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Centers for Medicare & Medicaid Services

View Public Comments for CED Public Solicitation

Flores, VerĂ³nica Bayetti
Policy Research Specialist
National Latina Institute for Reproductive Health

January 20, 2011

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

CED Public Solicitation: Potential impact of CED on the Medicare program and its beneficiaries

To Whom It May Concern:

As an organization dedicated to ensuring the fundamental human right to reproductive health and justice for Latinas, our families, and our communities, the National Latina Institute for Reproductive Health thanks Centers for Medicare & Medicaid Services (CMS) for the opportunity to comment on coverage with evidence development (CED) in the Medicare program.

Reflecting the demographics of older populations, Medicare recipients are disproportionately women. Though Medicare is a program that serves all U.S. citizens and eligible immigrants, it is those with the lowest incomes who rely on it most. Because Latinas and women of color are disproportionately poor, Medicare coverage of crucial health care services  has a profound impact on these communities. Moreover, while there is often a lack of robust clinical evidence that pertains to the health needs of communities of color – and particularly their subpopulations, such as migrant seasonal farmworkers and lesbian, gay, bisexual, and transgender (LGBT) people – new research concerning these populations is becoming available every day. Continuing and increasing the practice of coverage with evidence development allows clinical practice for under-researched groups to more quickly reflect the research as data begins to accumulate for a broader range of subpopulations, and ultimately improve patient access to effective emerging treatment options.

It is, of course, imperative that there be clear criteria for CED developed with consumer and client advocates so that CED is safe and weighs the benefits of experimental treatments against the limits of available data. Additionally, CMS must develop a transparent process for independent review and to ensure that those with financial stakes in new treatments are not encouraging their clinical use prematurely.

With proper regulation and transparent processes, however, CED can result in earlier and broader access to innovative treatments and strategies that work well for communities, particularly for communities that have been historically under-researched and under-served. Given this, we believe that CED is beneficial not only for Latinas’ reproductive health, but also for communities of color at large.


National Latina Institute for Reproductive Health

50 Broad St Suite 1937

New York, NY 10004