In response to a proposed national coverage decision by the Centers for Medicare and Medicaid Services not to pay for screening CT colonography (CTC) for Medicare enrollees, C3 has submitted comments asking that CMS cover screening CT colonography (virtual colonoscopy) as part of a Coverage with Evidence Development (CED) process.
A CED would enable CMS to determine if CT colonography is safe and effective in the older Medicare population and which patients might benefit from screening using CTC rather than optical colonoscopy.
We believe that older patients should have a choice for colorectal cancer screening methods after a discussion of the risks and benefits of each method with their doctors. And we want good information available for those patient decisions.
Recognizing the difference in screening guidelines from the American Cancer Society developed in consensus with the Multi-Society Task Force on Colorectal Cancer and the American College of Radiology which include CTC as a test that can prevent colorectal cancer and those of the United States Preventive Services Task Force (USPSTF) which found “insufficient evidence to assess the balance of risks and benefits of CTC“, C3 urges coverage that could provide more information to clear up this confusion.
C3 comments included:
Therefore, C3 strongly urges CMS to gather the evidence by approving coverage of CTC, and implement the new coverage through a Coverage with Evidence Development (CED) process. A CED will generate additional safety and efficacy data in people over the age of 65, a population that is typically under-represented in clinical research. CED can also generate information that will help to identify patients who can benefit from CTC as opposed to optical colonoscopy.
A complete denial of coverage is akin to “throwing the baby out with the bathwater.” Thus, we urge CMS to use its unique ability to generate data from its consumer base, and determine whether CTC is appropriate for people over age 65.
Background information supporting our comments included:
- Studies that showed CTC equivalent to optical colonoscopy in finding large polyps and colorectal cancers with fewer colon perforations and other complications.
- The need to reach additional people who are not now being screened and who might agree to be tested if CTC were covered by Medicare.
- Confusing and conflicting guidelines that don’t provide clear guidance to balance risks and benefits for Medicare patients who are deciding on a screening method.
C3 urges reconsideration of the non-coverage decision by CMS, and strongly urges CMS to gather the evidence by approving coverage of CTC, and implementing the new coverage through a Coverage with Evidence Development (CED) process.