CG-MED-97. 5'/2025. Biofeedback and Neurofeedback. Anthem's negative, fictional determination of "medical necessity"

[Michael Sitar]

CG-MED-97 Biofeedback and Neurofeedback https://share.google/0r6nGmFtlWZW3TfqI

M. Sitar

[Siegfried Othmer]

Michael et al —

So Anthem finds that “Neurofeedback... is considered not medically necessary for all indications….” even after lo these many years and oodles of studies. 

The overview of research for ADHD in this document sustained the case for the ’non-inferiority’ of NF vis-a-vis meds, but that apparently falls short of establishing medical necessity. So we have procedure codes without areas of application. 

How do we turn a liability into a virtue? The process begins with finally acknowledging the sheer folly of assaulting the medical edifice, and acquiescing to their terms of debate as to how efficacy needed to be established, namely RCTs and only RCTs. The medical industry has always wanted to drown NF in the bathtub, and the Anthem document can now claim success in that initiative. 

Even the definition of success eluded us along the way. Once medical necessity is proven, medical practitioners take advantage of the new market opportunity, and when it comes to reimbursement, they are first at the trough. The practitioner community that has come into existence would be left on the sidelines. 

Our uniqueness lies in the fact that our tool is the equivalent of the Swiss Army knife when it comes to healthcare. We teach self-regulatory competence, and one would not want to be without it. Our singular claim should be that by our methods we enhance self-regulatory competence. This cannot qualify for medical necessity, as it cannot rise to the level of a medical claim. It is not even recognized as a claim by the FDA, because it is likewise oriented toward the criterion of medical necessity. 

In this model, all of our published studies would be placed in the service of this single claim for the enhancement of self-regulatory competence, rather than being assigned to their respective bins within the medical model. All outcome studies become relevant, because the placebo is not our adversary. In this cause, we ally ourselves with biofeedback, whose core claim is likewise that of self-regulatory competence. 

Our burden shifts to one of making the case for self-regulation as the essential underpinning of both physical and mental health in considerable generality. That case is easy to make, as this serves the cause of prevention as well as of remediation. And then we become the beneficiaries…. 

The FDA has come to the point of allowing brain toys to exist under the banner of the ‘wellness model.’ We stand above that on the basis of a scientifically-guided, theory-informed discipline that promises the utmost with respect to individualization of the process. 

Siegfried Othmer, Ph.D.

Chief Scientist, The EEG Institute

Los Angeles

www.eeginfo.com

www.eeginstitute.com

On Feb 19, 2026, at 12:01 PM, Michael Sitar <michae...@gmail.com> wrote:

CG-MED-97 Biofeedback and Neurofeedback https://share.google/0r6nGmFtlWZW3TfqI

M. Sitar

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[Mark Trullinger]

Hello,

There are many ways to address this issue. I am sure our field will address it in the near future with the update to 90901, which has been approved to take effect January 1st, 2027.  

Also, as a general rule, the AMA as a whole is against blanket denials based on medical necessity when a category I CPT code exists, and in cases like this, from a parity perspective, they don't seem to address the direct comparison of the medically approved uses and diagnoses covered versus mental health ones.  As has been and I am sure will be noted, there are also more detailed and obvious issues.

Best,

Mark Trullinger, PhD, BCN, QEEG-D, Registered Psychology Associate (Maryland)

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