[Mark in Idaho]

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I have researched further and found an interesting report of a meeting held by the International Society for Neurofeedback and Research, formerly know as the International Society for Neuro Regulation.

The report is posted in full at http://www.eeginfo.com/newsletter/?p=296

About half way down the page are some interesting comments. I have quoted them here:

<This led to the discussion to the importance of the definition of biofeedback. Our profession has no agreed-upon definition of the interventions that constitute biofeedback and neurofeedback. He recommended we not limit ourselves to the volitional control of psychophysiological mechanisms and recommended that our profession band together and come to a broader more inclusive consensus as to what the

definition is while being mindful that FDA definitions change over time and could become more restrictive. Given the technological changes that are taking place now in the field, HRV, HEG, and the recent reintroduction of Direct Current Stimulation, the field should be looking to the future in anticipation of technological advances, and define the field broadly.

“If you don’t do it, someone else will and you’ll be stuck with that definition.” The attorney mentioned that in the current administration, there may even be less emphasis on going after manufacturers (the FDA has recently downsized significantly) and may be less focused on the consumer and but that this climate may indeed change with a new administration which could be more consumer-based and less tolerant of unsafe business practices.>

I suggest that persons interested in the stimulating (non-volitional) versions of neurotherapy be informed about the restrictions therapists have regarding the use of these systems. I consider those who try to circumvent the laws and regulations suspect. A professional knows both the science of his field and the laws and regulations that pertain to it. If they try to promote their practice in violation of those laws and regulations, how can we trust them to treat us with professional skill and ethics?

The non-volitional or stimulating versions of neurotherapy include LENS, ROSHI, pROSHI, FLEXYX, ( Flexyx Neurotherapy System–FNS) Alpha Stim, CES (Cranio-electrical stimulation ), and any device that inputs an electrical or magnetic force into the brain. Such devices are limited to use by M.D.'s.

If you see them promoted by other than M.D.'s or promoted for the treatment of head/brain injury, this is illegal. An M.D. can use them to treat the psychological symptoms of head injury, but not the physiological/cognitive symptoms.

If anybody doubts these comments, post your concerns and I will post the research and regulations that support my comments.