National Coverage Analysis (NCA) View Public Comments

Positron Emission Tomography (FDG) for Solid Tumors

Public Comments

Commenter Comment Information
Wahl, Richard Title: Professor of Radiology, Oncology, Nuclear Medicine
Organization: Johns Hopkins University School of Medicine
Date: 02/05/2009
Comment:

I previously stated that the CMS PET policy should be extended to cover all cancers at all stages of the disease. I referred to our data from last years'' SNM meeting in ovarian carcinoma. We have additional data of relevance to the role of PET/CT in ovarian cancer vs serological assessments. These data should help CMS decide to more broadly cover PET/CT in ovarian cancer (as well as other cancers). Javadi, Bristow and Wahl have submitted the following data (in part) for presentation at

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Wahl, Richard Title: Professor of Radiology, Oncology, Nuclear Medicine
Organization: Johns Hopkins University
Date: 02/05/2009
Comment:

I am a radiologist and nuclear medicine physician with a departmental appointment in oncology. On a daily basis I work with my colleagues at Johns Hopkins to solve clinically relevant patient care questions using PET/CT imaging. I also served on the CMS MCAC advisory committee for four years and on the recent CMS advisory panel evaluating evidence for broadening coverage with PET. I have over 20 years experience with oncologic PET and have contributed to the biological understanding of the

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Perry, Mark Title: Medical Director, Diagnostic Services
Organization: Kansas City Cancer Center, LLC
Date: 02/05/2009
Comment:

Dear Centers for Medicare & Medicaid Services:It is with great enthusiasm I applaud two proposed modifications in the PDM as vital steps in the advancement of Medicare PET and PET/CT coverage. The expanded coverage to tumor types not currently covered by Medicare’s current coverage will be especially beneficial for the diagnosis and initial staging of many types of cancer. In addition, condensing the four categories of indications (diagnosis, staging, restaging and therapy monitoring) to

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Segall, George Title: Professor of Radiology
Organization: Stanford University
Date: 02/05/2009
Comment:

I support the proposed decision memorandum for an omnibus approach to PET and PET/CT for Initial Treatment (formerly diagnosis and staging), with specific exclusions for prostate cancer, as well as regional lymph node staging in breast cancer and melanoma.

I urge CMS to modify the proposed decision memorandum for Subsequent Treatment (formerly restaging and monitoring) to include the same omnibus considerations for PET and PET/CT when MR or CT cannot be performed due to the risk of

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Fleckenstein, James Date: 02/05/2009
Comment:

As a Radiologist, I encourage CMS to expand PET and PET/CT coverage to address all cancers for diagnosis, staging and restaging. The proposed structure will help reduce the miscategorization of scans due to semantics. For example, some PET scans are ordered for the initial diagnosis of cancer; however by the time the scan is performed, it may instead be for the purpose of staging the cancer if the biopsy results have since confirmed a diagnosis. Also, many medical oncologists do not see

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Millman, Diane Organization: Association for Freestanding Radiation Oncology Centers
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Mailstop: C1-09-06
7500 Security Blvd.
Baltimore, MD 21244

Re: Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R)

Dear Dr. Phurrough:

The Association for Freestanding Radiation Oncology Centers (AFROC) is delighted to have this

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Dusing, MD, Reginald Organization: University of Kansas Hospital
Date: 02/05/2009
Comment:

Thank you for the opportunity to comment on the Draft National Coverage Decision for Positron Emission Tomography for Solid Tumors. The University of Kansas Hospital in conjunction with the Kansas University Medical Center has participated in the National Oncological PET Registry (NOPR). We have included results of those NOPR Pet Scans along with quotes from ordering physicians as part of our comments below.

COMMENTS:

PROPOSED FRAMEWORK FOR INITIAL VS SUBSEQUENT

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DeMarco, Linda Title: MD
Organization: NYOH
Date: 02/05/2009
Comment:

PET via the registry has been extremely important for my clinical management of pts, restaging in particular. SCLCA post RT often has CT noted fibrosis; PET helps determine underlying active disease. Ovarian and endometrial often recur with subtle disease, especially peritoneal carcinomatosis, which can show up as a vague infiltrate on PET, but not on CT at all and early therapy is important to protect against hospitalization for symptomatic disease. Prostate PET helps with locally

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Rathbun, Jill Organization: Society of Gynecologic Oncologists
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R))

Dear Dr. Phurrough,

Society of Gynecologic Oncologists (SGO) thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to comment on the draft decision

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Smith, Daniel Title: President
Organization: American Cancer Society Cancer Action Network
Date: 02/05/2009
Comment:

February 5, 2009

Charlene M. Frizzera
Acting Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

RE: Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R)

Dear Ms. Frizzera:

On behalf of the American Cancer Society Cancer Action Network (ACS CAN) and its many volunteers and supporters, we respectfully submit the following comments

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Silfen, Eric Title: Sr. Vice President & Chief Medical Officer
Organization: Philips Healthcare
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Mailstop: C1-09-06
7500 Security Blvd.
Baltimore, MD 21244

Re: Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R)

Dear Dr. Phurrough:

Philips Healthcare (Philips) is delighted to have this opportunity to comment on the Proposed Decision

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Kaplan, Karen Title: Chief Executive Officer
Organization: Ovarian Cancer National Alliance
Date: 02/05/2009
Comment:

