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January 29, 2009 Maria Ellis Executive Secretary for MEDCAC Centers for Medicare and Medicaid Services Office of Clinical Standards and Quality Coverage and Analysis Group Mailstop C10906 7500 Security Blvd Baltimore, MD 21244 Re: Comments to MEDCAC on Genomic Testing Dear Ms. Ellis: The American Clinical Laboratory Association (“ACLA”) is pleased to have this opportunity to submit comments to the Medicare Evidence Development and Coverage Advisory Committee (MEDCAC) on requirements for evidence to determine if diagnostic uses of genomic testing in Medicare beneficiaries with signs or symptoms of disease improve health outcomes. ACLA is an association representing independent clinical laboratories throughout the country, including local, regional and national laboratories. Many if not all of our members perform genomic/genetic testing (terms used interchangeably); thus, ACLA has a significant interest in this issue. According to the announcement for this meeting, the Centers for Medicare and Medicaid Services (CMS) has asked MEDCAC to make recommendations “regarding the desirable characteristics of evidence that could be used by the Medicare program to determine whether genetic testing as a laboratory diagnostic service improves health outcomes.” ACLA recognizes the importance of this issue, especially given the growth in genetic testing since the completion of the Human Genome Project. ...
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