Compliance with the provisions in this policy may be monitored and addressed through post payment data analysis and subsequent medical review audits.
History/Background and/or General Information
The emergence of personalized laboratory medicine has been characterized by a multitude of testing options which may more precisely pinpoint management needs of individual patients. As a result, the growing compendium of biomarkers requires a more careful evaluation by both clinicians and laboratorians as to what testing configurations can more optimally realize the promises of personalized medicine. There are a plethora of burgeoning tools, including both gene-based (genomic) and protein-based (proteomic) assay formats, in tandem with more conventional (longstanding) flow cytometric, cytogenetic, etc. biomarkers. Classified somewhat differently, there are highly diverse approaches ranging from single mutation biomarkers to multiple biomarker platforms, the latter of which often depend upon sophisticated biomathematical interpretative algorithms. This policy will provide guidance on the broad range of (recently coded) biomarkers, and how such a wide array of testing platforms can be best accommodated by this local Medicare Administrative Contractor.
Medicare coverage for screening of those individuals with a family history of certain disease is covered only for a limited number of services as listed in the Section 280 – Preventative and Screening Services of the IOM 100-02, Medicare Benefit Policy Manual, Chapter 15.
Tests performed without relationship to treatment or diagnosis of a patient with no findings or history for a specific illness, symptom, complaint or injury unless set exclusion are so noted in Title 42 CFR, Section 411.15(a)(1).
Local Medicare coverage of such biomarkers must be predicated upon three fundamental principles:
First, there must be an underlying performance of acceptable, high-quality analytical validity for all such laboratory testing. As a result, the laboratory shall have available upon request:
- Analytical and clinical validation reports for Clinical Laboratory Improvement Amendments (CLIA), including the test description, intended use, and indications for testing.
- If applicable, all formal, written minutes and correspondences (including any Q & A and supporting documentation) with the New York State Department of Health (NYSDOH) or the US Food and Drug Administration (FDA).
- Most recent inspection results (including recommendations) or scheduled inspection(s) from CLIA, College of American Pathologists (CAP), or NYSDOH, as applicable.
Second, there must be an appreciation of evidence-in-transition where new biomarkers should be brought on-line in harmonization with their proven clinical validity/utility (CVU). Although analytical validity is an equally important metric, it remains more outside of a payer's purview to conduct such detailed evaluations. Therefore, in the absence of a standard CVU referee process (e.g., although FDA labeling of biomarkers can be a helpful adjunct, it may not always be relevant), the key imperative is for medical necessity to be reflected by the clear articulation of a particular biomarker niche.
Third, there must be a recognized decision impact of such biomarkers by the clinical community. In other words, there must be acceptance/uptake of specific testing into patient management. It should be taken into account that to reach the medical necessity threshold, such acceptance should be based on the strongest evidence available, ideally from along the spectrum of high-quality masked, randomized controlled clinical trials, and much less preferably from lower levels of evidence, which are predicated upon expert opinion only without primary study data.
Per above, it is relevant to categorize biomarkers into functional clusters which, in turn, can enable longitudinal coverage guidance that is most relevant to the Medicare program mission:
The commercial availability does not ensure that a molecular diagnostic test is indicated for clinical application. Molecular diagnostic testing is a rapidly evolving science in which the significance of detecting specific mutations has yet to be clarified in many circumstances. Analytical and clinical validity as well as clinical utility are the responsibility of the provider, and all testing must meet standards of care.
Covered Indications
1.GERMLINE (HEREDITARY) MUTATIONS
Medicare considers genetic testing medically necessary to establish a molecular diagnosis of an inheritable disease when all of the following criteria are met:
- The beneficiary must display clinical features of an associated disease, but noting that coverage of molecular testing for carrier status or family studies is considered screening and is statutorily excluded from coverage; and
- The result of the test will directly impact the treatment being delivered to the beneficiary; and
- A definitive diagnosis remains uncertain after history, physical examination, pedigree analysis, genetic counseling, and completion of conventional diagnostic studies.
Note: The following two germline hereditary mutation tests will be considered medically reasonable and necessary when performed for evaluation of venous thromboembolism. Refer to ICD-10 Code Group 3 in the related Local Coverage Article: Billing and Coding: Biomarkers Overview A56541.
- Factor II (F2 gene)
- Factor V (F5 gene)
* While not required for payment, NCCN Guidelines recommend referral to a cancer genetics professional with expertise and experience in cancer genetics prior to genetic testing and after genetic testing. Examples of cancer genetics professionals with expertise and experience in cancer genetics include: an American Board of Medical Genetics or American Board of Genetic Counseling certified or board eligible Clinical Geneticist, Medical Geneticist or Genetic Counselor not employed by a commercial genetic testing laboratory (excludes individuals employed by or contracted with a laboratory that is part of an Integrated Health System which routinely delivers health care services beyond just the laboratory test itself as these individuals are also considered independent); medical oncologist, obstetrician-gynecologist or other physician trained in medical cancer genetics, a genetic nurse credentialed as either a Genetic Clinical Nurse or an Advanced Practice Nurse in Genetics by either the Genetic Nursing Credentialing Commission (GNCC) or the American Nurses Credentialing Center (ANCC) who is not employed by a commercial genetic testing laboratory (excludes individuals employed by or contracted with a laboratory that is part of an Integrated Health System which routinely delivers health care services beyond just the laboratory test itself as these individuals are also considered independent).
