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
DART is the only medical society focused on
the use of radiation therapy and other non-surgical options for the
treatment of skin cancer (and dermatologic conditions). DART and
its members are committed to analyzing and educating on therapies
that are most beneficial to patients. DART has four core
objectives: (1) Provide a forum for radiation therapy practitioners
and other interested persons to consider, discuss and share current
knowledge and information in the field of dermatologic radiation
therapy and related topics; (2) Sponsor meetings, forums, seminars
educational programs, dealing with the subject of radiation in the
dermatology setting and related topics; (3) Develop and share
information and materials on the use of radiation therapy in the
dermatologic setting; and (4) Promote the practice of dermatologic
radiation therapy and the common business interests of those
engaged in such practices. DART is headquartered in Chicago, Illinois. Membership information and
additional details can be found at dermassociationrt.org.
Media Contact:
Matt
Russell
Russell Public Communications
520-232-9840
mrussell@russellpublic.com
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SOURCE Dermatology Association of Radiation Therapy