ASH Clinical News May 2016 | Page 68

FEATURE CMS Expands Coverage for Hematopoietic Cell Transplantation: Proceed with Cautious Optimism The recent decision by the Centers for Medicare and Medicaid Services (CMS) to cover allogeneic hematopoietic cell transplantation (alloHCT) for eligible patients with sickle cell disease (SCD), myelofibrosis, and multiple myeloma (MM) is a boon for hematology. But, as is often the case with good news, this National Coverage Determination (NCD) needs to be taken with quite a few grains of salt. In this case, the specific criteria needed to be met that govern exactly how and when CMS will cover eligible patients are causing many transplanters to slightly curb their enthusiasm. “This decision is a very significant milestone that reflects our advances in the art and science of stem cell transplantation,” said Krishna Komanduri, MD, director of the Adult Stem Cell Transplant Program at the University of Miami Health System’s Sylvester Comprehensive Cancer Center in Miami, Florida. “Beyond that, there are some caveats, including that, within each disease state, there are some eligibility restrictions for patients based on their risk level and the severity of disease.” The NCD requires the establishment of clinical trials to assess and validate alloHCT in Medicare patients with SCD, myelofibrosis, and MM, and those will take some time to develop and start enrolling patients, added Dr. Komanduri, who is also president-elect of the American Society for Blood and Marrow Transplantation (ASBMT). Laura Michaelis, MD, associate professor of medicine at the Medical College of Wisconsin in Milwaukee, Wisconsin, agreed that this decision is a clear “win” for clinicians and patients, but that “there are still aspects [of the NCD] that need to be finalized.” “I don’t think these criteria are meant to be restrictive,” Dr. Michaelis said. “I think CMS wants to expand coverage, and that’s great, but they also want to gather information to ensure that this course of action is appropriate. We need to make sure that we work with CMS to achieve that goal.” Mary Horowitz, MD, chief of the Division of Hematology and Oncology at the Medical College of Wisconsin, called the NCD “a 66 ASH Clinical News way forward that removes the financial barrier to transplant for a growing population of patients who can benefit from it.” She also cautioned that the transplant community and CMS still have to agree on what constitutes acceptable clinical data to support coverage. Drs. Kumanduri, Michaelis, and Horowitz, as well as other members of the transplant community spoke with ASH Clinical News about the details of this NCD and what it means for hematologists, transplant specialists, and patie nts – both now and in the near future. The Big Picture and the Finer Points With NCDs such as these, CMS can mandate or prohibit coverage for specific procedures in specific indications. Prior to the recent NCD, CMS was “silent” on the use of alloHCT for the treatment of SCD and myelofibrosis. That meant coverage decisions were up to local Medicare Administrative Contractors, so patients and transplant centers were put in a position of potentially taking on the full financial burden of the procedure if coverage was denied, explained Stephanie Farnia, MPH, director of payer policy at the National Marrow Donor Program (NMDP)/Be The Match. Beyond that, CMS outright prohibited coverage of alloHCT for MM. Enter the new NCD, with coverage of alloHCT in these three disease states and the caveat that reimbursement would be provided only if the patient is enrolled in a CMSapproved clinical trial designed to evaluate the benefit of alloHCT in a Medicare population. Called a Coverage with Evidence Development (CED), this requirement mandates that eligible beneficiaries meet the following criteria to receive coverage: • Symptomatic, stage II or III MM • Intermediate-2 or High Dynamic International Prognostic Scoring System myelofibrosis, plus score in primary or secondary disease • Severely symptomatic SCD Additionally, the CED trial requirements for alloHCT in these conditions state that patients must be participating in an approved prospective clinical study that meet the following criteria: “There must be appropriate statistical techniques in the analysis to control for selection bias and potential confounding by age, duration of diagnosis, disease classification, International Myeloma Working Group classification, International Staging System score, Durie Salmon staging, comorbid conditions, type of preparative/ conditioning regimen, graft-versus-host disease (GVHD) prophylaxis, donor type, and cell source.”1 The principal objectives, according to the CED, are to test whether alloHCT therapy improves health outcomes, to compare survival outcomes between alloHCT and non-alloHCT therapies, and to address acute and chronic GVHD and transplant-related adverse events. Analysis of quality of life among those receiving alloHCT is an optional component to these studies, according to CMS. This isn’t the transplant community’s first go-round with a CED – in 2010, CMS required one for coverage of myelodysplastic syndromes (MDS), although the CED in that setting was much less demanding, asking that trials: • Prospectively compare MDS Medicare beneficiaries who receive alloHCT therapy and determine if they have better outcomes than those who do not get alloHCT treatment. • Examine how International Prognostic Scoring System score, age, cytopenias, and comorbidities predict outcomes among these patients. May 2016