Steve Phurrough, MD, MPA
Director
Coverage and Analysis Group
Centers for Medicare & Medicaid
7500 Security Blvd, Mail Stop
Baltimore, MD 21244 C1-09-06

Re: Proposed Decision Memo for Positron EmissionTomography (FDG) for Solid Tumors (CAG 00181R)

Dear Dr. Phurrough:

The Ovarian Cancer National Alliances writes toyou regarding the proposed decision memo forFDG-PET imaging (PET scans). The memo proposesallowing most cancer patients one PET scan

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Williams, Bonnie Title: Research Nuclear Medicine Technologist Coordinator
Organization: The Ohio State University Medical Center
Date: 02/05/2009
Comment:

The national NOPR results of 33% for change in patient management was a very low percentage, that our site was surprised about. Our site was expecting a 70-80% in change in patient management from results from the NOPR PET scans. We did not enter prostate as an initial indication, which may have brought this (33%) nationale NOPR average down. Over utilization of imaging modalities is a concern for our patients, but our NOPR PET scan patients have told us that we are saving them costs of

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Schultz, Elizabeth Title: System Manager, Regulatory Affairs
Organization: Providence Health & Services
Date: 02/05/2009
Comment:

On behalf of Providence Health & Services (Providence), thank you for the opportunity to provide our comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed revision of the National Coverage Determination Manual that would replace the four-part diagnosis, staging, restaging, and monitoring response to treatment categories. The new framework would consist of two parts that differentiate FDG PET imaging used to inform the initial treatment strategy from other

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Bailes, MD, Joseph S. Title: Chair
Organization: ASCO Government Relations Council
Date: 02/05/2009
Comment:

February 5, 2009

Via Electronic Mail to CAGinquiries@cms.hhs.gov

Steve E. Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, Maryland 21244

Re: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R)

On behalf of the American Society of Clinical Oncology (ASCO), I am

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Gordon Don, Megan Title: Director of Government Affairs
Organization: Pancreatic Cancer Action Network
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Positron Emission Tomography (FOG) for Solid Tumors (CAG-00181R)

Dear Dr. Phurrough,

The Pancreatic Cancer Action Network thanks the Centers for Medicare & Medicaid Services (CMS) for the oppottunity to comment on the draft decision

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Guastella, Michael Title: Co-Chair
Organization: CORAR Health Policy Committee
Date: 02/05/2009
Comment:

September 19, 2012

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid
7500 Security Blvd., Mail Stop C1-09-06
Baltimore, MD 21244

Re: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG 00181R)

Dear Dr. Phurrough:

On behalf of the Council on Radionuclides and Radiopharmaceuticals (CORAR), we are pleased to submit comments to the Centers for Medicare &

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Schuman, Ilyse Organization: The Medical Imaging and Technology Alliance (MITA)
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Mailstop: C1-09-06
7500 Security Blvd.
Baltimore, MD  21244

Re:      Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R)

Dear Dr. Phurrough:

The Medical Imaging and Technology Alliance (MITA), a division of the

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Zettel, Hugh Title: Strategic Reimbursement Executive
Organization: GE Healthcare
Date: 02/05/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director
Coverage and Analysis Group
Centers for Medicare & Medicaid
7500 Security Blvd, Mail Stop
Baltimore, MD 21244 C1-09-06

Re: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG 00181R)

Dear Dr. Phurrough:

GE Healthcare (GEHC) appreciates this opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) proposed decision

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Beitsch MD, FACS, Peter Organization: Dallas Surgical Group
Date: 02/04/2009
Comment:

To Whom it May Concern,

I have recently learned about the proposed changes in Medicare coverage for PET/CT scans. I am pleased that CMS has recognized the significant contribution of PET/CT for appropriately staging patients at the onset of treatment. I feel strongly that this decision to expand coverage to all solid tumor types will allow surgeons to better evaluate our cancer patients by clarifying the extent of disease and identifying the most appropriate surgical candidates.

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Belcheva, Dr. Anna Title: medical oncologist
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Bhuriwala, Dr Title: medical oncologist
Organization: Houston Cancer Clinics
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PETICT scans. I firmly agree that the coverage of PETICT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PETICT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Bocchino, Carmella Title: EVP, Clinical Affairs and Strategic Planning
Organization: America's Health Insurance Plans (AHIP)
Date: 02/04/2009
Comment:

February 5, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Dear Dr. Phurrough:

Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services' (CMS's) proposed national coverage decision (NCD), Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R).

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Carpenter, MD, L. Steven Title: Radiation Oncologist
Organization: St. Luke's Cancer Center
Date: 02/04/2009
Comment:

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent ofthe disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction. However, from my

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Clouse, Dennis Title: PACS Sales Specialist
Organization: Philips Healthcare Informatics
Date: 02/04/2009
Comment:

From 2001 - 2006, I sold PET and PET/CT systems to hospitals and oncology centers. I'm aware that CMS has used a deliberate process in approving reimbursement of PET imaging, balancing the clinical benefit and the cost. This all became very personal for me last year (2008). [PHI Redacted] started having abdominal pain last Spring. He was 70 years old, retired, and under Medicare health insurance. His physician proceeded with a series of diagnostic tests including

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Cook, MD, Deborah R. Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my experience

