CLC COMMENDS CMS DECISION TO EXPAND COVERAGE OF PET SCANS
(December 1, 2004)
December 1, 2004
Submitted Electronically to CMS
Re: Draft Decision Memo for Positron Emission Tomography (FDG) for Brain, Cervical, Ovarian, Pancreatic, Small Cell Lung, and Testicular Cancers (CAG-00181N)
Dear Dr. McClellan:
The undersigned organizations, representing cancer patients, providers, and researchers, are writing to express their support for the draft decision memo for coverage of PET scans as a diagnostic tool for several cancers. We applaud the Centers for Medicare & Medicaid Services (CMS) plan to cover PET scans in brain, ovarian, pancreatic, and small cell lung cancers while at the same time collecting data that may establish the benefits of the technology in these cancers.
We note that CMS concluded
that the evidence was sufficient to support coverage of PET for cervical
cancer diagnosis and staging without requiring enrollment in a trial or
registry, while the agency issued a non-coverage decision for use of PET
in testicular cancer. Because the CMS-requested technology assessment
concluded there is some evidence of the utility of PET in testicular cancer
and in light of the most recent recommendations from the National Comprehensive
Cancer Network that PET scans be used in cases of recurrent or residual
testicular cancer, we would encourage the agency, instead of establishing
a non-coverage policy, to cover the technology for testicular cancer if
patients are enrolled in a high-quality clinical trial. This approach
is responsive to the conclusion of the technology assessment that more
studies are necessary to establish the effectiveness of PET in testicular
This innovative plan for coverage will likely encounter some implementation obstacles, and we are encouraged that CMS is consulting with the professional and research organizations whose members will be utilizing PET in cancer diagnosis and staging and analyzing the clinical trials and registry data.
We appreciate the opportunity to comment on this proposal and look forward to working with CMS on other cancer care coverage and reimbursement issues.
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