Thursday, September 7, 2023

Brief Blog: CMS Updates NCD Wait List

 A few weeks ago, I gave a talk CMS's plans for "TCET" Transitional Coverage for Emerging Technology.  I noted that even if you think it sounds good, CMS has a record of underperforming regarding coverage innovations.  I listed three things -

1.  Parallel Review was announced with great fanfare and gusto, but was used ultra rarely.

2.  Coverage with Evidence Development is perennially praised, yet its accomplishments are few (not zero, but few).  (CED is a pillar of the proposed TCET).

3.  CMS some years ago announced a national NCD dashboard, but updated it once or twice and forgot about it (like a child or puppy wandering to a different room and leaving a forlorn toy behind.)  Called the NCD Dashboard (on this page), until a few days ago, its last annual update (so called) was 2019 or so.

It's Updated

CMS has updated the NCD Dashboard on August 23, 2023.  It's here:

https://www.cms.gov/files/document/ncd-dashboard.pdf


Finals

In the past years, 2 NCDs were finalized, for cochlear implantation and for seat elevation (both are related to benefit category issues, too.)   

In Flight

Four NCDs are in process right now.  The Beta Amyloid PET NCD is proposed for deletion.  A USPSTF prevention benefit is being created as an NCD - PREV therapy.  There is an umpteenth update of a carotid stenting NCD.  Then there's the fairly recent opening of the stem cell transplantation NCD, opened June 7, draft decision expected December 7, 2023.  Myelodysplatic syndrome (MDS) is covered only CED, and organizations have asked the CED to be put to rest.  See the nine page request from ASH and others.

Note - MolDx recently covered whole genome sequencing for MDS therapeutics.  Blog.

Backlogged

Unlike finished or in-process NCDs, backlogged future topics are represented by a title phrase and not always penetrable.  Backlog topics include 1) "diaphgram pacemakers for neuromuscular disease [please non cover]", 2) hepatitis C screening [USPSTF endorsed 5/2020], 3) subcu insulin infusion pumps, 4) "power standing systems" (e.g. stand-up?), 5) pulmonary pressure sensor, 6) ventilators for COPD [ DME issue?], and finally 7) HPV for cervical screening.

The USPSTF rec for HPV and cervical screening is a few years old and being revised shortly.  I suspect there may be some revision issue, like coverage every 3 vs every 5 years.  Right now CMS covers annual Pap smears plus 1 HPV per 5 years on top of that.  USPSTF is somewhat laisse faire, allowing any of the following:  1) annual Pap, 2) HPV q5y, or 3) both.

CMS has coverage for insulin pumps now, and they must be subcu (not IV or IM), so there is likely some revision in play on that one, too.  

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TCET Fun Fact

The comment period for TCET closed in late August.  As of September 7, 153 comments were received but 149 are still on hold and not posted yet.