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Jumean MD, George Title: Medical Oncologist
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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JUVVADI. M.D., SRIDEVI Title: Medical Oncologist
Organization: CLINICAL ONCOLOGY AND HEMATOLOGY
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT. MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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KHOURY, M.D., PIERRE N. Title: Medical Oncology
Organization: Houston Cancer Clinics
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PETICT scans. I firmly agree that the coverage of PETICT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PETICT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my experience

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Lilly MD, Scott Title: Medical Oncologist
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my experience

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Linden, MD, FACP, Hannah Title: Associtate Pofessor, Medicine, Onocology
Organization: University of Washington
Date: 02/04/2009
Comment:

Dear CMS Administrators,

I am writing to express my gratitude that expansion of coverage for PET FDG in medical oncology is occurring and express concern that we have limitations in the clinical use of PET FDG in breast cancer. I am a practicing medical oncologist, a breast researcher and an Associate Professor, at an academic institution (University of Washington, Seattle Cancer Care Alliance, Fred Hutchison Cancer Research Center, and Harborview Medical Center). As we know PET

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Middleton , MD, Mike Title: Past President
Organization: American College of Nuclear Physicians 2006-07
Date: 02/04/2009
Comment:

Dear Sirs-

As a Nuclear Physician that utilizes this PET/CT imaging technique daily, I think I can speak to the efficacy of PET in managing the cancers listed in the document. PET should have broader coverage to include these types listed as well as others.

We think that if utilized appropriately PET can provide cost savings by upgrading staging, thereby reducing unneccesary surgeries, and other diagnostic tests. More appropriate diagnostic initial staging and restaging

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PERKINS, M.D., STEVE Title: Medical Oncologist
Organization: CLINICAL ONCOLOGY AND HEMATOLOGY
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT. MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Perkins, MD, Patrick J. Title: Department of Radiology & Nuclear Medicine
Organization: Alta Bates Summit Medical Center
Date: 02/04/2009
Comment:
  1. Should the current framework for evaluating the use of FDG PET imaging be modified as proposed?

  2. Yes, but even better to expand coverage for both initial treatment evaluation and subsequent treatment evaluation for all cancers, thus giving physicians the same latitude in use of PET that they have with CT and MRI.
  3. Does the evidence support the broad expansion of coverage of FDG PET imaging to all solid tumors when determining initial treatment strategy?

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Phan, Dr C Title: radiation oncologist
Organization: NORTHWOOOS CANCER CENTER
Date: 02/04/2009
Comment:

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent of the disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction. However, from my perspective,

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Phan, Dr T Title: radiation oncologist
Organization: Memorial Hermann
Date: 02/04/2009
Comment:

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent of the disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction. However, from my

More

Ramshesh, MD, Priya Title: medical oncologist
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Ranzini, MD, FACS, Joseph L. Date: 02/04/2009
Comment:

As a surgeon who cares for oncologic patients, the evolving use of PET and especially PET-CT has added an extraordinary new diagnostic dimension to my ability to care for patients with cancers in a variety of organ systems.

We are long since beyond the time when PET started as a novel way to image patients with solid organ tissue tumors. PET and PET-CT techniques have become vitally important to the accurate diagnosis, staging, restaging, and long term monitoring of oncologic

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Reddy, Dr. Title: medical oncologist
Organization: TEXAS ONCOLOGY - Garland
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Rimawi, M.D., Mothaffar F. Title: Assistant Professor of Medicine
Organization: Lester & Sue Smith Breast Center and Dan L. Duncan Cancer Center
Date: 02/04/2009
Comment:

To Whom It May Concern:

Thank you for receiving my feedback regarding the proposed expansions of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Scott, MD, Miho Toi Title: medical oncologist
Organization: Cancer Center of the Rockies
Date: 02/04/2009
Comment:

February 5, 2009

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients'

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Sethi, Dr. Gurdeep Title: medical oncologist
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PET/CT scans. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my experience

More

Seymour MD, Gregory Title: medical oncologist
Organization: Houston Cancer Clinics
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PETICT scans. I firmly agree that the coverage of PETICT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PETICT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

More

Shadle, Dr. Kathleen Title: radiation oncologist
Date: 02/04/2009
Comment:

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent of the disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction. However, from my

More

Simpson, MD, C. Kelley Title: Radiation Oncologist
Organization: POUDRE VALLEY RADIATION ONCOLOGY, L.L.C.
Date: 02/04/2009
Comment:

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent of the disease and determining an appropriate' course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction, However, from my

More

Suki M.D., Samer Title: medical oncologist
Organization: Houston Cancer Clinics
Date: 02/04/2009
Comment:

To whom it may concern:

Thank you for receiving my feedback regarding the proposed expansion of coverage for oncologic PETICT scans. I firmly agree that the coverage of PETICT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PETICT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans fail to provide adequate information regarding my patients' conditions. As my

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Waxman, A Date: 02/04/2009
Comment:

I am at the Cedars Sinai Medical center in Los Angeles California. I serve as director of nuclear Medicine and Co-Chairman of imaaging.

