National Coverage Analysis (NCA) View Public Comments

Screening for Hepatitis B Virus (HBV) Infection

Public Comments

Commenter Comment Information
Clary, Ryan Title: Executive Director
Organization: National Viral Hepatitis Roundtable
Date: 08/06/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Services National Coverage Analysis for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

The National Viral Hepatitis Roundtable (NVHR), a coalition of

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Chen, Jr., Ph.D., M.P.H., Moon S. Title: Professor, Div. of Hematology & Oncology, Departme
Organization: National Center for Reducing Asian American Cancer Health Disparities
Date: 08/06/2016
Comment:

August 6, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the National Center for Reducing Asian American Cancer Health

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Rude, Eric Title: Director, Viral Hepatitis Policy
Organization: NYC Department of Health and Mental Hygiene
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Proposed Decision Memorandum for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

The New York City Department of Health and Mental Hygiene (NYC DOHMH) fully supports the Centers for

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Steinfurth, Nancy Title: Executive Director
Organization: Liver Health Connection
Date: 08/05/2016
Comment:
Liver Health Connection strongly supports the CMS proposal to expand access to Hepatitis B Virus (HBV) testing by covering the cost to Medicare patients. This is an important next step for identification of people with the disease. However, it needs to go beyond the primary care physician and to other sectors of health care, such as an emergency department or specialist.
Weiss, Gretchen Title: Director of HIV, STI, and Viral Hepatitis
Organization: National Association of County and City Health Officials
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Proposed Decision Memorandum for Screening for Hepatitis B Virus (HBV) Infection

Dear Ms. Jensen:

On behalf of the National Association of County and City Health Officials (NACCHO), I appreciate the

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Garcia, Barbara Title: Director of Health
Organization: San Francisco Department of Public Health
Date: 08/05/2016
Comment:

August 4, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the San Francisco Department of Public Health (SFDPH), we appreciate the

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Moraras, Kate Title: Senior Program Director
Organization: Hepatitis B Foundation
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the over 30 hepatitis B community coalitions and

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Caballero, MPH, Jeffrey Organization: Association of Asian Pacific Community Health Organizations
Date: 08/05/2016
Comment:

August 4th, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the Association of Asian Pacific Community Health Organizations (AAPCHO), we

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Chan, Eddie Title: President & CEO
Organization: North East Medical Services
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of North East Medical Services we write to express our appreciation and strong

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Cohen, DrPH, MPH, Chari Title: Chairperson
Organization: Coalition Against Hepatitis for People of African Origin
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the Coalition Against Hepatitis for People of African Origin (CHIPO), I

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Hep B United Philadelphia, . Organization: Hep B United Philadelphia
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG00447N)

Dear Ms. Jensen:

On behalf of the over 70 coalition partners and organizations

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Jiobu, DLM (ASCP), Karen Title: Health Care Consultant
Organization: Asian American Community Services
Date: 08/05/2016
Comment:

AACS
ASIAN AMERICAN COMMUNITY SERVICES

August 4, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of Asian American Community

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Ramachandran, Nisha Title: Policy and Operations Manager
Organization: National Council of Asian Pacific Americans
Date: 08/05/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the National Council of Asian Pacific Americans (NCAPA), we write to

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Sandberg, Nicole Title: Health Program Planner
Organization: San Francisco Department of Public Health
Date: 08/05/2016
Comment:

San Francisco Department of Public Health
Barbara A. Garcia, MPA
Director of Health

City and County of San Francisco
Edwin M. Lee
Mayor

August 4, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision

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Vertrees, Marisa Title: Director, Policy and Advocacy
Organization: Prevent Cancer Foundation
Date: 08/05/2016
Comment:

prevent cancer foundation

August 4, 2016

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CAG-00447N
7500 Security Boulevard
Baltimore, MD 21244

Re: Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection

Dear Acting Administrator Slavitt:

Thank you for the opportunity to comment on the Proposed Decision Memo for Screening for Hepatitis B Virus (HBV)

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McLean, Rachel Title: Chief, Office of Viral Hepatitis Prevention
Organization: California Department of Public Health
Date: 08/04/2016
Comment:

August 4, 2016

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

Re: Proposed Decision Memorandum for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

I am writing on behalf of the California Department of Public Health (CDPH), Office of Viral

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Sankarappa, Manju Title: Executive Director
Organization: Ohio Asian American Health Coalition
Date: 08/04/2016
Comment:

August 04, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of Ohio Asian American Health coalition, we write to express

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Goldsmith, R. Jeffrey Title: President
Organization: American Society of Addiction Medicine
Date: 08/04/2016
Comment:

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

Re: Proposed Decision Memorandum for Screening for Hepatitis B Virus (HBV) Infection

Dear Ms. Jensen,

On behalf of the American Society of Addiction Medicine (ASAM), a national medical specialty organization representing more than 4,000 physicians and other

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Abbas, Amina Title: Director of Government Relations
Organization: APIAHF
Date: 08/04/2016
Comment:

August 4, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

The Asian & Pacific Islander American Health Forum (APIAHF) writes to

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Abdul-Kadir, Mohammed Title: Hepatitis Coalition of Washington Coordinator
Organization: International Community Health Services
Date: 08/04/2016
Comment:

August 02, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the International Community Health Service (ICHS), we write to

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Altug, Arman Organization: Hepatitis Education Project
Date: 08/04/2016
Comment:

8/4/2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the Hepatitis Education Project (HEP) we write to express our appreciation and

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Cohen, DrPH, MPH, Chari Title: Director of Public Health
Organization: Hepatitis B Foundation
Date: 08/04/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of the Hepatitis B Foundation (HBF), I write to express our appreciation and

