From: Jeffrey Wilson [mailto:JWilson@ADDTreatmentCenters.org] 

Sent: Thursday, May 28, 2009 7:21 PM 

To: EBSA, E-OHPSCA - EBSA 

Subject: FW: Parity for Neurofeedback - resent

Comments Regarding Regulatory Guidance USCG-2007-27022 

page 19157, II B specific areas 1 and 4

 

I am a clinical psychologist who provides neurofeedback treatment to individuals with Attention 

Deficit Hyperactivity Disorder and Mood Disorders. Neurofeedback is an empirically validated 

and widely recognized effective non-medication treatment for ADHD, as well as other 

conditions. There are over 50 studies evaluating the effectiveness of neurofeedback in the 

treatment of ADHD, substance use disorders and Autism. A recent review of this literature 

concluded "Neurofeedback meets the American Academy of Child and Adolescent Psychiatry 

criteria for Clinical Guidelines for treatment of ADHD." This means that neurofeedback meets 

the same criteria as medication for treating ADHD, of which 60% of prescriptions are in fact 

prescribed "off label," and that neurofeedback "should always be considered as an intervention 

for this disorder by the clinician." 

 

This service has been denied by Georgia Medicaid, Aetna, United Behavioral Health, Blue Cross, 

Cigna, and Amerigroup. 

 

This is limitation of an effective and validated treatment for a mental health problem. The 

reasons given by the insurance companies for this denial fell into two categories: 1) our 

company does not cover biofeedback for mental health problems or 2) there is not yet 

sufficient evidence for the efficacy of neurofeedback. As such, they are using evidence-based 

criteria that are far more restrictive for mental health services than the criteria which are used 

for medical/surgical services. There are many routine medical and surgical procedures which 

have far fewer controlled studies about their efficacy than does neurofeedback. These medical 

and surgical procedures are generally not limited because of concerns about how many 

controlled studies have been performed about them. 

 We believe that the parity regulations, based on legal reviews of the parity statute should 

require that employers and plans pay for the same range and scope of services for behavioral 

treatments as they do for medical surgical benefits and that a plan cannot be more restrictive 

in their managed care criteria and reviews for mental health and substance abuse disorders 

when compared to medical surgery. Today plans are being more restrictive in how they review 

evidenced-based mental health and Substance Abuse Treatments when compared to medical 

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

that the regulations will clarify that this can't continue. 

Sincerely, 

Jeffrey Wilson, PhD

Clinical Director

ADD Treatment Center

27725 Santa Margarita Pkwy #215

Mission Viejo, CA 92691

(949) 272-3870

(949) 951-2802 fax

www.ADDTreatmentCenters.com
 

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