From: Eileen Roberts [mailto:drrobs@hotmail.com] 

Sent: Tuesday, May 26, 2009 9:14 PM 

To: EBSA, E-OHPSCA - EBSA 

Subject: Inequity in parity between mental health and medical treatments

I am a licensed clinical psychologist and have been in practice in hospital, university 

and private settings since 1977. Across that time I have explored a variety of 

evidence based treatments that might enhance my effectiveness. I have tried and 

abandoned many tools, keeping only those techniques with research backing and 

demonstrated effectiveness in my clinical practice. This journey has led me to 

specialize in the use of biofeedback, and most specifically EEG 

biofeedback/Neurofeedback, for the treatment of ADHD and medication resistant 

depression and anxiety. This modality has helped many of my patients who were 

either unresponsive or minimally responsive to medication, or were unable to 

tolerate medication side effects. 

 

Unfortunately, most insurance companies refuse to reimburse for the use of 

Neurofeedback or other forms of biofeedback, despite many decades of research. 

They claim that it is an "alternative treatment" and state that their failure to 

reimburse is based on "lack of research evidence of effectiveness". However, they 

reimburse routinely for physicians to prescribe medications "off label" or perform 

other procedures without any research basis other than the report of other 

physicians that a given medication or procedure has had a beneficial effect on a 

given syndrome. For example, JAMA recently published a review of the evidence 

base supporting the joint cardiovascular practice guidelines of the American College 

of Cardiology and the American Heart Association (Journal of the American Medical 

Association, February 25,2009, Vol 301, No 8). They found that of the 16 current 

practice guidelines only 11% of the guidelines were based on evidence from multiple 

randomized trials or meta-analyses (the standard that insurance companies state is 

required to consider EEG biofeedback as a reimburseable treatment). The 

remaining 89% of recommended cardiovascular practice guidelines were based upon 

a single randomized study, nonrandomized studies or "expert opinion, case studies 

or standards of care". THIS IS NOT EQUITY. Many medical treatments are routinely 

covered that have substantially less research basis than biofeedback. The core of 

the matter is that more scientific review criteria are employed for limiting 

reimbursement of biofeedback in mental/behavioral health treatment than are 

employed for the review/reimbursement of many common medical procedures. 

 

The reserach literature on EEG Biofeedback can be viewed at isnr.org. The evidence 

for it's effectiveness in many behavioral health/mental health conditions is 

significant, especially in the area of ADHD where a number of well designed studies 

have been published. There are also seven current studies showing a positive impact 

on Autism, where almost no other viable medical treatments have been established. 

 PARITY REQUIRES THAT THE SAME SCIENTIFIC REVIEW CRITERIA BE USED BY 

INSURANCE COMPANIES FOR BEHAVIORAL HEALTH CARE TREATMENTS SUCH AS 

NEUROFEEDBACK AS ARE EMPOLOYED IN THE EVALUATION OF MEDICAL AND 

SURGICAL BENEFITS. If this were the case, EEG neurofeedback would be a 

reimburseable treatment. 

 

Eileen Roberts Ph.D. 

Licensed Clinical Psychologist PSY21296 

State of California 

465 Healdsburg Ave 
Healdsburg Ca 95448 

707-338-9084 

 

 

 

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