2. PHARMACOGENOMICS
The cytochrome P450 (CYP450) gene superfamily is composed of many isoenzymes that are involved in the metabolism of many medications. Although this superfamily has more than 50 enzymes, six of them metabolize 90% of clinically used drugs. Each cytochrome P450 gene is named with CYP indicating it is part of the cytochrome P450 family. CYP2C19 metabolizes at least 10% of all commonly prescribed drugs, whereas CYP2D6 enzymes metabolize approximately 20-25%, and CYP2C9 metabolizes approximately 10%.
Human CYP genes are highly polymorphic. As a result, polymorphisms are classified into four groups based on the level of CYP enzyme activity and include poor (abolished activity), intermediate (reduced activity), extensive (normal activity) and ultra-rapid metabolizers (enhanced activity). Genetic variability or polymorphism in these enzymes may influence a patient’s response to commonly prescribed drug classes. The most pharmacologically and clinically relevant CYP polymorphisms are found in CYP2D6, CYP2C9, and CYP2C19. The genotypic rates vary by ethnicity.
A. CYP2C19 Genotyping
Background on CYP2C19 Testing
Genetic alterations or polymorphisms are common in these isoenzymes, with more than 30 polymorphisms identified in CYP2C19. These polymorphisms can lead to differences in individual drug response secondary to variation in metabolism.
The frequency of the various CYP2C19 metabolizer phenotypes has been estimated as follows:
- 2-15% - poor metabolizers
- 18-45% - intermediate metabolizers
- 35-50% - extensive metabolizers
- 5-30% - ultra-rapid metabolizers
Pharmacogenetic testing has been proposed to predict individual response to a variety of CYP2C19-metabolized drugs including clopidogrel, proton pump inhibitors, and tricyclic antidepressants, among others. In certain scenarios, an individual patient may benefit from genetic testing in determining dosage and likely response to specific medications.
Clopidogrel bisulfate (Plavix) is a widely prescribed medication to/for:
- Prevent blood clots in patients with acute coronary syndrome (ACS),
- Other cardiovascular (CV) disease-related events,
- Undergoing percutaneous coronary intervention.
Clopidogrel response varies significantly due to genetic and acquired factors including obesity, smoking and non-compliance. Patients with poor response to clopidogrel may experience recurrent CV event or thrombotic events while taking clopidogrel. They are at greater risk for major adverse CV events such as heart attack, stroke and death. These individuals are typically poor to intermediate metabolizers of clopidogrel due to the presence of the associated CYP2C19 polymorphisms. These individuals should be given an alternate treatment strategy (Plavix PI). As such, the clinical utility of CYP2C19 genotyping has been supported with net benefits on improving health outcomes for individuals with ACS who are undergoing percutaneous coronary interventions (PCI). There is insufficient evidence of clinical utility of CYP2C19 genotyping for individuals considering clopidogrel therapy for other indications.
With regards to CYP2C19 testing for antidepressant treatment, recent evidence has suggested genetic testing prior to initiating certain tricyclic antidepressants, namely amitriptyline, due to the effects of the genotype on drug efficacy and safety. Use of this information to determine dosing has been proposed to improve clinical outcomes and reduce the failure rate of initial treatment. However, the Clinical Pharmaco-genetics Implementation Consortium did not have enough evidence to make a strong recommendation for dose modification based on genotype, and a moderate recommendation was given based on data outside of randomized trials. Additionally, even with genotype information, a suggestion is given to start patients on low dose, gradually increasing to avoid adverse side effects. Consequently, genotyping is not needed with this approach.
Proton pump inhibitors are used to treat several gastric acid-related conditions including duodenal ulcer, gastric ulcer and gastroesophageal reflux disease. Proton pump inhibitors can also be used to treat Helicobactor pylori. Several proton pump inhibitors are metabolized by CYP2C19. However, there is insufficient data to warrant CYP2C19 genotyping to determine health outcomes or adverse drug reactions in treatment with proton pump inhibitors.
With regards to Serotonin reuptake inhibitors, there is insufficient evidence to support CYP2C19 genotyping to determine medical management for the treatment of obsessive compulsive disorder at this time.
This policy limits CYP2C19 genetic testing to patients with ACS undergoing PCI who are initiating or reinitiating Clopidogrel (Plavix) therapy.
Genetic testing for the CYP2C19 gene is considered investigational at this time for all other indications including, but not limited to the following medications:
- Amitriptyline
- Clopidogrel for indications other than above
- Proton pump inhibitors
- Selective serotonin reuptake inhibitors
- Warfarin
B.CYP2D6 Genotyping
Background on CYP2D6 Testing
Genetic alterations or polymorphisms are common in these isoenzymes, with more than 100 polymorphisms identified in CYP2D6. These polymorphisms can lead to differences in individual drug response secondary to variation in metabolism.
