As of: May 28, 2009 Received: May 28, 2009 Status: Pending_Post PUBLIC SUBMISSION Tracking No. 809bc72e Comments Due: May 28, 2009 Submission Type: Web Docket: EBSA-2009-0010 Request for Information Regarding the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 Comment On: EBSA-2009-0010-0001 Request for Information Regarding the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 Document: EBSA-2009-0010-DRAFT-0252 Comment on FR Doc # E9-9629 Submitter Information Name: Aubrey K. Ewing Address: 1230 S. Federal Hwy STE 101 Boynton Beach, FL, 33435 Email: [email protected] Organization: Associatin for Applied Psychophysiology & Biofeedback General Comment I am a counseling psychologist who provides EEG biofeedback treatment to individuals with Attention Deficit Hyperactivity Disorder. I also utilize general, peripheral biofeedback modalities (EMG, skin temperature) for the treatment of anxiety related disorders. EEG biofeedback 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 EEG biofeedback in the treatment of ADHD, Substance Use disorders and Autism. A recent review of this literature concluded “EEG biofeedback meets the American Academy of Child and Adolescent Psychiatry criteria for” Clinical Guidelines “for treatment of ADHD.” This means that EEG biofeedback meets the same criteria as to medication for treating ADHD, and that EEG biofeedback “should always be considered as an intervention for this disorder by the clinician”. In the case of general, peripheral methods of biofeedback, there is also compelling evidence published in peer reviewed journals indicating biofeedback to be effective in the treatment of generalized anxiety and related disorders. Despite a significant body of scientific literature supporting neurofeedback (EEG biofeedback) and general biofeedback as equivalent in their efficacy in the treatment of these mental health diagnoses to the traditional methods of medication and psychotherapy, coverage for these services continues to be denied by many health insurance providers. 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 biofeedback. 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 EEG biofeedback. 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 Med Surg benefits and that a plan cannot be more restrictive in their managed care criteria and reviews for MH and SA disorders when compared to Med Surg. Today plans are being more restrictive in how they review evidenced based Mental Health and Substance Abuse Treatments when compared to Med Surg treatments. This violates both the intent and letter of the parity statue and we hope that the regulations will clarify that this can't continue. Please include neurofeedback and biofeedback treatment of mental disorders as sevices that should be covered in parity with other Med Surg and mental health procedures. Thank you. Aubrey K. Ewing, Ph.D. Immediate Past-President Association for Applied Psychophysiology and Biofeedback Attachments EBSA-2009-0010-DRAFT-0252.1: Comment on FR Doc # E9-9629 Evidence-Based Practice in Biofeedback and Neurofeedback CAROLYN YUCHA , P H.D. DOIL MONTGOMERY , P H.D. Association for Applied Psychophysiology and Biofeedback (AAPB) Founded in 1969, AAPB is the foremost international association for the study of biofeedback and applied psychophysiology. AAPB is an interdisciplinary organization representing the fields of psychology, psychiatry, medicine, dentistry, nursing, physical therapy, occupational therapy, social work, education, counseling, and others. The mission of AAPB is to advance the development, dissemination, and utilization of knowledge about applied psychophysiology and biofeedback to improve health and the quality of life through research, education, and practice. AAPB 10200 W. 44th Ave #304 Wheat Ridge, CO 80033 303 422 8436 phone 303 422 8894 fax email [email protected] www.AAPB.org Copyright/Ownership Copyright © 2008 Association for Applied Psychophysiology and Biofeedback. ISBN 1-887114-19-X All rights reserved. No part of this publication may be reproduced or utilized in any form or by any means, electronic or mechanical, including photocopying, recording, or by any information storage and retrieval system, without permission in writing from the publisher. Acknowledgements — 2008 