National Coverage Analysis (NCA) View Public Comments

Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer

Public Comments

Commenter Comment Information
Goss, Elizabeth Title: Policy Advisor
Organization: Cancer Leadership Council
Date: 11/28/2019
Comment:

November 27, 2019

The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

RE: CAG-00450R — Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer

Dear Administrator Verma:

The undersigned cancer patient, provider, and research organizations are writing to

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Thibault-Sennett, Sarah Organization: Various Patient and Provider Organizations
Date: 11/28/2019
Comment:

November 28, 2019

Seema Verma, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Dear Administrator Verma:

The undersigned organizations represent a diverse and broad community of patient advocates and providers committed to ensuring cancer patients have access to clinically appropriate, high-quality cancer

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Kafka, Peter Organization: Answer Cancer Foundation
Date: 11/28/2019
Comment:

I have some comments on the National Coverage Decision [PHI Redacted] They are as follows:

  • As is usually the case with cancer therapy, most thought goes immediately to women’s issues. In this instance the topic becomes breast cancer and ovarian cancer. Other cancers are lumped into the “other” category. Yet the incidence of prostate cancer in men is right on par with women and breast cancer both in terms of diagnosed cases and deaths. The same genetic

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Branham, JD, Chandra N. Title: VP, Payment & Health Care Delivery Policy
Organization: AdvaMed
Date: 11/28/2019
Comment:

Tamara Syrek Jensen, JD
Director, Coverage & Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop S3-02-01
7500 Security Blvd
Baltimore MD 21244

RE: National Coverage Analysis (NCA) for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

The Advanced Medical Technology Association (AdvaMed) and

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Phillips, Steve Title: Senior Director, Health Policy
Organization: Johnson & Johnson
Date: 11/28/2019
Comment:

November 29, 2019

Tamara Syrek Jensen, J.D.
Director, Coverage & Analysis Group
Centers for Medicare & Medicaid Services
Mailstop S3-02-01
7500 Security Blvd.
Baltimore, MD 21244

Sent electronically

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

On behalf of Johnson & Johnson, I am pleased to offer the

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Scarpelli, Brian Title: Senior Global Policy Counsel
Organization: Connected Health Initiative
Date: 11/28/2019
Comment:

November 29, 2019

Administrative File: CAG-00450R
Tamara Syrek Jensen
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop # S3-02-01
7500 Security Boulevard
Baltimore, Maryland 21244-1850

RE: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

The Connected Health Initiative (CHI) appreciates the opportunity to provide

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Schulze, Matthew Title: Director, Center for Public Policy
Organization: American Society for Clinical Pathology
Date: 11/27/2019
Comment:

November 27, 2019

Ms. Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen:

On behalf of the American Society of Clinical Pathology (ASCP), I am

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Franklin, Elizabeth Title: Executive Director, Cancer Policy Institute
Organization: Cancer Support Community
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop #S3-02-01
7500 Security Boulevard
Baltimore, MD 21244

Re: Reconsideration of the National Coverage Determination on Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

The Cancer Support Community (CSC) appreciates the opportunity to

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Baroni Allmon, Tracy Title: E.D., State Public Policy
Organization: Novartis Pharmaceuticals Corporation
Date: 11/27/2019
Comment:

November 26, 2019

Tamara Syrek Jensen, J.D.
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

BY ELECTRONIC DELIVERY

Re: Proposed Decision Memo for Next Generation Sequencing for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

Novartis appreciates the opportunity to provide comments in response to the

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Rodriguez, Patricia Title: Medical Director
Organization: US Oncology, GREAT Program
Date: 11/27/2019
Comment:

November 27, 2019
Tamara Syrek Jensen Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen,

We appreciate the opportunity to provide feedback on behalf of The US Oncology Network’s

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England, Christine Title: Senior Director
Organization: Memorial Sloan Kettering Cancer Center (MSK)
Date: 11/27/2019
Comment:

