LCD Issued by Palmetto GBA's MoIDX
Last week, CSRO submitted comments in response to a recently released proposed Local Coverage Determination (LCD) issued by Palmetto GBA’s Molecular Diagnostics Program (MolDX) regarding Molecular Biomarker Testing to Guide Targeted Therapy Selection in Rheumatoid Arthritis (DL39424). In their letter, CSRO argued that “molecular biomarker tests are the first tool offering an objective, science-based approach to identifying appropriate medication therapies for RA treatment and management,” and urged the contractor to “establish a local coverage policy and associated payment for the use of molecular biomarker testing to guide targeted therapy in RA” with certain caveats. Read more in CSRO’s comments.
Nondiscrimination in Health Programs and Activities Rule
In comments to the Department of Health and Human Services (HHS), CSRO expressed its commitment to ensuring patients do not face discrimination based on race, color, national origin, age, disability, or sex, consistent with Section 1557 of the Affordable Care Act, but urged the Department to make resources available that will help practices comply with newly proposed Section 1557 requirements outlined in the Nondiscrimination in Health Programs and Activities rule. Specifically, CSRO asked HHS to develop template policies and procedures, staff educational and training resources, and patient notices and educational materials. CSRO also urged HHS to postpone enforcement until these resources and other technical assistance have been made available.
In addition, CSRO suggested that certain policies established under the Medicare program, namely the Self-Administered Drug Exclusion List (SAD List), are discriminatory against patients with disabilities, and called on the Department to work with the Centers for Medicare and Medicaid Services to make modifications to the SAD List criteria to ensure robust beneficiary access to important medication therapies. Read more in CSRO's comments.