I am in favor of expanding the indications for PET CT. The NOPR data clearly demonstrated the need for expanded indications for PET/CT imaging. We have found that limiting PET indications encourages physicians to order inferior testing modalities and will delay diagnosis with actual added expense in the long run. Pet CT for multiple tumor

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Mountz, James Title: Chief of Nuclear Medicine
Organization: University of Pittsburgh Medical Center
Date: 02/04/2009
Comment:

There is a vital need to develop quantitative assessment methods of cancer therapy response. CT and standard MRI cannot provide information on the molecular, biochemical and physiologic properties of cancer tissues. Therefore, quantitative imaging techniques and protocols are needed to reveal biomarkers of molecular events induced by cancer therapy. In particular, early imaging of molecularly targeted pathways predicted to be essential for effective cancer therapy is highly likely to play a

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Meko, Jennifer Title: Western Region Medical Director
Organization: MedSolutions, Inc.
Date: 02/04/2009
Comment:
FROM: Gregg P. Allen, M.D.
Chief Medical Officer,
MedSolutions, Inc.
Jennifer Meko, MD
Western Region Medical Director,
MedSolutions, Inc.
Daniel Garner, MD
Associate Medical Director,
MedSolutions, Inc.

DATE: February 4, 2009

RE: Comments to CMS on the Proposed Decision Memo for Position Emission Tomography (FDG) for Solid Tumors (CAG 00181R)

MedSolutions, Inc. performs medical necessity review of PET and PET/CT (collectively

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Fenton Ambrose, Laurie Title: President and CEO
Organization: Lung Cancer Alliance
Date: 02/04/2009
Comment:

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R))

Dear Dr. Phurrough,

Lung Cancer Alliance (LCA) appreciates the opportunity to comment on the draft decision memo on Medicare Coverage of Positron Emission Tomography. Coverage determinations are difficult and

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SPRINGETT, GREGORY Title: ASSISTANT PROFESSOR
Organization: H. LEE MOFFITT CANCER CENTER
Date: 02/04/2009
Comment:

February 4, 2009

To Centers for Medicare and Medicaid services Re: the NOPR program for coverage of PET/CT under Medicare

Dear Sir/Madam:

The H. Lee Moffitt Cancer Center has been a participant in the Medicare NOPR program for coverage of PET/CT scans since its inception. Over 250 patients at Moffitt cancer center have participated in this program. In particular 231 of patient’s with pancreatic cancer from the Moffitt gastrointestinal oncology program have benefited from this

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Pracht, Laurel Title: Survivor, Patient Advocate
Organization: Southwest Oncology Group
Date: 02/04/2009
Comment:

CMS has been presented with compelling evidence of the efficacy of FDG-PET scan. Not including broad coverage for these cancer indications in NOPR''s request still leaves PET scans out of reach for many patients. Remember, patients do not have time on his/her side! Coverage for response to treatment improves patient care PLUS assurance healthcare dollars are used wisely.

Your careful reconsideration including the request as submitted is in the best interest of the

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Hoda, Daanish Date: 02/04/2009
Comment:

I have seen on multiple occasions PET/CT providing valuable information with regards to diagnosis and staging of multiple solid tumors. There have been times that PET scan identifies patients who otherwise have gone to surgery and it has identified patients who may not have been surgical candidates. It provides more early detection at times than regular CT scans. It is very important for medicare to continue allowing these in all solid tumors.

Olds, Tia Title: Radiation Oncologist
Organization: New York Oncology Hematology
Date: 02/04/2009
Comment:

PET scans are invaluable in my practice is a radiation oncologist. Radiation therapy is dependent upon not only accurate radiographic anatomic detail but functional imaging such as PET scans. Without functional imaging, it is nearly impossible to detect scar deposition versus recurrent disease particularly in the setting of pancreatic cancer in which multiple bouts of pancreatitis are antecedent. In situations where patients have received prior chemotherapy and are referred for salvage

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Anderson, Jr., MS, RPh, Ernest Title: President
Organization: Association of Community Cancer Centers (ACCC)
Date: 02/04/2009
Comment:

February 4, 2009

BY ELECTRONIC DELIVERY

Steve Phurroug Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Mail Stop C1-09-06
Baltimore, Maryland 21244

Re: Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R).

Dear Dr. Phurrough:

The Association of Community Cancer Centers (ACCC) appreciates this

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Ambrose, Laurie Fenton Title: President and CEO
Organization: LUNG CANCER ALLIANCE
Date: 02/03/2009
Comment:

February 4, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Positron Emission Tomography (FOG) for Solid Tumors (CAG-00181R)

Dear Dr. Phurrough,

Lung Cancer Alliance (LCA) appreciates the opportunity to comment on the draft decision memo on Medicare Coverage of Positron Emission Tomography. Coverage

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Griffeth, M.D., Ph.D., Landis K. Organization: US Oncology
Date: 02/03/2009
Comment:

February 4, 2009

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Proposed Decision Memorandum for Positron Emission Tomography (FDG) for Solid Tumors (CAG 00181R)

Dear Dr. Phurrough:

US Oncology, headquartered in Houston, Texas, is one of the nation's foremost cancer treatment and research networks. US Oncology provides extensive

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KOSTAKOGLU, LALE Title: Professor of Radiology
Organization: Mount SInai School of Medicine
Date: 02/03/2009
Comment:

I''m deeply disappointed to see that more data should be obtained for expansion of PET coverage in many cancer types, particularly particularly for cancers for which there are few diagnostic options to aid the physician in developing a course of treatment or in monitoring recurrence and follow-up treatment, including, the following.

