Medical Imaging & Technology Alliance (MITA)
August 11, 2017
BY ELECTRONIC DELIVERY
The Honorable Seema Verma
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue S.W.
Washington, DC 20201
Re: CAG-00399R4, National Coverage Analysis (NCA) Tracking Sheet for Magnetic Resonance Imaging (MRI)
Dear Administrator Verma:
As the premier trade association representing the manufacturers of medical imaging equipment and radiopharmaceuticals, the Medical Imaging & Technology Alliance (MITA) is submitting the following comments on the referenced National Coverage Analysis (NCA) for magnetic resonance imaging (MRI). The Agencyfs current coverage policy for MRI reflects the vital role that this technology plays in diagnosing a wide array of medical conditions which affect Medicare beneficiaries.
Significant advances have been made in MRI technology over the past several years, so it is commendable that CMS is updating its coverage policy to reflect the current literature. In particular, CMS should look to the latest clinical evidence and clinical practice guidelines as it updates this coverage policy.
As the innovators bringing new technologies to providers and their patients, MITA and its member companies have in-depth knowledge of the significant benefits that early and accurate diagnosis through medical imaging provides the healthcare system. MITA would like to serve as a resource to the Agency as it updates its understanding of the role and value of MRI.
If you have any questions, please contact Peter Weems at 703-389-1614 or by email at
Executive Director, MITA
MITA is the collective voice of medical imaging equipment and radiopharmaceutical manufacturers,
innovators and product developers. It represents companies whose sales comprise more than 90 percent
of the global market for medical imaging technology. These technologies include: magnetic resonance
imaging (MRI), medical X-Ray equipment, computed tomography (CT) scanners, ultrasound, nuclear
imaging, radiopharmaceuticals, and imaging information systems. Advancements in medical imaging are
transforming health care through earlier disease detection, less invasive procedures and more effective
treatments. The industry is extremely important to American healthcare and noted for its continual drive
for innovation, fast-as-possible product introduction cycles, complex technologies, and multifaceted
supply chains. Individually and collectively, these attributes result in unique concerns as the industry
strives toward the goal of providing patients with the safest, most advanced medical imaging currently