Edition The authors would like to thank Donald P. Moss, PhD, for his guidance in developing this monograph. They would also like to thank Pam Sherwill, MS, librarian at the University of Florida (2004 edition) and Eva Stowers, MS, librarian at the University of Nevada, Las Vegas (2008 edition) for their invaluable assistance in searching the literature for biofeedback articles. Thank you to Robert P. Whitehouse, EdD, and Ronald L. Rosenthal, PhD, for compiling the CPT Treatment Codes. We would like to acknowledge the work of Christopher Gilbert, PhD, for his work on the 2004 edition of this book. In addition, we would like to thank the following members of the Association for Applied Psychophysiology and Biofeedback who reviewed this edition of the monograph prior to publication. Frank Andrasik, PhD Angele McGrady, PhD, MEd, LPCC Steven M. Baskin, PhD Susan J. Middaugh, PhD, PT Jeffrey E. Bolek, PhD Vincent J. Monastra, PhD Patricia S. Cowings, PhD Fred Muench, PhD Aubrey K. Ewing, PhD, BCIAC Randy Neblett, MA, LPC Richard N. Gevirtz, PhD Olafur S. Palsson, PsyD Howard I. Glazer, PhD Stephen Porges, PhD Howard Hall, PsyD, PhD, BCIAC Richard A. Sherman, PhD Lynda P. Kirk, MA, LPC, BCIAC, QEEGT Andrea J. Sime, LCSW Paul M. Lehrer, PhD, BCIAC Gabriel Tan, PhD, ABPP, BCIAC Websites for further information Association of Applied Psychophysiology and Biofeedback www.aapb.org Biofeedback Certification Institute of America www.bcia.org Biofeedback Foundation of Europe www.bfe.org International Society for Neurofeedback and Research www.isnr.org i Foreword: Evidence-Based Practice in Biofeedback and Neurofeedback Donald Moss, PhD, and Frank Andrasik PhD Biofeedback and Neurofeedback Biofeedback is a technique that enables an individual to learn how to change physiological activity for the purposes of improving health and performance (Gilbert & Moss, 2003; Schwartz & Andrasik, 2003; Shaffer & Moss, 2006).1 Biofeedback instruments are used to feed back information about physiological processes, assisting the individual to increase awareness of these processes and to gain voluntary control over body and mind. Biofeedback instruments measure muscle activity, skin temperature, electrodermal activity (sweat gland activity), respiration, heart rate, heart rate variability, blood pressure, brain electrical activity, and blood flow. Research shows that biofeedback, alone and in combination with other behavioral therapies, is effective for treating a variety of medical and psychological disorders, ranging from headache to hypertension to temporomandibular to attentional disorders. The present publication surveys these applications and reviews relevant outcome research. Biofeedback is used by physicians, nurses, psychologists, counselors, physical therapists, occupational therapists, and others. Biofeedback therapies teach the individual to take a more active role in maintaining personal health and higher level mind-body health. Neurofeedback is a specialty field within biofeedback, which is devoted to training people to gain control over electro-physiological processes in the human brain (Demos, 2005; Evans & Abarbanel, 1999; LaVaque, 2003; Thompson & Thompson, 2003). Neurofeedback uses information from the electroencephalogram (EEG) to show the trainee current patterns in his or her cortex. Many neurological and medical disorders are accompanied by abnormal patterns of cortical activity (Hammond, 2006). Neurofeedback assessment uses a baseline EEG, and sometimes a multi-site quantitative EEG (QEEG), to identify abnormal patterns (LaVaque, 2003). Clinical training with EEG feedback then enables the individual to modify those patterns, normalizing or optimizing brain activity. Neurofeedback practice is growing rapidly with the widest acceptance for applications for attention deficit hyperactivity disorder (ADHD), learning disabilities, seizures, depression, acquired brain injuries, substance abuse, and anxiety (Clinical EEG, 2000). Complementary and Alternative Therapies Biofeedback and neurofeedback are attractive approaches for individuals who are seeking complementary and alternative medicine (CAM) therapies (Lake & Moss, 2003). The public appears to seek out therapies that 1) give the individual a more active role in his or her own health