Ovarian cancer, pancreatic cancer, lung cancer: according to NOPR data, change in management occurs in ~ 40% for staging,restaging, and for suspected

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Gere, Maxine Title: Program Manager
Organization: Blue Cross and Blue Shield Associaition
Date: 02/03/2009
Comment:

The Blue Cross and Blue Shield Association (BCBSA), an association of 39 independent Blue Cross and Blue Shield Plans that collectively provide health insurance benefits to 102 million Americans, appreciates the opportunity to comment on the national coverage determination proposed by the Centers for Medicare and Medicaid Services (CMS) to expand coverage for initial diagnostic testing with positron emission tomography (PET) for many Medicare beneficiaries who are being treated for

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Hillner, Bruce Title: Chair
Organization: National Oncologic PET Registry (NOPR) Working Group
Date: 02/03/2009
Comment:

Dear Dr. Phurrough:

We are writing in response to the Centers for Medicare & Medicaid Services’ (CMS) request for comments on its proposed decision memorandum revising the current coverage determinations for oncologic FDG-PET imaging.

This letter is submitted jointly on behalf of the National Oncologic PET Registry (NOPR) Investigators, the American College of Radiology (ACR), the Academy of Molecular Imaging (AMI), the American Society for Radiation Oncology (ASTRO), the

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Dahlin, Dr. John Title: Dr.
Organization: Marquette General Hospital- Nuclear Medicine
Date: 02/03/2009
Comment:

As a Nuclear Medicine physician, whose primary professional responsibility is reading PET scans, I can tell you from experience how vital they are. They not only are one of the best (if not THE best in circumstances) evaluation tool we have, for the reimbursable indications, but I have also found many other "incidental" findings and tumors, which would not have been found otherwise. This has lead to a multidisciplinary approach to patients, to erradicate their malignancies; having lead to

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Kibel, Adam Date: 02/03/2009
Comment:

To whom it may concern,

As a urologist practicing at a National Cancer Institute Comprehensive Cancer Center, I applaud CMS’ intent to provide expanded coverage for PET for initial evaluation of many cancers that previously were covered under a coverage with evidence development program, by inclusion in the National Oncologic PET Registry. I further encourage CMS to ensure that there is no gap in coverage for subsequent treatment evaluations of these cancers, and to find a pathway

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Camacho, Dr. Luis Title: Director
Organization: Department of Research, Houston Medical Center
Date: 02/02/2009
Comment:

Houston, February 3, 2009

Dear Sir or Madam:

I would like to submit my feedback regarding the proposed expansion of coverage for PET/CT scans in cancer patients. I firmly agree that the coverage of PET/CT scans ought to extend to all tumor types in the initial treatment period. As a medical oncologist, I routinely use PET/CT scans in my practice, especially when conventional imaging modalities such as CT, MRI and bone scans frequently fail to provide adequate information

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Gardner MD, Barry L. Title: Radiation Oncologist
Organization: St. Anthony Regional Mountain Cancer Center
Date: 02/02/2009
Comment:

Feb. 3, 2009

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent ofthe disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction.

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Schewe MD, Kevin L. Title: Radiation Oncologist
Organization: St. Anthony Regional Mountain Cancer Center
Date: 02/02/2009
Comment:

Feb. 3, 2009

To Whom it May Concern:

Re: PET/CT Coverage

As a Radiation Oncologist, I find that PET/CT is a vitally important tool for radiation treatment planning. The initial staging scans are critical for defining the true extent of the disease and determining an appropriate course of action. I fully support CMS' assessment that PET/CT scans should be covered in the initial treatment of all solid tumors and am pleased at this step in the right direction.

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Kalnicki, Shalom Title: Chairman, Radiation Oncology
Organization: Montefiore Medical Center
Date: 02/02/2009
Comment:

As a Radiation Oncologist who has been using PET CT fusion for treatment planning since 2000 and co-authored peer reviewed publications on the subject I would like to submit my support to the use of functional imaging in the diagnosis and treatment of solid tumors. It adds significant information to anatomical diagnosis, spares local therapies to patients who have disseminated disease and provides invaluable prognositic and therapeutic evaluation data, eliminating unnecessary biopsies and

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Durie, MD, Brian Title: Chairman of the Board
Organization: International Myeloma Foundation
Date: 02/02/2009
Comment:

Steve Phurrough, MD, MPA
Director, Coverage and Analysis Group
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG-00181R))

Dear Dr. Phurrough,

International Myeloma Foundation thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to comment on the draft decision memorandum on Medicare coverage of Positron

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Paul, Diane Date: 02/02/2009
Comment:

For 15 years I have seen women and their doctors wrestle with making decisions about treatment for recurrent ovarian cancer. Rising ca125s were often used for determining the resumption of cytotoxic treatment because often recurrent ovarian cancer resembles grains of sand which are not big enough to pick up on a CT scan. About 10 years ago PET scans became available, but while they were better about picking up smaller lesions, there was too much "noise". Recently the PET/CT has been

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Bartel, Twyla Organization: Myeloma Institute for Research and Therapy
Date: 01/30/2009
Comment:

I am emailing our Myeloma Institute''s comments on this topic in reference to our experience and recommendations for use of FDG-PET/CT in myeloma patients and others with plasma cell dyscrasias.

