colon. Some worry that surgery or heart conditions might make them more vulnerable tocolonoscopy complications. While bowel preparation is the most frequently given reason for avoiding colonoscopy, patients also are concerned about the invasiveness of the procedure,the size and length of the scope, being sedated, having to miss work, and needing a ridehome.While anecdotal information has limited usefulness, we believe that the relatively low uptakeof colorectal cancer screening illustrates public concern with existing methods of screening.The ACS-MSTFCC-ACR consensus guidelines point out that, “
CTC surveillance could beoffered to those patients who would benefit from screening but either decline CSPY (colonoscopy) or are not good candidates for CSPY for one or more reasons."
The American Society for Gastrointestinal Endoscopy, a member of the US Multi-SocietyTask Force on Colorectal Cancer, does not recommend CTC for “widespread screening” but points out in their 2008 Screening Recommendations, “
However, it may be useful for patientswho refuse colonoscopy or who have had an incomplete colonoscopic examination.”
Patients Need Clear Guidance
C3 is concerned that there is an important difference in the screening recommendations between ACS in collaboration with the Multi-Society Task Force on Colorectal Cancer andthe American College of Radiology and the guidelines from the US Preventive Services Task Force. While the ACS-MSTFCC-ACR consensus includes CTC as a screening option to prevent colorectal cancer, the USPSTF does not. In an environment where several differentscreening options are available, choices with varying benefits, risks, and payment coveragecan confuse patients and physicians.CMS coverage with evidence development of CTC will generate data that can resolve thisconfusion and provide significant public benefit.
C3 urges reconsideration of the non-coverage decision by CMS, and strongly urgesCMS to gather the evidence by approving coverage of CTC, and implementing thenew coverage through a Coverage with Evidence Development (CED) process.
C3 pushes for research to improve screening, diagnosis, and treatment of colorectal cancer;for policy decisions that make the most effective colorectal cancer prevention and treatment
C3: Colorectal Cancer CoalitionComments to CMS regarding CTC, March 9, 2009Page 4 of 4
available to all; and for increased awareness that colorectal cancer is preventable, treatable,and beatable. More information can be found at www.FightColorectalCancer.org.C3 believes in fully disclosing sources of financial support, per our disclosure policy whichcan be viewed at www.FightColorectalCancer.org/sponsors. C3 has received no financial or in-kind support from manufacturers of CTCs. None of our other corporate supporters have