The Dermatology Association of Radiation Therapy (DART) filed comments in opposition to a proposed change in Medicare coverage in seven states of Image-Guided Superficial Radiation Therapy (Image-Guided SRT or IGSRT) for the treatment of nonmelanoma skin cancer (NMSC).
| CHICAGO, April 29, 2024 /PRNewswire/ -- The Dermatology Association of Radiation Therapy (DART), a non-profit medical society working to heighten awareness of radiation therapy in the dermatological setting through advocacy, education, and research, filed comments in opposition to a proposed change in Medicare coverage in seven states of Image-Guided Superficial Radiation Therapy (Image-Guided SRT or IGSRT) for the treatment of nonmelanoma skin cancer (NMSC).
“The local coverage determination, or LCD, if finalized in its current form, would cause a significant, adverse impact on patient choice and access to care for the treatment of NMSC,” DART President and Chairman Jacob Scott, MD, DPhil, DABR, wrote in the organization’s submission to Palmetto GBA, a South Carolina claims processing company working under contract to the Centers for Medicare & Medicaid Services to make coverage decisions in the Southeast United States. The proposed LCD at issue, DL39808 “Superficial Radiation Therapy (SRT) for the Treatment of Nonmelanoma Skin Cancers (NMSC),” would affect residents in North and South Carolina, Virginia, West Virginia, Alabama, Georgia and Tennessee. The DART filing noted, “In its current form, the LCD is fundamentally misdirected, misguided, and inappropriate. It would altogether remove any semblance of patient choice or physician clinical decision making for patients who are diagnosed with NMSC. As IGSRT has increasingly become a common and widely-utilized safe alternative to surgical excision and Mohs surgery, Palmetto must reverse its proposed course that would head off these advances in the nonsurgical treatment of NMSC.” DART’s objections fall into two broad categories. First, the LCD’s scope is unclear and its references to SRT are misleading; and second, Palmetto’s “Coverage Guidance” fails to reflect several peer-reviewed journal articles and industry guidance supporting IGSRT as the nonsurgical standard of care and a first-line treatment option for NMSC. At the outset, DART underscores that the proposed LCD was filed as a Medicare Part A policy. However, both SRT and IGSRT are almost exclusively provided by dermatologists in the office setting, meaning these services would fall under the jurisdiction of Medicare Part B. Palmetto also conflates IGSRT with SRT, but while IGSRT was developed from previous generations of SRT technology, IGSRT is an entirely different treatment modality that has become the community standard of care for the nonsurgical treatment of NMSC and keloids in dermatologists’ offices. Arguing for its proposed LCD, Palmetto distorts the extent of scientific support for IGSRT. At least seven peer-reviewed studies illustrate the improved outcomes and diminished recurrence rates associated with IGSRT as compared to non-image-guided SRT and Mohs surgery. Palmetto omits several of these pivotal studies entirely, and those studies that are referenced in the LCD are either misrepresented or ignored in favor of other research that is outdated or irrelevant to IGSRT. Had all IGSRT studies been properly considered, Palmetto would have recognized that there is no clinical or scientific basis for the extreme IGSRT coverage requirements and limitations that are embodied in the LCD. The National Comprehensive Cancer Network (NCCN) guidelines for basal cell carcinoma (BCC) and squamous cell carcinoma (SCC), which Palmetto cites in the LCD, support IGSRT as a first-line treatment option for patients who are not surgical candidates or refuse surgery. Palmetto appears to acknowledge as much, noting that NCCN guidelines state, “considerations of function, cosmesis and patient preference may lead to the choice of RT as primary treatment over surgery.” However, the LCD disregards this guidance by relegating IGSRT to a second-line treatment and ignoring the paramount considerations of function, cosmesis, and patient preference in choosing an appropriate treatment for NMSC. American Academy of Dermatology (AAD) and American Society for Radiation Oncology (ASTRO) guidelines cited by Palmetto also specify the appropriateness of radiation therapy for patients who refuse surgical treatment, but Palmetto disregards these and instead limits IGSRT coverage to situations in which the patient is documented as a nonsurgical candidate. “Other errors of fact and omission abound in the LCD and Palmetto’s supporting documentation,” said Dr. Scott. “DART has addressed these in a 19-page filing which we will post on our website. We encourage all who share our confidence in IGSRT and our concern about the proposed LCD to express their views via email to the Palmetto decisionmakers.” Those wishing to object to the proposed LCD should address their comments to A.Policy@PalmettoGBA.com before the end of the comment period, May 11, 2024. About DART Media Contact:
SOURCE Dermatology Association of Radiation Therapy |
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