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Dao, MD, Doan Title: Chair, the National Hep B Task Force
Date: 08/04/2016
Comment:

National Task Force on Hepatitis B Focus on Asian Pacific Islander Americans

www.hepbtaskforce.org

August 3, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for

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Miller, Kimberly Title: Senior Policy Officer
Organization: HIV Medicine Association
Date: 08/04/2016
Comment:

August 4, 2016

Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services (CMS)
7500 Security Blvd.
Baltimore, MD 21244

RE: CMS’s Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

The Infectious Diseases Society of America (IDSA) and the HIV Medicine Association (HIVMA) appreciate the

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Tang, Amy Shen Title: Hepatitis B Program Associate
Organization: Charles B. Wang Community Health Center
Date: 08/04/2016
Comment:

Amy Shen Tang, MD
268 Canal Street
New York, NY 10013

astang@cbwchc.org
Tel: 212-379-6999

August 3, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for

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Tran, Binh Title: Exective Director
Organization: Asian Pacific Health Foundation
Date: 08/04/2016
Comment:

August 3, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

On behalf of Asian Pacific Health Foundation we write to express our appreciation

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Wang, Su Title: Medical Director
Organization: Center for Asian Health
Date: 08/03/2016
Comment:

August 5, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

As a primary care physician who has screened and cared for many

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Hamburg, Richard Organization: Trust for America's Health
Date: 08/03/2016
Comment:

August 6, 2016

Centers for Medicare and Medicaid Services (CMS)
Attention: Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection
(CAG-00447N)

To Whom It May Concern:

Trust for America’s Health (TFAH) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) proposed decision memo regarding the inclusion of Hepatitis B virus (HBV) screening into the group of preventive services covered under

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O'Brien, Patrick Title: General Counsel
Organization: Arrowhead Pharmaceuticals
Date: 08/03/2016
Comment:

August 3, 2016

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

RE: Centers for Medicare and Medicaid Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

Arrowhead Pharmaceuticals, Inc. is a clinical-stage research and development company

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Penner, Murray Title: Executive Director
Organization: NASTAD
Date: 08/02/2016
Comment:

August 2, 2016

Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Attention: Screening for Hepatitis B Virus (HBV) Infection

On behalf of the National Alliance of State and Territorial AIDS Directors (NASTAD), the association which represents public health officials who administer HIV and hepatitis health care, prevention, education, and supportive service programs funded by state and federal governments, I write to

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Cameron, Ivonne Fuller Title: President & CEO
Organization: Hepatitis Foundation International
Date: 07/26/2016
Comment:

July 26, 2016

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

RE: Proposed Decision Memo for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen,

On behalf of the Hepatitis Foundation International (HFI), we are pleased to share our comments with the Centers

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Tetri, MD, Brent Title: Professor of Internal Medicine
Organization: Saint Louis University
Date: 07/24/2016
Comment:

1. The policy should state the appropriate screening test (HBsAg). There are multiple HBV tests and primary care providers often do the wrong ones such as tests for acute hepatitis B (anti-HBc IgM).
2. Gastroenterologists should be allowed to screen. They see patients at risk and are knowledgeable about the appropriate testing.
Brent Tetri, MD
Director, Division of Gastroenterology and Hepatology
Saint Louis University

Bushman, Jesse Title: Director, Federal Government Affairs
Organization: American College of Nurse Midwives
Date: 07/22/2016
Comment:

CMS has proposed to cover the Hepatitis B screening test “when ordered by the beneficiary's primary care physician or practitioner within the context of a primary care setting.” The proposal goes on to define primary care practitioners and primary care settings.

We are concerned that the definition of primary care practitioner does not include certified nurse-midwives (CNMs) and we strongly recommend that CMS modify its proposal to include these providers. Under Section

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So, Samuel Title: Professor and Director
Organization: Asian Liver Center at Stanford University
Date: 07/20/2016
Comment:
On behalf of the Asian Liver Center at Stanford University, I strongly support the proposed Medicare coverage for hepatitis B screening. Medicare's coverage would help accelerate the adoption of USPSTF recommended hepatitis B screening guidelines by both private and public healthcare entities. Current evidence suggests that as many as two thirds of those living with chronic HBV infection in the country are not aware of their disease because they have not been screened. This important policy

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Huriaux, Emalie Title: Director of Federal & State Affairs
Organization: Project Inform
Date: 07/20/2016
Comment:

Project Inform is in strong support of the CMS proposal. Adding hepatitis B screening as a covered Medicare preventive service would significantly improve efforts to identify people living with hepatitis B and link them to lifesaving care and treatment.

We request that coverage be expanded beyond the primary care setting. By limiting coverage to primary care, CMS would be creating barriers to hepatitis B screening in other vital health care settings, such as emergency departments.

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Deskins, Sharon Title: MD, FACP
Date: 07/13/2016
Comment:
Although I support Medicare coverage for hepatitis B screening for high risk individuals I don't think this will be an effective strategy unless Hepatitis B immunizations are covered by Medicare in primary care offices as well
Swanson, Charles Date: 07/09/2016
Comment:
This testing should not be covered by CMS. The risk seems relatively low except for individuals engaged in activities which should be discouraged. Also - a vaccine is available to prevent HBV. Let's spend our money on something else.
Huang, Xiaoguang Title: MD, PhD
Organization: Dr Xiaoguang Huang's Office
Date: 07/09/2016
Comment:
I strongly support the idea of screening for high risk patient such as Chinese and Asian people. So far, I screen all new patients of Asian ethnicity. I have been treating these patients to prevent cirrhosis and liver cancer so successfully that none of my patient died of liver cancer from HBV though I found probably 6 to 8 of them and none of the patient with cirrhosis from HBV died except one who refused the treatment. The now a day understand and diagnosis and management of HBV are so

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