Memorial Sloan Kettering Cancer Center (MSK) appreciates the opportunity to offer feedback on the proposed decision memo on Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer, which has been revised to address germline testing. MSK is a National Cancer Institute-designated comprehensive cancer center devoted solely to the research and treatment of cancer. We are committed to advancing clinical care through scientific innovations, including by advancing

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Bens, Cynthia Title: Senior Vice President, Public Policy
Organization: Personalized Medicine Coalition
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, J.D.
Director, Coverage & Analysis Group
Centers for Medicare & Medicaid Services
Mailstop S3-02-01
7500 Security Blvd.
Baltimore, MD 21244

Sent electronically

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

The Personalized Medicine Coalition (PMC), a

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Murphy, Hannah Title: Executive Director
Organization: Coalition for 21st Century Medicine
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: National Coverage Analysis (Reconsideration) for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Director Syrek Jensen:

On behalf of the Coalition for 21st Century Medicine (C21), we appreciate the

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Martin, Sarah Title: Director, Regulatory Science and Policy
Organization: American Association for Cancer Research
Date: 11/27/2019
Comment:

November 28, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop # S3-02-01
7500 Security Boulevard
Baltimore, MD 21244-1850

RE: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

On behalf of the American Association for Cancer Research (AACR), the first and largest scientific

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Isenberg, Jeremy Title: Manager, Health Policy
Organization: BIO
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
U.S. Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Lori Ashby, MA
Director, Division of Policy & Evidence Review
U.S. Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Andrew Ward, PhD
Director, Evidence Development Division
U.S. Centers for Medicare &

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Silverstein, Roy Title: President
Organization: American Society of Hematology
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Reconsideration of the National Coverage Determination on Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-0045OR)

Dear Ms. Jensen,

The American Society of Hematology (ASH) is pleased to provide comments on the Centers

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Sang, Charles Title: SVP, Clinical Diagnostics
Organization: Adaptive Biotechnologies
Date: 11/27/2019
Comment:

November 26, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Director Syrek Jensen:

Adaptive Biotechnologies Corporation (Adaptive) is appreciative of the opportunity to comment on the proposed changes to Section

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Loy, Bryan Title: Corporate Medical Director
Organization: Humana
Date: 11/27/2019
Comment:

We would like to propose the following revisions to the proposed decision memo. Our recommendations are aimed at providing additional clarity.

Recommendation #1
Section I.A. of the proposed decision memo would require that a diagnostic test using NGS include “results provided to the treating physician for management of the patient using a report template to specify treatment options.”

Humana comments: We believe this criterion would benefit from specifying

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Markwood, Priscilla Title: Executive Director
Organization: Association of Pathology Chairs
Date: 11/27/2019
Comment:

RE: National Coverage Analysis (NCA) Tracking Sheet for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Administrator Verma:

The Association of Pathology Chairs represents academic departments of pathology and laboratory medicine in academic medical centers throughout the U.S. and Canada. Our members are committed to providing the best care possible, including high quality, clinically-proven Next Generation Sequencing

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barnhart-hinkle, blair Title: director, government relations
Organization: Cleveland Clinic
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen
Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen:

Cleveland Clinic appreciates the opportunity to provide comments on the proposed

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Allen, Jeff Organization: Friends of Cancer Research
Date: 11/27/2019
Comment:

Jeff Allen, PhD
1800 M Street NW Suite 1050
South Washington, DC 20036

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

November 28, 2019

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

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Carlson, Brantley Title: Director, Policy, US Oncology
Organization: AstraZeneca
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Department of Health and Human Services
P.O. Box 8013
Baltimore, MD 21244–1850

RE: Comments Regarding Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen:

On behalf of AstraZeneca, I am pleased to submit

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Appleberry, Ginger Title: VP - Associate General Counsel
Organization: Caris Life Sciences
Date: 11/27/2019
Comment:

COMMENTS TO CMS PROPOSED NCD FOR BREAST/OVARIAN CANCER NGS TESTING

The Centers for Medicare & Medicaid Services (“CMS”) issued the Proposed Decision Memorandum for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R) (the “Proposed NCD”) on October 29, 2019. As part of the public comment period, we submit the following comment for CMS’s consideration.

