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Centers for Medicare & Medicaid Services

View Public Comments for Positron Emission Tomography (CAG-00065R2)

Novich, Ira
Medical director
Carecore National

Policy regarding the use of PET technology should be made at the national level. Policies regarding the use of any procedure or technology should be based on rigorous scientific evidence published and scrutinized in peer reviewed journals. There is no reason to think that local MACs have exclusive access to scientific information unavailable nationally. Moreover,on a national level CMS already has programs in place,such as NOPR, to gather statistically valid data concerning the clinical efficacy or utility of new technology or new indications for currently available technology. The large amount of data needed to assess clinical utility could best be achieved on a national level.

If local MACs were to decide policy there would likely be a lack of uniformity in coverage with resultant confusion among the insured and among providers. Issues concerning quality might arise. Local MACs could be more easily pressured by local providers or others with a commercial interest in the technology to be liberal in their approach.

At a time when there is great concern regarding the cost of medical care in general allowing local MACs to make these kinds of policy decisions without rigorous science based data could unnecessarily raise the cost of medical care.

CMS is a national program. Coverage policies should be made nationally.