National Coverage Analysis (NCA) Tracking Sheet

Pharmacogenomic Testing for Warfarin Response

CAG-00400N

Issue

Pharmacogenomics is the study of how an individual's genetic makeup, or genotype, affects the body's response to drugs. It is an examination of the inherited components and variations in genes that dictate drug or medication response. Pharmacogenomics explores the ways these variations can be used to try to predict whether a patient will have a good response to a drug, a bad response to a drug, or no response at all.

There has been considerable public interest in the use of pharmacogenomic testing to predict the patient's response to warfarin, an orally administered anticoagulant drug that is marketed most commonly as Coumadin. Anticoagulant drugs are sometimes referred to as "blood thinners" by the lay public. Warfarin affects the vitamin K-dependent clotting factors II, VII, IX and X. The anticoagulant effect of warfarin is assessed with the prothrombin time (PT) and the International Normalized Ratio (INR). In this method, the ratio of the patient's PT to the mean PT for a group of normal individuals is calculated.

The most common and generally agreed upon indications for warfarin therapy are in patients with mechanical heart valves and, to a lesser extent, those patients with atrial fibrillation who are post-cerebrovascular accident or transient ischemic attack. Other indications include atrial fibrillation with thromboembolic risk factors including age over 65 years, diabetes, hypertension, as well as congestive heart failure.

The duration of anticoagulation therapy varies with the underlying indication and with the patient's response to therapy. Some conditions require anticoagulation for only a period of a few months, while other conditions require long-term and possibly life-long anticoagulation.

Since October 4, 2006, the FDA approved labeling for Coumadin® has included the following boxed warning.

WARNING: BLEEDING RISK

Warfarin sodium can cause major or fatal bleeding. Bleeding is more likely to occur during the starting period and with a higher dose (resulting in a higher INR). Risk factors for bleeding include high intensity of anticoagulation (INR >4.0), age >65, highly variable INRs, history of gastrointestinal bleeding, hypertension, cerebrovascular disease, serious heart disease, anemia, malignancy, trauma, renal insufficiency, concomitant drugs (see PRECAUTIONS) and long duration of warfarin therapy. Regular monitoring of INR should be performed on all treated patients. Those at high risk of bleeding may benefit from more frequent INR monitoring, careful dose adjustment to desired INR, and a shorter duration of therapy. Patients should be instructed about prevention measures to minimize risk of bleeding and to report immediately to physicians signs and symptoms of bleeding (see PRECAUTIONS: Information for Patients).

The FDA approved label notes many factors that can influence the anticoagulant effect of warfarin, including dietary intake of green leafy vegetables and cranberry juice, alcohol consumption, age, Asian ethnicity and liver function. Many other drugs affect warfarin metabolism. A very small sample includes analgesics, antibiotics, anticonvulsants, antineoplastics, beta adrenergic blockers, antifungals, hormone preparations and vitamins. The current label lists approximately 130 specific drugs reported to interact with coumadin.

Warfarin is eliminated by metabolic conversion to inactive metabolites by cytochrome P450 enzymes in the liver. It is claimed that genetic variability in the CYP2C9 and/or VKORC1 genes, in combination with many other factors, may partially predict a patient's response to warfarin.

The label also notes several small clinical trials that associate genomic factors with warfarin dose. The trial investigators suggest that pharmacogenomic testing may contribute to the identification of patients who may be more likely to over- or under-respond to warfarin. The dosing information in the label does not require or explicitly recommend pharmacogenomic testing prior to the initiation of warfarin therapy.

Clearly, an individual patient's initial response to warfarin therapy may be influenced by a multitude of factors well beyond genetic variation. We are concerned by the paucity of evidence available to determine what effect on overall health outcomes, if any, can be confidently attributed to treatment strategies that include pharmacogenomic testing in the determination of dosing.

CMS is internally opening this National Coverage Analysis (NCA) to complete a thorough review of the evidence to determine if the use of pharmacogenomic testing for warfarin is reasonable and necessary under the Medicare program.

Benefit Category

Diagnostic Tests (other)

Requestor Information

Requestor Name Requestor Letter
Internally Generated N/A
N/A

Important Dates

Formal Request Accepted and Review Initiated
08/04/2008
Expected NCA Completion Date
08/03/2009
Public Comment Period
08/04/2008 - 09/03/2008
Proposed Decision Memo Due Date
Proposed Decision Memo Released
05/04/2009
Proposed Decision Memo Public Comment Period
05/04/2009 - 06/03/2009
Decision Memo Released
08/03/2009
Comments for this NCA
View Public Comments

Contacts

Lead Analysts
Maria Ciccanti
Kimberly Long
Kimberly.long@cms.hhs.gov
410-786-5702
Lead Medical Officers
Jeffrey Roche, MD

Medicare Benefit Category Determination Date

Actions Taken

August 4, 2008

CMS initiates this national coverage analysis of pharmacogenomic testing for warfarin metabolism. The initial 30-day public comment period begins with this posting date, and ends after 30 calendar days.

CMS is requesting public comments on the effectiveness of pharmacogenomic testing for warfarin metabolism in the Medicare beneficiary population.

CMS considers all public comments, and is particularly interested in comments regarding clinical studies and other scientific information about the technology under review and the short and long term outcomes of the technology. Instructions on submitting public comments can be found at http://www.cms.hhs.gov/Medicare/Coverage/InfoExchange/publiccomments.html. You can also submit a public comment by clicking on the highlighted word comment in the title bar at the top of this page. We strongly urge that all public comments be submitted through this website. Please do not submit personal health information in public comments. Comments with personal health information may not be posted to the website.

December 10, 2008

CMS will convene the Medicare Evidence Development & Coverage Advisory Committee (MEDCAC) on February 25, 2009 to make recommendations on the desirable characteristics of evidence used by CMS to determine whether or not a diagnostic genetic test improves health outcomes in Medicare beneficiaries.

Due dates amended.

May 4, 2009

CMS is requesting public comments on the proposed decision. The 30-day public comment period begins with this posting date, and ends after 30 calendar days. Instructions on submitting public comments can be found at http://www.cms.hhs.gov/Medicare/Coverage/InfoExchange/publiccomments.html.

To submit comments, please use the orange COMMENT button at the top of the page.

August 3, 2009