regenesis position on ced to cms011812
DESCRIPTION
Regenesis Biomedical, Inc. (“Regenesis”) letter of support to the Centers for Medicare & Medicaid Services (“CMS”) on the National Coverage with Evidence Development (“CED”) Guidance Document solicitation. Regenesis supports the use of CED as a way to improve health outcomes through timely adoption of new technologies.TRANSCRIPT
January 17, 2012
VIA EMAIL [email protected] Louis Jacques, M.D. Director, Coverage Analysis Group Office of Clinical Standards & Quality Centers for Medicare & Medicaid Services 7500 Security Boulevard Mail Stop S3-02-01 Baltimore, MD 21224
Re: CED Public Solicitation: Comments on Guidance Document for National Coverage with Evidence Development
Dear Dr. Jacques: Regenesis Biomedical, Inc. (“Regenesis”) appreciates this opportunity to present its comments
to the Centers for Medicare & Medicaid Services (“CMS”) on the National Coverage with Evidence
Development (“CED”) Guidance Document solicitation. Regenesis supports the use of CED as a way to
improve health outcomes through timely adoption of new technologies. In particular, our comments
address some of the unique circumstances facing small companies offering promising new technologies.
Our comments also address suggestions for establishing a CED guidance document that takes into
account how stakeholders of all sizes can partner with CMS to develop needed evidence for Medicare
coverage, as well as the importance to the Medicare population of improving quality of life in the home
setting. In addition, we would suggest that CMS continue to work with stakeholders in refining the CED
process to reduce barriers to innovation.
Regenesis is a privately held medical technology company focused on developing and marketing
noninvasive regenerative medicine products. Regenesis developed, patented, and now markets the
Provant® Therapy System, cleared by the Food and Drug Administration for the palliative treatment of
post-operative pain and edema in superficial soft tissue. We are particularly interested in CMS’s
proposed refinements of the current CED process so that small companies can be included in any
approach adopted by the Agency. Only through workable CED pathways to coverage can meaningful
access and choices be made available to Medicare beneficiaries.
Regenesis believes that to best serve and maximize benefits to the Medicare population, the
CED process should reflect flexible approaches, as described further below. With this letter, we are
submitting comments in the following areas:
(1) The CED Process Should Be Expanded and Should Consider the Resources Available to
Small Manufacturers; and
(2) The CED Process Should Encourage Coverage in the Home Setting for New
Technologies Otherwise Covered.
The CED Should Be Expanded and Should Consider the Resources Available to Small Manufacturers
Because the CED process remains important for early access to new technologies, we believe that CMS should retain this tool. Indeed, the use of the process should be expanded so that it plays a more prominent role in national coverage. This may be accomplished through avenues other than the national coverage determination process, including through local coverage. Even if its implementation remains within the context of the national coverage analysis procedures, however, the CED process should be sufficiently simplified and streamlined so that adoption of new technologies is encouraged, and barriers to innovation may be simultaneously reduced.
To promote the efficient implementation of the CED process, CMS should adopt a flexible
approach that can tailor specific evidentiary requirements to the particular circumstances. Recognizing
that high-level quality controls are a key to collecting meaningful data, going forward, CMS should
consider how the process can become more practical, particularly given some of constraints on small
manufacturers bringing new technologies to market. Perhaps the greatest challenge for manufacturers
posed by the CED process is the amount of resources required to develop well-powered clinical trials
and registries. We recognize that CMS and the Medicare population would be best served with clinical
trials and registries that are developed and maintained by qualified entities. We believe that often
manufacturers are experienced in coordinating registries and, therefore, would recommend that CMS
consider the use of manufacturer registries. Further stakeholder collaboration should also be
considered to help identify the specific criteria that would ensure appropriate safeguards are
incorporated into software or other data collection tools for registries.
CMS should also consider developing more formalized partnerships with other government
agencies and independent third parties. The coordination for CED evidence-gathering with agencies
within the Department of Health and Human Services that have experience with research and data
collections, including the National Institutes of Health and the Agency for Healthcare Research and
Quality, may help to limit barriers.
In addition, to promote practical implementation—without compromising the integrity of
data—consideration should be given to the expanded use of the electronic claim form for data
collection activities. This would also help reduce burdens on providers. For example, information may
be recorded for easy reviews by CMS using the claim form (e.g., the “NTE segment”) to relay information
about progress and key observations from the use of a product under review. The electronic format
could then streamline the ability of CMS to evaluate outcomes data.
As to evaluation of data, CMS should identify scheduled intervals—such as 18 to 24 months—
after which time, the agency will assess whether there is sufficient information to make a final national
coverage determination decision, or whether additional information should continue to be developed
and gathered. For some technologies, CMS may determine that continuation of the data-gathering is
appropriate, whereas for others the NCD process may come to a close.
The CED Process Should Reinforce the Use of New Technologies in the Home Setting
We also urge CMS to adopt the CED process for evaluating and collecting data to demonstrate how advances in technologies can be applied to alternative settings. As our population ages, technologies that permit individuals to remain at home become more critical. When patients can be cared for in the home or community setting, not only does the patient’s quality of life benefit, but also the Medicare program stands to achieve cost savings. Particularly for technologies that have already been recognized and accepted by Medicare in one setting—and for which there is a defined benefit category—CMS should consider using a streamlined CED process to obtain clinical evidence for home use. Extending coverage to this setting could proceed with the appropriate safeguards, adapted to the special circumstances associated with the specific technology and other applicable factors.
On behalf of Regenesis, thank you for your consideration of our comments. Should you have any questions or need additional information from us, we can be reached at [telephone #]
Sincerely,
William P. Gittinger
Vice President, Reimbursement &
Health Economics
REGENESIS BIOMEDICAL, INC.