VAN GEFFEN, JACK Title: Director
Organization: Nuclear Medicine
Date: 01/30/2009
Comment:

To: CMS Re: Proposed Decision Memo for PET for Solid Tumors

At Anne Arundel Medical Center in Annapolis, Maryland, we have participated fully with the National Oncologic PET Registry, and I would like to offer a comment on the proposed CMS decision memo for Positron Emission Tomography for Solid Tumors (CAG-00181R).

During the course of the trial, we performed approximately 200 PET/CT examinations under the NOPR. These cases were associated with a total of 52 diagnostic

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Northcutt, David Title: Business Development Specialist
Organization: DMS Health Technologies
Date: 01/30/2009
Comment:

I agree completely with your decision to change the framework combining Diagnosis and Initial Staging into one category while combining Restaging and Therapy Monitoring into another. A very good decision.

I agree completely with the expansion of coverage in Initial Treatment Strategy to virtually all solid tumors (with the four noted exceptions).

I do, however, strongly disagree with the decision to not expand the use of PET in Subsequent Treatment Strategy beyond the nine cancers

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Gress, Karen Title: V.P. of Ancillary & Support Services
Organization: St. Margaret''s Health
Date: 01/30/2009
Comment:

After reading your policy I have very happy that you are planning on lifting the CED requirements to allow Medicare coverage of one PET scan to guide the initial treatment of cancer patients. [PHI Redacted]

I would like you to consider the need for a mechanism to proide coverage for multiple inital treatment studies on patients undergoing radiation therapy.

I feel it is important to avoid a cerage gap after the finalization of the NCD to ensure continued

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Whitlock, Gary Title: Imaging Director
Organization: Mercy Regional Health Center
Date: 01/29/2009
Comment:

I agree completely with your decision to change the framework combining Diagnosis and Initial Staging into one category while combining Restaging and Therapy Monitoring into another. A very good decision.

I agree completely with the expansion of coverage in Initial Treatment Strategy to virtually all solid tumors (with the four noted exceptions).

I do, however, strongly disagree with the decision to not expand the use of PET in Subsequent Treatment Strategy beyond the nine cancers

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Tedesco, Karen Title: Physician- medical oncology and hematology
Organization: New York Oncology Hematology
Date: 01/29/2009
Comment:

Thank you for the proposed expansion of PET coverage for many types of malignancies. I would like to see further coverage for restaging and therapy monitoring for patients with testicular, small cell lung, pancreatic, esophageal, and ovarian cancer. For metastatic testis cancer, current standards of care mandate surgical resection of residual disease after initial therapy, which is often technically difficult, potentially dangerous, and costly. For the other diagnoses as well PET for

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Yu, Michael Title: Director of Nuclear Medicine and PET Service
Organization: Fox Chase Cancer Center
Date: 01/29/2009
Comment:

As a nuclear medicine physician working in one of the National Comprehensive Cancer Network institutions, I have seen so many patients benefit from PET studies. And also seen the difficulties to get approval for non covered cancer indications.

NOPR provided a great pathway for people to get the scan and change their management. I fully support the CMS proposed expansion for coverage, and would like to see the continuation of NOPR for non covered cancers to provide essential service

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Simon, George Title: Director, Thoracic Oncology
Organization: Fox Chase Cancer Center
Date: 01/29/2009
Comment:

In principle, PET Scans are a vital and efficient tool in the diagnosis, staging and follow up management of Thoracic Malignancies. I think PET Scans are a useful tool in assessing response to treatment in patients with NSCLC both in stage IV disease and in stage III disease after treatment with chemotherapy and radiation therapy. In Stage III disease, after definitive chemotherapy and radiation therapy often there is a residual mass. PET Scan is a useful tool to help differentiate this

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Mankoff, David Title: Professor
Organization: University of Washington and SCCA
Date: 01/28/2009
Comment:

Thank you for the opportunity to comment on the proposed CMS coverage rules for PET. As highlighted in my August 2008 presentation to CMS, NOPR data and a number of other publications cited in the presentation strongly support the utility of PET for staging in the cancers that were included in the NOPR. I therefore strongly support the CMS decision to provide coverage for FDG PET/CT for initial treatment evaluation. I would also like to add that the NOPR data and cited publications also

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Resta, Regina Title: Physician
Organization: NYOH Troy
Date: 01/28/2009
Comment:

I want to share some comments on the value of PET scans in caring for my patients with cancer.

I take care of a 72 yo gentleman who presented with an undifferentiated cancer in his lung. CT scans, bone scan and brain MRI were negative for disease outside the lung. He was scheduled for mediastinoscopy and possible lobectomy, but we arranged a PET scan first. This revealed suspicious uptake in multiple abdominal lymph nodes and a high neck node, not seen on CT scans. Biopsy has confirmed

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Arington, Lisa Title: President & CEO
Organization: Northern Shared Medical Services
Date: 01/27/2009
Comment:

January 27, 2009

Steve Phurrough, MD, MPA
Director
Coverage and Analysis Group
Centers for Medicare & Medicaid
7500 Security Blvd, Mail Stop
Baltimore, MD 21244
C1-09-06

Re: Proposed Decision Memo for Positron Emission Tomography (FDG) for Solid Tumors (CAG 00181R)

Dear Dr. Phurrough:

We are writing in response to the Centers for Medicare & Medicaid Services’ (CMS) request for comments on its proposed decision memorandum revising the

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Adkins, M.D., Douglas Title: Associate Professor
Organization: Washington University/Siteman Comprehensive Cancer Center
Date: 01/27/2009
Comment:

As a medical oncologist at Siteman Comprehensive Cancer Center at Washington University in St Louis, I see 100 new patients with sarcoma yearly, and provide long term care for many more. In my experience, PET scans frequently provided important information about disease extent and about tumor response to chemotherapy or targeted therapy. The information provided by PET scans commonly added to that of CT scans, and in my experience changed the treatment plan in approximately 30% of patients.