Genetic variation, as well as drug-drug interactions, can influence the classification of CYP2D6 metabolism into one of the above phenotypes. In addition, chronic dosing of a CYP2D6 drug can inhibit its own metabolism over time as the concentration of the drug approaches a steady state.
Pharmacogenetic testing has been proposed to predict individual response to a variety of CYP2D6-metabolized drugs including tamoxifen, antidepressants, opioid analgesics, and tetrabenazine for chorea, among others. In certain scenarios, an individual patient may benefit from this genetic testing in determining dosage and likely response to specific medications.
Tamoxifen
Available evidence fails to support direct evidence of clinical utility for testing of CYP2D6 in treatment with tamoxifen. Tamoxifen metabolism and the causes for resistance are complex rather than the result of a single polymorphism.
Antidepressants
In regards to CYP2D6 testing for antidepressant treatment, there was insufficient evidence in the past to support testing to determine treatment. More recently, evidence has supported the use of genetic testing prior to initiating certain tricyclic antidepressants due to the effects of genotype on drug efficacy and safety. Use of this information to determine dosing can improve clinical outcomes and reduce the failure rate of initial treatment. However, there is insufficient evidence for CYP2D6 genotyping for individuals considering antipsychotic medications or other antidepressants with CYP2D6 as a metabolizing enzyme.
Codeine
In addition, the role of CYP2D6 genotyping has been evaluated for use in opioid analgesic drug therapy, specifically codeine analgesia. The efficacy and toxicity, including severe or life-threatening toxicity after normal doses of codeine has been linked to an individual’s CYP2D6 genotype. However, genotyping would indicate avoidance of codeine due to risk of adverse events in only 1-2% of the populations, and there is considerable variation in the degree of severity of adverse events, with most not classified as serious. Furthermore, codeine is widely used without genotyping. At this time, there is insufficient evidence to support clinical utility of genotyping for management of codeine therapy.
Tetrabenazine
The dosing of tetrabenazine is based, in part, on CYP2D6 genotyping. However, a recent study suggests that the necessity to genotype may need to be reconsidered. The manufacturer package insert indicates that poor metabolizers of CYP2D6 should not exceed a maximum dose of 50 mg/day.
Drugs for Alzheimer’s Disease
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- Galantamine is an antidementia drug used in the treatment of Alzheimer’s disease. Studies have been performed that reveal the CYP2D6 genotype significantly influences galantamine concentrations in blood. Still other studies have revealed that urinary assays for CYP2D6 phenotype are technically feasible. At this time, the association between phenotype and drug responsiveness remains unknown. It has been suggested that confirmation studies in larger populations are necessary to establish evidence regarding individuals most likely to benefit from galatamine, including information on treatment efficacy and tolerability.
- Donepezil (Aricept) is a drug used to treat Alzheimer’s disease. Some studies have reported an influence of the CYP2D6 on the response to treatment with this drug. Other studies suggest that therapy based on CYP2D6 genotype is unlikely to be beneficial for treating Alzheimer’s disease patients in routine clinical practice. Additional studies are needed to determine the efficacy and utility of CYP2D6 genotyping in those patients who are treated with donepezil.
Covered Indications for CYP2D6
Genetic testing of the CYP2D6 gene is considered medically necessary to guide medical treatment or dosing for individuals for whom initial therapy is planned with:
- Amitriptyline or nortriptyline for treatment of depressive disorders
- Tetrabenazine doses greater than 50 mg/day, or re-initiation of therapy with doses greater than 50 mg/day
Indications considered not reasonable and necessary for CYP2D6
There is insufficient evidence to demonstrate that genetic testing for the CYP2D6 gene improves clinical outcomes for the following medications. Consequently, genetic testing for the CYP2D6 gene is considered investigational for the following:
- Antidepressants other than those listed above
- Antipsychotics
- Codeine
- Donepezil
- Galantamine
- Tamoxifen
3. SOMATIC MUTATIONS, ONCOLOGY:
- Please Refer to LCD L35396, Biomarkers for Oncology.
CYP2C9 Genotyping
- This policy does not address coverage with evidence development (CED) under section 1862(a)(1)(E). For CED coverage information related to CYP2C9 and VKORC1 for warfarin responsiveness please refer to the NCD for Pharmacogenomic Testing for Warfarin Response (90.1).
This LCD imposes frequency limitations. For frequency limitations please refer to the Utilization Guidelines section below.
Notice: Services performed for any given diagnosis must meet all of the indications and limitations stated in this policy, the general requirements for medical necessity as stated in CMS payment policy manuals, any and all existing CMS national coverage determinations, and all Medicare payment rules.
The redetermination process may be utilized for consideration of services performed outside of the reasonable and necessary requirements in this LCD.