Caris MPI, Inc., doing business as Caris Life Sciences (“Caris”), is a pioneer

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Burke, Tara Title: Senior Director of Public Policy and Advocacy
Organization: Association for Molecular Pathology
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: Reconsideration of the National Coverage Determination on Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-0045OR)

Dear Ms. Jensen,

The Association for Molecular Pathology (AMP) is pleased to offer comments on the Centers for

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Norton, Patrick Title: VP of Public Affairs
Organization: University
Date: 11/27/2019
Comment:

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Administrator Verma:

On behalf of the University of Pennsylvania Health System (UPHS), we appreciate the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R).

UPHS is comprised of three

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Schreier, Jeff Title: Senior Director
Organization: Diaceutics
Date: 11/27/2019
Comment:

Ms. Tamara Syrek Jensen
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop #S3-02-01
7500 Security Boulevard
Baltimore, Maryland 21244

November 27, 2019

RE: Reconsideration of the National Coverage Determination on Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Director Syrek Jensen:

We at Diaceutics welcome the opportunity to offer

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Carlson, Robert Title: CEO
Organization: National Comprehensive Cancer Network
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director
Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore MD 21244

RE: National Coverage Analysis (NCA) Tracking Sheet for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen:

The National Comprehensive Cancer Network® (NCCN®) is pleased to comment on the Proposed

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Santiago, Kristen Title: Senior Director of Public Policy Initiatives
Organization: LUNGevity Foundation
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage & Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop S3-02-01
7500 Security Blvd
Baltimore, MD 21244

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek Jensen,

On behalf of LUNGevity Foundation, the nation’s preeminent

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Grenache, PhD, DABCC, David G. Title: President-Elect
Organization: The American Association for Clinical Chemistry (AACC)
Date: 11/27/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services

Subject: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Ms. Jensen:

The American Association for Clinical Chemistry (AACC) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) proposed national coverage

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Nogle, Gregory Title: Director, Market Access
Organization: Ambry Genetics
Date: 11/26/2019
Comment:

Ms. Tamara Syrek Jensen
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop #S3-02-01
7500 Security Boulevard
Baltimore, Maryland 21244

As a leading laboratory providing germline genetic testing services to Medicare beneficiaries, we are writing to summarize our understanding of issues regarding the CMS NCD for Next Generation Sequencing for Medicare Beneficiaries with Advanced Cancer (90.2).[1] Thank you for

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Maddox-Smith, Andrea Title: CEO
Organization: Bladder Cancer Advocacy Network
Date: 11/26/2019
Comment:

November 25, 2019

Mrs. Seema Verma, Administrator
Centers for Medicare and Medicaid Services (CMS)
200 Independence Avenue, SW
Washington, DC 20201

Subject: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R), October 29, 2019.

Dear Administrator Verma,

On behalf of the Bladder Cancer Advocacy Network (BCAN), the only national organization solely devoted to advancing

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Black-Schaffer, MD, W. Stephen Title: Chair, Economic Affairs Committee
Organization: College of American Pathologists
Date: 11/26/2019
Comment:

November 26, 2019

Tamara Syrek Jensen, J.D.
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen,

The College of American Pathologists (CAP) appreciates the opportunity to submit comments on the Proposed Decision Memo

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Schlager, Lisa Title: Vice President, Public Policy
Organization: FORCE: Facing Our Risk of Cancer Empowered
Date: 11/26/2019
Comment:

November 26, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244
Tamara.Syrekjensen@cms.hhs.gov
Kimberly.Long@cms.hhs.gov

Seema Verma
Administrator
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201
Seema.Verma@cms.hhs.gov

RE: Proposed Decision Memo for Next

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George, Sean Title: President & Chief Executive Officer
Organization: Invitae Corporation
Date: 11/26/2019
Comment:

November 28, 2019

Tamara Syrek-Jensen, JD
Director, Coverage and Analysis Group
Centers of Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Syrek-Jensen,

On behalf of Invitae Corporation, we applaud you and your team at the Centers of Medicare & Medicaid

