The proposal
Publish a commentable Standard of Care
A shared floor of competence, safety, and honest representation — not a new license, and not a replacement for existing ethics codes.
What we are proposing
We propose that Essential Practice Standards for Neurofeedback be published as a public, commentable Standard of Care. The draft describes a proposed floor that adopters would agree to. It is not the legal standard of care, and it does not bind people who have not adopted it. It does not create a license. It does not replace the ethics code of a provider’s primary profession.
Why it is needed
- Clients cannot tell a competent service from an automated pipeline or an unlicensed shop.
- Other health professions look for a Standard of Care and find ethics codes and voluntary certification instead.
- A 2011 ISNR Board-accepted position paper described practice standards, but the field did not adopt a membership-ratified Standard of Care. Later society materials emphasize ethics principles and Guidelines for Practice.
- Certification is valuable and voluntary. It is not a license and does not bind non-certificants.
What would change if these standards were adopted
| Now | Proposed floor |
|---|---|
| Maps from automated qEEG software accepted without raw-trace review | Raw traces reviewed before maps may set a protocol |
| Introductory workshop treated as qualification | Structured training, mentoring, and supervision before independent practice |
| Certification spoken of as a license | Certification described accurately; treatment of diagnosed conditions stays inside a license or documented supervision |
| Experimental protocols advertised as established | Condition-by-condition honesty; experimental work labeled and consented |
| Unsupervised multi-station or home programs for diagnosed conditions | A responsible practitioner present or accountable; home training is the exception, not the default |
The 14 proposed domains
- 1. Licensure, scope, and supervision — Treat diagnosed conditions only inside a license, or under documented supervision.
- 2. Competence beyond an introductory course — A workshop is not qualification for independent practice.
- 3. Representation of credentials — State licenses and certificates accurately. A certificate is not a license.
- 4. Informed consent — Document the method, risks, limits, and experimental status before training begins.
- 5. Assessment before training — Plan from history, goals, and a pre-training EEG assessment.
- 6. Claims about evidence — Distinguish published support from experimental use, condition by condition.
- 7. Presence, coaching, and technicians — A responsible practitioner remains with the trainee. Technicians work under direction.
- 8. Remote and home training — Home programs are the exception for diagnosed conditions, not the default.
- 9. Hygiene, sensors, and equipment — Clean technique, adequate contact, and equipment fit for clinical use.
- 10. Records, billing, and privacy — Bill only what was delivered. Keep a complete clinical record.
- 11. Public statements — Advertising matches published support. No promised cure.
- 12. Training programs and equipment sales — Do not place clinical methods in unlicensed, unsupervised hands.
- 13. Quantitative EEG used to guide training — Raw traces must be reviewed before maps may set a protocol.
- 14. Research using neurofeedback — Honest design and reporting. Clinical competence, or supervision by someone who has it.
Domain 13 in plain language
Quantitative EEG maps, z-scores, source images, and software narratives are derived products. They are only as valid as the raw recording.
Before any quantitative output is accepted for clinical use, a qualified reviewer inspects the original raw traces, in more than one montage, and documents artifact, drowsiness, electrode and reference problems, and spike-like or paroxysmal events.
Uploading a recording to automated processing software or a remote mapping service does not satisfy that review unless the original traces are independently inspected and the processed output is checked against those traces.
A map hotspot that cannot be seen in the raw tracing is not used as a training target.
This proposed rule exists because muscle can appear as excess fast activity, eye movement as frontal slowing, drowsiness as a false waking baseline, and automated rejection can strip real events or leave artifact in.
What this proposal is not
Not a license. Not a claim of society adoption. Not a treatment-efficacy argument. Not a clinic advertisement.
How this would be organized
This site is a draft for committee discussion. If the field later wants a home for these standards, the working idea is:
- A nonprofit compact (educational 501(c)(3) or professional 501(c)(6) — counsel would choose), not a clinician-owned collection company.
- Voluntary opt-in. Non-signatories would not be bound.
- Private remedies limited to warning, correction, listing, and any future mark — not fines designed to force clinics into small claims.
- Clinical harm would still go to a state licensing board.
- Societies such as AAPB, ISNR, and BCIA would be asked for support and comment, not to police non-signatories.
How to respond
Email office@altbehtherapy.com or call 360-553-1350. Additional working-group contacts will be posted as people consent. These contacts are for comments on the draft, not requests for clinical care.