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PUBLIC SUBMISSION 

Docket: IRS-2009-4008 

Rcquest fnr Information Sir Paul Wellstane and PG~G Domcnici Mental HeaIth Parity and 

Addiction Equity Act of 2008 

Comment On: TRSL200~4A~8~0&01 

Requesl filr Informatinn Regarding the Paul Wellstone and Pete Dorn~nict Mental Health Parity 

and Addidion Equity Act of 2008 

nocument: ~RS~2~~~!1-0008-00_$_$~ 

Comment on FR Doc # E9-09629 

Submitter Information 

Name: Susan Elise Antelis 

Address: 

Lynbrook, N Y . Submitter's Representative: Susan E Antelis 

Organization: Northeast Regional Biofeedback Society 

General Comment 

Comm cots regarding Regulrztory Guidance 11 SCG -2007-27022 

page 1 9 157,il B specific areas 1 and 4 

1 am the Executive Dircctor of the Northeast Regional Biofeedback Society, and 

1 an7 a NYS Licensed Mcntal Health Counselor who providcs EEG biofeedba~k 

treatrncnt to individuals with Altcntion Deficit Hyperactivity Disorder and Mood 

Disorders. EEG hiofeedback is an empirically validated and widely rcwgnized 

effective nun mdication treatment for ADHD, as well as other conditions. Thac 

are over 50 studies evaluating the effectiveness of EEG biofeedback in the 

treatment of ADHD, Substance Use disorders and Autism. . A recent review of 

(his literature concluded "EEG biofeedback meets the Ammican Academy of Child 

and Adotcscent Psychiatry critmia for" Clinical Guidelines "Sir treatment of 

AD1 ID." This mcms that EEG biofeedback mccts the same criteria ab to medication 

for treating ADHD, mnd that EEG biofeedback "should always be considered as an 

intewrntio11 for this disorder by the clinician". 

This survitx has been denied by Georgia Medicaid, Aetna United Behxvioral 

IIeaIth, Bluc Cross, Cigna, and Amerigrc~up. 

This is limilation of nn effective and validated treatment for a mental health 

problem. Thc reasons given by the insurancc co~~lpanies for this denial fc1I into 

two ca tcgories: 1 ) our company does not cover biofeedback for Mcntal I-lealth 

problems or 2) there is nnt yet sufficien( evidcnce for the efficacy uf EECi 
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hiofeedback. As such, they are using evidence-basal c:riteria that are far more 

restrictive for mental health serviccs than the criteria which are used for 

medical/surgical services. There are many routine medical atld surgical 

procedures which have t'a fcwer contrnlIed studies about their efficacy than 

does EEG hiofeedback. These mcdicaI and surgical procedures are generally not 

limited because of concerns about how many co~itrolld studies have been 

paformed about them. 

We believe that thy parity regulations, based on legal reviews of thc parity 

statue should require that empluycrs and plans pay for the same range and 

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

that a plan cannot be inore restrictive in their managed care criteria and 

reviews fur MH and SA disorders when compared to Mod Slug. 'Today plans are being 

mnre restrictive in huw lhcy review evidenced based Mental Hcaltl~ and Substance 

A huse Treatments when campard to Med Surg treatments. This violates both the 

intcnt and letter of the parity statute and wc hope that the regulations will 

clarify that this can't continue. 

Sincerely, 

Susan Antelis, MPS, LMHC:, BCIA-C Sr. Fellow, BcIAC-EEG 

Executive Director of NRBS, Northeast Rcgional Biofeedback Society 

Regional Chapter of the AAPB, Association for Applid Psychophy siology and 

Biofeedback