofeedback is an 

empirically validat4 and widely recognized effective nnn-medication treatmalt for 

ADHD. as well as tnany other conditions. There are ovcr 50 studics evaluating the 

effectiveness of EEG biofeedback in the treatrncnt of ADHD, Substance Use 

disorders and Autism. A rccmt review or this literature concluded "EEG 

hiofecdback mccts the American Academy of Child and Adfllescent Psychiatry 

critetia for" Clinical Guidclincv "fir treatment of ADIID." This means that EEG 

biofeedback tneets the samc crilcria as medication for treating ADHD, and that 

EEG binfeedhack "should always bc considered as an intervention for this disorder 

by the clinician". H~ofeedback has bc~m shown to be as effective as any 

prophylactic medication studied to datc at prcvcnting migraine 

This service has heen denied by Georgia Medicaid, Aetna, United Behavioral 
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Health, Bluc Cross, Cigria, and Amerigroup. 

This is limitatio~l of mn cffcctive and validated treatment for n mental hcalth 

pmhlein. The rcasons givm by the insurance cotnpanies for this denid fkll into two 

categories: 1 ) our company does not cover biofeedback tor Mental Health 

problems or 2) there is not yet sufficierlt evidcncc ibr the efficacy of EEG 

biofeedback. -4s such, they are using evidence-based criteria that are far rnore 

restrictive for nlcntal health services than the criteria which me uscd for 

n~dical/surgical services, There are many routine medicat and surgical 

procedures which have far fewer control led studicx about their efficacy than does 

EEG biofeedback. These medical and surgical procedures are generally not 

limited becawe of concerns about how many wntrolled studies have been 

performed about thm. 

Wc bclicvt: that the parity regulations, based on legal rcviews of the parity statute 

should require that employers and plans pay fur the same range and scope of 

services for Rehavioral Treatments as they do for Med Surg benefits and that a 

pl,m cannot bc mure restridive in their managed care critcria arkd reviews fur MI1 

and SA disorders when compared tn Med Surg. 'I'oday plans art: being more 

restridive in how they review evidenced-bascd Mental Health and Substance 

Abuse Treatments \v hen compared tu Med Surg treatments. This violates both the 

intent and letter of thc parity statute md we hope that the regulatio~ls will clarify 

that this can't wntinue. 

Mental heath Issues are one of the great prejudices of our society, based in part 

that these prfibletns are sorncl~ow less wurthy of care or something we should bc 

aqhamed of or hidc. It is time to treat people with Mental i Ilness with thc rcsptxl 

arid empathy that we treat all other medical problerns with. 

Sincerely, 

Joseph West, T.MHC