New York, NY – Aug. 9, 2017 – The National Advertising Division has recommended that Neurocore, LLC, discontinue challenged advertising claims for the company’s “Brain Training Centers,” including claims related to Attention Deficit/Hyperactivity Disorder (ADHD), autism, migraines, memory issues, sleep disorders and stress.  The company said it will appeal NAD’s decision to the National Advertising Review Board.

NAD is an investigative unit of the advertising industry’s system of self-regulation. It is administered by the Council of Better Business Bureaus.

The claims at issue in NAD’s review are made at the advertiser’s website where the “Who We Help” tab provides a menu that allows users to click on individual issues – ADHD, Adult ADHD, Anxiety, Autism, Depression, Memory, Migraines, Sleep, Stress and Teen ADHD. The individual issues pages feature health-related claims about what the Neurocore program can do.  Those claims include:

• “Overcome ADHD – without drugs”
• “How to Overcome Adult ADHD Drug-free (and Improve Your Daily Life in the Process)”
• “Control your anxiety without medication”
• “Drug-free program to help curb the symptoms associated with Autism”
• “Strengthen your brain to fight depression – without medication”
• “Stay sharp for years to come” “Don’t miss out on life’s precious moments,” and “Stop migraines before they start.”

NAD noted in its decision that Neurocore makes quantified claims about its outcomes for ADHD, anxiety, and depression – and that the claims are based on results from Neurocore’s internal data analysis, the Neurocore 2016 Study, which tracks the before and after results of Neurocore clients who complete their 30-session program.

For example, NAD’s decision stated, the ADHD outcomes are listed as:

• 90% report fewer or less frequent ADHD symptoms
• 85% experience a “clinically important” reduction of ADHD symptoms 76% achieve non-clinical status
• 54% no longer meet symptomatic thresholds for ADHD

NAD determined that the strong health-related claims convey the message that each new client is just as likely to experience the same results after completing 30 sessions of the Neurocore Program.

Health-related efficacy claims must be supported by competent and reliable scientific evidence. As NAD noted in its decision, generally, for health-related claims, competent and reliable scientific evidence are human clinical trials that are methodologically sound and statistically significant to the 95% confidence level with results that translate into meaningful benefits for consumers that relate directly to the performance attributes promised by advertising.

The advertiser provided its internal client data analysis and argued that its use of internal efficacy outcomes is sound. NAD was concerned, however, that studies analyzing internal assessment data, while important for internal or external accountability, do not provide competent and reliable scientific evidence in support of health-related advertising claims.

NAD noted that, as Neurocore’s own statistical expert report explained, there is a difference between clinical studies and observational studies. Observational studies, like Neurocore’s review of internal data, provide information on the treatment of a particular group of people but they do not provide a basis for inferring or projecting how another population will respond to the same treatment. As Neurocore’s statistician explained, “descriptive statistics do not, however, allow us to make conclusions beyond the data analyzed.”

In addition to its internal studies on the Neurocore program, the advertiser submitted multiple studies and articles on neurofeedback and its use in treating symptoms of ADHD, anxiety, depression, autism, as well its effect in improving memory, sleep and migraines.  The most reliable form of evidence to support health-related advertising claims is randomized controlled trials which compare results from using the product at issue (here a thirty session Neurofeedback and biofeedback program) to a control so that the results from the neurofeedback can be distinguished from a placebo.

The research submitted by Neurocore referenced a variety of different neurofeedback protocols, while Neurocore uses a specific type of neurofeedback – “Z Score.” The advertiser’s expert report explained the mechanism of action of Z-Score neurofeedback and why it is an improvement over prior methods, but an expert opinion cannot substitute for randomized controlled trials on the method itself.

In addition, to NAD’s concern that the specific type of neurofeedback used in the Neurocore program has not been subject to robust clinical trials, to the extent there is clinical testing regarding the effectiveness of neurofeedback on a variety conditions including ADHD, the results are mixed. A February 2017 article evaluating how neurofeedback is being used in both clinical and experimental settings notes that while there are randomized controlled trials regarding improvements in ADHD symptoms, meta-analyses of these studies have yielded inconsistent findings.

Inconsistent evidence regarding a claimed effect may affect the strength of the advertising claim made to consumers, or whether an advertising claim claim can be made at all. Evidence on the efficacy of neurofeedback on all of these conditions is mixed. As a result, NAD had substantial concerns about whether this body or research supports the strong, health-related claims made for Neurocore.

Neurocore’s claims about ADHD, anxiety, depression, autism, and memory, migraines and sleep are interspersed with testimonials from Neurocore clients claiming improvements after completing the program. In addition, the website includes an entire webpage with client reviews. Many of the testimonials claim that the Neurocore program reduced or eliminated the need for medication and provided a solution or even a cure for these challenging conditions.

Following its review of the evidence in the record, NAD concluded that the advertiser’s evidence was insufficiently reliable to substantiate the strong health-related advertising claims.

NAD recommended that all of the challenged claims be discontinued. NAD also recommended that the advertiser discontinue its testimonials which claim that Neurocore clients have reduced or eliminated the need for medication for ADHD, Anxiety, Depression, memory problems, migraines or sleep disorders and further cautioned the advertiser to discontinue its use of testimonials which make claims that the advertiser could not support.

Neurocore, in its advertiser’s statement, said that the company would appeal NAD’s finding to the NARB.

“Neurocore stands firmly behind the accuracy and integrity of the results reported by the clients who complete its program, and strongly believes that the testimonials of its clients are truthful, accurate, and representative of the typical client experience,” the company said.

Note: A recommendation by NAD to modify or discontinue a claim is not a finding of wrongdoing and an advertiser’s voluntary discontinuance or modification of claims should not be construed as an admission of impropriety. It is the policy of NAD not to endorse any company, product, or service. Decisions finding that advertising claims have been substantiated should not be construed as endorsements.