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Alexander, MD, MPH, Brian Title: Chief Medical Officer
Organization: Foundation Medicine, Inc.
Date: 11/26/2019
Comment:

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop # S3-02-01
7500 Security Boulevard
Baltimore, MD 21244-1850

RE: National Coverage Analysis (Reconsideration) for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen:

On behalf of Foundation Medicine, Inc. (“FMI”), the developer of the

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McClure, Michelle Title: Public Policy Director
Organization: American College of Medical Genetics and Genomics
Date: 11/26/2019
Comment:

The American College of Medical Genetics and Genomics (ACMG) welcomes the opportunity to comment on CMS’s Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer. ACMG is the only nationally recognized professional membership organization dedicated to improving health through the practice of medical genetics and genomics. Our membership includes over 2300 genetics professionals, nearly 80% of whom are board-certified clinical and

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Lacasse, Lisa Title: President
Organization: American Cancer Society Cancer Action Network
Date: 11/26/2019
Comment:

November 27, 2019

Tamara Syrek Jensen, JD
Director, Coverage & Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop S3-02-01
7500 Security Blvd
Baltimore, MD 21244

Re: Coverage of NGS tumor panels CAG-00450R

Dear Ms. Jensen:

The American Cancer Society Cancer Action Network (ACS CAN) appreciates the opportunity to comment on the reopened process for a

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Audeh, William Title: Chief Medical Officer
Organization: Agendia, Inc.
Date: 11/25/2019
Comment:

November 25, 2019

###
PUBLIC COMMENT
AGENDIA
Agendia is a leading international developer and manufacturer of molecular diagnostic tests. We appreciate the opportunity to comment on NCD CAG-00450R.
CURRENT STATUS OF NCD:
The NCD currently provides national coverage for FDA-approved combination diagnostics with an on-label indication for patients with advanced cancer. As CMS states, “Medicare’s current coverage of NGS is restricted to patients with a

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Khani, Julie Title: President
Organization: American Clinical Laboratory Association
Date: 11/25/2019
Comment:

November 25, 2019

Ms. Tamara Syrek Jensen
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop #S3-02-01
7500 Security Boulevard
Baltimore, Maryland 21244

Dear Ms. Syrek Jensen,

The American Clinical Laboratory Association submits these comments on the Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Stage Cancer (CAG-00450R).1 ACLA is a

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Quinn, Bruce Title: Principal
Organization: Bruce Quinn Associates
Date: 11/24/2019
Comment:

NCA Restriction to Specifically NGS Evidence Doesn’t Match FDA Approach

For Revision 90.2R1 (CASG 00450R), CMS follows the convention established in NCD 90.2 of using primarily, or only, NGS-based evidence. This is not the approach the FDA uses.

** Background

Sequencing tests of different methods are different than imaging tests of different methods. For example, ultrasound of the liver and CT of the liver both may be used to diagnose liver cancer. However,

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Satterfield, Lisa Title: Senior Director
Organization: American College of Obstetricians and Gynecologists
Date: 11/22/2019
Comment:

November 22, 2019

Tamara Syrek Jensen
Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Decision Memo for Next Generation Sequencing (NGS) for Medicare Beneficiaries with Advanced Cancer (CAG-00450R)

Dear Ms. Jensen,

The American College of Obstetricians and Gynecologists (ACOG),

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Qadan, Ammar Title: Vice President, Global Market Access
Organization: Illumina
Date: 11/20/2019
Comment:

November 18, 2019

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Blvd.
Baltimore, MD 21244

Re: CAG-00450R

Dear Ms. Syrek Jensen,

On behalf of Illumina, a leading developer and manufacturer of next generation sequencing (NGS) tools for both research and clinical use, we appreciate the opportunity to provide comments on the Proposed National Coverage

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Flowers, Michelle Title: President
Organization: Oncology Managers of Florida
Date: 10/30/2019
Comment:
This step for Breast and Ovarian cancer patients will have a tremendously positive effect on treatment decisions for many patients thereby targeting the most effective course of treatment for improved patient outcomes.