On October 5, 2015 the U.S. Preventive Services Task Force (USPSTF) issued draft recommendations for colorectal cancer screening with the purpose of receiving public input. Below are the official comments from Fight Colorectal Cancer.
October 28, 2015
Dear USPSTF Review Committee:
Fight Colorectal Cancer, along with our Medical Advisory Board, appreciates the opportunity to submit the following comments to USPSTF regarding the Colorectal Cancer Draft Screening Recommendations. Fight Colorectal Cancer (Fight CRC) is the United States’ leading advocacy-focused colorectal cancer nonprofit based in Washington, D.C. We envision victory over colon and rectal cancers. We raise our voice to empower and activate a community of patients, fighters and champions to push for better policies and to support research, education and awareness for all those touched by this disease. We offer support for patients and caregivers. We serve as a resource for advocates, policymakers and medical professionals. Additionally, we lead efforts to increase and improve research of colorectal cancer at all stages and throughout the cancer continuum.
Fight Colorectal Cancer believes in fully disclosing all potential conflicts of interest. As an organization, we have received sponsorships and/or educational grants from companies who have an interest in novel screening methods for colorectal cancer, including: Clinical Genomics; Endochoice; Exact Sciences; Medtronics and Quest Diagnostics. None of these companies, nor any of our corporate supporters, have influenced our comments on this issue.
After review of the recommendations by our Medical Advisory Board, governing board leadership and senior staff, we would like to highlight the following responses regarding the USPSTF draft recommendations:
Regarding sDNA and CT colonography as options on the menu, the USPSTF qualified them with the “alternate” categorization:
- The “alternate” categorization alludes to permission for use of these modalities without truly assigning a status rating. As it stands now, it is unclear how physicians will use these tests and if insurance coverage will be provided to patients who use these “alternative-rated” screening modalities. The USPSTF rating of “A” or “B” sets the standard for usage and reimbursement.
- We agree that with emerging screening technologies there is a need for more data with adequate rigor. We recommend clearly outlining required data endpoints needed for new tests to be considered for “A” or “B” recommendations.
Recommendations on screening age 45-50 and 75 and older:
- In the age group 45-50, we recommend that USPSTF consider populations such as African Americans who have higher incidence of colorectal cancer in the guidelines.
- In the age group 75 and older, the “C” rating is warranted with allowance of co-morbidity management and previous findings.
- Although the data is still emerging, we also request that USPSTF deliberately monitor any forthcoming evidence regarding individuals under the age of 50; recent data suggests marked increase of incidence in this population.
Surveillance and screening guidelines:
- It is recommended that USPSTF further review and consider other established professional guidelines for consistency, including National Comprehensive Cancer Network (NCCN) and American Society of Clinical Oncology (ASCO). These high-risk and surveillance guidelines have been established and should be referenced in the USPSTF guidelines.
Flexible sigmoidoscopy and FIT/FOBT every 10 years:
- This recommendation is guided by limited data. Further evidence is needed before this recommendation is implemented; perhaps review of empirical data vs. modeling studies.
Fight Colorectal Cancer submits the above recommendations for consideration. We underscore that while offering more screening options will potentially allow for greater uptake of screening within the population, the grading recommendation of a USPSTF grade “A” or “B” is necessary for these services to be covered and paid for by insurance. The “alternate” rating allows use of new screening modalities, but adds an element of confusion for providers and patients about the evidence base and how most Americans will truly be able to access these screening modalities.
In an effort to reach the national goal of 80% by 2018, it is critical that the USPSTF update its guidelines to provide quality recommendations and clarity. Currently, we believe the lack of clarity will have practical implications for patients and the physician community. As-is, they will have to weigh the benefits and risks of colorectal cancer screening, adding an unintended barrier.
Thank you for the opportunity to provide comments and listening to our concerns based on our review of these proposed guidelines.
Anjee Davis, President, Fight Colorectal Cancer
Andrea Dwyer, Director of Health Promotion, Fight Colorectal Cancer
Fight Colorectal Cancer has reviewed the USPSTF guidelines thoroughly with our Medical Advisory Board members, governing board leadership and senior staff. These comments are based on ongoing input from stakeholders and review amongst diverse perspectives over a four-week span. The comments are reflective of Fight Colorectal Cancer in its entirety, not a single individual.