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Lane, Aaron Date: 01/26/2009
Comment:

As a technologist that has performed scores of NOPR scans, I can say that I honestly know that PET/CT has affected the treatment outcome on a great number of patients covered by NOPR. I strongly recommend covering most, if not all, indications for oncology PET/CT.

Grigsby, Perry Title: Professor of Radiation Oncology and Radiology
Organization: Washington University School of Medicine
Date: 01/26/2009
Comment:

findings of restaging PET performed approximately 3 months after completion of chemoradiation therapy are strongly predictive of clinical outcome. CT nearly always show partial response in the primary tumor and regional nodes early after chemoradiation therapy, but is insensitive for detecting residual disease. Also well known is how difficult it is to assess for residual or recurrent disease by physical examination, cytopathology, or biopsy during the first few months after

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Czernin, Johannes Title: Professor
Organization: David Geffen School of Medicine at UCLA
Date: 01/26/2009
Comment:

TEMPLATE MESSAGE

To Whom it May Concern:
On January 6, the Centers for Medicare and Medicaid Services (CMS) announced its proposed National Coverage Determination (NCD) for oncologic PET, in response to the request from the National Oncologic PET Registry (NOPR) that CMS reconsider the current National Coverage decision on FDG-PET and to end the data collection requirements for diagnosis, staging and restaging for all cancers.

In brief, CMS is proposing to provide

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Schneider, Dr. Paul Title: Nuclear Rdaiologist
Organization: Radiology Consultants of Iowa
Date: 01/24/2009
Comment:

I am respectfully requesting consideration for utilizing FDG-PET imaging as an initial staging tool for all types of solid cancers. Tumor avidity for FDG radiotracer is often unpredictable (esp. prostate CA). If a tumor''s avidity for FDG can be confirmed, PET may be useful for both initial staging and assessing treatment response.

Sirott, Matthew Title: President and Attending physician
Organization: Diablo Valley Oncology
Date: 01/23/2009
Comment:

As a medical oncologist, Pet is the most useful diagnostic modality and should be readily available for all solid tumors and multiple myeloma. The CED restrictions for follow-up do not make any sense. THe PET often shows that patients are or are not responding to therapy and often do not correlate with CT or the CT scan cannot determine. Some patients may continue on therapy because their disease is only evaluable by PET, and they are actually not responding. OThers can appear progressive

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Tricot, Guido Title: MD, PhD, Professor of Medicine
Organization: University of Utah School of Medicine
Date: 01/23/2009
Comment:

I am a myeloma specialist and have been treting myeloma patients for the last 16 years. I see more than 200 new myeloma patients each year. Our goal is to cure this disease. Our extensive experience on > 10,000 myeloma patients has told us that the two most important prognostic markers are genetic information as obtained by cytogenetics and gene expression profiling, and extend of disease as assesssed by MRI and PET/CT scan. Skeletal surveys as typically recommended for myeloma are outdated

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Carol, Mark Title: Chief Medical Officer
Organization: Alliance Imaging
Date: 01/22/2009
Comment:

On behalf of Alliance Imaging, the largest provider of PET services in the nation, we appreciate the opportunity to comment on CMS’s proposed decision memorandum regarding the expansion of PET coverage for purposes of initial and subsequent treatment strategies for certain designated solid tumors. While we believe the approach outlined in the proposed decision memorandum is a step in the right direction, in our view it does not go far enough. As stated in our comments submitted on October

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Wright, Kelly Date: 01/22/2009
Comment:

PUBLIC COMMENT

I understand that CMS is proposing to provide coverage for the initial treatment evaluation (currently called diagnosis and initial staging) for all cancers, except for prostate cancer and those indications that are already explicitly non-covered (breast cancer diagnosis and axillary nodal staging, and melanoma regional nodal staging). CMS also will cover subsequent treatment evaluation (including what is now considered treatment planning and restaging) for non-small cell

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Ceplecha, Tracey Title: PACS Administrator - formally a Nuc Med Tech
Organization: Ridgeview Medical Center
Date: 01/22/2009
Comment:

I strongly agree with the proposed changes. I really like the 2 stage framework - I think this will help minimize confusion for the doctor, scheduler, and biller. I greatly agree with the added coverages. I have spoke with oncologist that felt strong about pancreas coverage for PET scanning and that the PET scan results did alter treatment decisions. I would like to see CMS - cover the CED as well someday. I think if there is strong clinical evidence to proceed it should be covered.

HEARNE, MICHAEL Date: 01/22/2009
Comment:

we need to open these cancers so that patients can get the care they need without needless jumping through hoops.

eilber, fritz Date: 01/22/2009
Comment:

FDG-PET is often very important in the treatment of sarcoma patients, particularly in the setting of extent of disease evaluation and monitoring response to therapy, as it is in other malignancies. Unfortunately is it predominantly not covered for these patients. I feel strongly that it should be and is an example of a rare malignancy not receiving comparable care to other malignancies because it is not a prevalent.

Wright-Browne, Vance Title: Oncologist
Organization: Florida Cancer Specialists
Date: 01/21/2009
Comment:

Am encouraged by the decision to expand coverage for initial staging, and subsequent treatment. Would urge further study of role of PET in following up indeterminate CT masses post treatment, and their utility in diagnosing relapse and changing outcomes in potentially curable situations ( eg lymphoma or locally recurrent Non small cell lung cancer.

Reddy, Sashidhar Date: 01/21/2009
Comment:

I fully support the expanded use of PET scanning for solid and lymphoid tumors. In my private practice, I find PET imaging very useful in determing what is active cancer and what is not. I find it helps save time and other unnecessary testing in working up things that are or are not cancer. Finally, I think PET imaging is useful in follow up imaging. This give me a much better idea if my treatment is working

Sink, Kim Date: 01/21/2009
Comment:

I feel strongly about these key points: PET led to a change in the initial treatment approach in over one-third of all cases in which it was employed.

Recognize the limitations of the NOPR data in linking the use of PET to patients'' long-term clinical outcomes

Consider supporting CMS'' proposed decision to lift the CED requirements to allow Medicare coverage of one PET scan to guide the "initial treatment strategy" for cancer patients with a confirmed or strongly

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Livingston, Robert Title: Professor
Organization: Arizona Cancer Center
Date: 01/21/2009
Comment:

CMS Approvals for PET in Breast Cancer

To whom it may concern:

I am a Professor of Medicine at the University of Arizona, specializing in the treatment of breast cancer. I am the former Chair of the Breast Committee of the Southwest Oncology Group, and remain a member of its Working Group.

From my perspective as a medical oncologist, the greatest single use for FDG-PET at present is in the serial evaluation of response. The best example may be in the situation of

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Hughes, Dennis Title: Assistant Professor of Pediatrics
Organization: The Children''s Cancer Hospital at M. D. Anderson Cancer Center
Date: 01/20/2009
Comment:

I would strongly encourage the continued use of PET/CT data for evaluation of treatment effects, especially in the setting of rare tumors and recurrent or refractory disease, where it will be much harder to have all uses of PET confined within a prospective trial design. Our institution treats about 10% of the US patients with relapsed osteosarcoma, but that still amounts to fewer than 150 patients each year. Treatment must be individualized to obtain best results. By using PET data I

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YOUMAN, MD, JOSEPH Title: PHYSICIAN
Organization: TEXAS ONCOLOGY
Date: 01/16/2009
Comment:

PET/CT imaging has CHANGED the practice of oncology. In Hodgkins Dz and NHL we scan after 1 or 2 doses and know whether we will get a remission/cure. If still + then we consider high dose therapy without wasting $ on chemo cycles that will not be curative!

The PET/CT is invaluable in melanoma since many sites will not be seen on CT/MRI. PET/CT changes management of NSCLC, upstaging patients at diagnosis - saving $$ for unnecessary surgery =/or RoRx. It is much more sensitive for

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Pracht, Laurel Title: Patient Advocate
Organization: Southwest Oncology Group, Gynecologic Committee
Date: 01/08/2009
Comment:

Please note, not incuding subsequent treatment use of PET for ovarian cancer through expansion of broader coverage will revert patients to a lesser standard of care. For those with CT negative, CA-125 negative and PET scan positive disease, broad coverage of PET scan is vital. Sincerely, Laurel Pracht

Berg, Jonathan Title: Nuclear Medicine / PET Coordinator
Organization: Austin Radiological Association
Date: 01/08/2009
Comment:

As a technical coordinator and registered PET technologist, I personally witness every day how PET results in a much higher degree of accuracy than is achieved by anatomic imaging alone. PET has and continues to have a profound impact on patient care. Yet, the regulatory requirements for a study to be performed are set at a higher standard than for anatomic imaging techniques. Please, allow PET to be used in the same manner and with the same ease as is currently allowed for other modalities

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Davies, Diane Title: Mom, Wife, Daughter
Organization: Human Race
Date: 01/07/2009
Comment:

The decision as to what tests and treatments for a disease such as cancer should be left to the professionals - meaning the doctors. Maybe you need to fine-tune this policy. There is a difference between Non-invasive and Invasive cancer. If you don''t know the difference, you should educated yourselves on this topic. Preliminary scans and biopsies can usually determine which. ANYONE WITH AN INVASIVE CANCER SHOULD HAVE WHATEVER TESTS THE DOCTOR/S DECIDE IS USEFUL FOR PROPER DIAGNOSIS.

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goss, victoria Date: 01/07/2009
Comment:

CMS should do all they can to expand PET coverage. There may be a small percentage of false positives but when you have a PET scan you see all the cancer all through the body not just one area like other modalities. I am a nuclear medicine professional and have performed PET scans and know it is a very reliable test. If I were diagnosised with cancer I would want a PET scan so I could know how spread the disease is. Think of it as yourself or a family member wouldn''t you want the best

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