Sunday, December 7, 2025

CMS Expert Becomes Deputy Director of CBER at FDA

Many of us who've worked for some time in genomics will remember Katherine Szarama PhD, who was one of the CMS coverage group staff assigned to the ground breaking NCD guaranteeing coverage of FDA-approved NGS companion diagnostics (e.g. Foundation Medicine circa 2017).

Szarama is now Deputy Center Director for CBER, the center for biologicals at FDA.   

Find her at Linked In:

https://www.linkedin.com/in/katherine-b-szarama-phd-627a172b/

Szarama worked at CMS 2016-2019.  She left CMS to join the Emerson Collective, then Arnold Ventures 2022-2025.   She was with the Advanced Research Projects Agency for Health, ARPA-H, most of 2025, January to fall 2025, before shifting over to the FDA.

See also a note at RAPS.org,

https://www.raps.org/news-and-articles/news-articles/2025/10/this-week-at-fda-more-layoffs-at-hhs-prasad-s-cbe

Noting,

According to MedPage Today, Vinay Prasad, the director of CBER, has started to shape his new  staff, as announced in an email to his colleagues. Katherine Szarama, PhD, has been appointed acting deputy director of CBER. She previously worked at the Advanced Research Projects Agency for Health and the Centers for Medicare and Medicaid Services before joining the FDA. Prasad noted that Szarama “will focus on policy and governmental relations while also participating more broadly within the center.”



MAC Issues LCD on Automated Detection of Brain MRI's: NO COVERAGE

 The CGS MAC has issued a final LCD on "Automated Detection and Quantification of Brain MRI's", L40224.   The proposal apppeared on  September 25, with comment to November 8.  The final appears December 4, with a "notice period" until January 18.  The LCD was "MAC initiated."

I check new LCD postings every Thursday and I don't recall seeing DL40224.   The non coverage statement is simple:

  • This is a non-coverage policy for artificial intelligence assistive software tool for automated detection and quantification of the brain.

I would note the author who wrote this might also write"non coverage...automated detection...whole slide imaging."

The LCD has 54 citations, some (by no means all) on ARIA, brain defects seen on amyloid therapies.

The MAC notes that "no comments were received."  

This is the concluding non coverage rationale:

While investigations have been exploring the potential of automated quantification technology for evaluation of ARIA, MS, TBI, epilepsy, brain tumors and other neurological conditions, this has been challenged by lack of established standards for measurements and access to large datasets to train the devices. While expert radiologists read the images based on visual patterns these programs quantify the brain volumes. While this is promising there is a lack of standards to establish what the normal values for brain volumes should be and each program has proprietary data so it is not interchangeable. There is not sufficient diversity within the data sets used to train the models to ensure changes based on age, gender, or ethnicity are accounted for. This is especially pertinent in the Medicare population as there are changes to brain volume related to age and with lack of standardized data it is challenging at this time to ensure subtle changes represent pathology and not variations of normal. At this time there is not sufficient clinical utility or validity data and use of this technology is considered investigational and not covered. CGS will continue to monitor the progression of research for these devices.


 

Friday, December 5, 2025

Freenome - Keeping On Top of Its Announcements (SPAC, More)


Freenome made a big splash in 2019, when it closed a sizable $160M funding round as its Series B (here).  Now, December 5, 2025, there were a number of announcements and documents - let's catch up with recent Freenome news.

First, in June 2025, Freenome had a JAMA publication for blood-based CRC screening that met CMS coverage requirements under the CRC screening NCD.  Here.  See Shaukat et al. here.

Second, in August 2025, Freenome announced an exclusive license agreement with Exact Sciences, for Freenome's colorectal cancer blood-based screening test.  Here.  Freenome framed the deal as "worth up to $885M" including milestones.

Third, in mid-November, Freenome announced another exclusive agreement, this one with Roche and for out-side-the-US test commercialization.  Here.   This deal was framed as "worth $200M plus" and increasing Roche's investment in Freenome via a "$75m equity instrument."

Next, on December 5, 2025, Freenome announces an agreement to make a business combination (i.e. to take Freenome public0 via a SPAC-type mechanism.  Here.  The package involves Freenome, PCSC (Perceptive Captial Solutions Corp) and PIPE investors.  Completion is "first half of 2026" and the ticker will be FRNM.  The $240M value includes $90M held in PCSC currently.

The deal involves: "The PIPE is led by Perceptive and RA Capital with participation from ADAR1 Capital, Bain Capital Life Sciences, Farallon Capital Management, as well as other new and existing leading healthcare investors."

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See early coverage at Fierce Biotech.  At STAT+.

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The PCSC K-8 announcement is online at SEC - here.  

Scroll to the bottom and there are 8 additional links - one of which is a new investor presentation (deck) which is 51 pages long.   The deck also has data on Freenome's CRC V2 test - see e.g. page 13.

See also a detailed business combination agreement - here.

51-page deck online at SEC




Thursday, December 4, 2025

Prolific at Linked In: Jose Pereira Leal (Diagnostics Strategies)

 Jose Pereira Leal is a prolific author at Linked In:

https://www.linkedin.com/in/pereiraleal/

See e.g. his June essay, "Lessons from the validation trenches of biomarker development,"

https://www.linkedin.com/pulse/from-promising-proven-lessons-validation-trenches-jose-pereira-leal-jh2ff/

He has a new pair of articles, "Rebuilding the Case for Diagnostics Investment," parts 1 and 2.

Part 1

Part 2

Part 1 opens like this:

The diagnostics sector faces a paradox: we're living through a precision medicine revolution, yet the tools that make precision medicine possible remain chronically underfunded.

In 2023-2024, diagnostics captured just $2.2 billion in global venture funding, while AI companies raised over $100 billion globally in 2024. Even within healthcare, nearly 30% of the $23 billion in US healthcare VC funding went to AI-focused startups, leaving diagnostics fighting for scraps.

Why does the market avoid a sector that underpins every major advance in modern medicine?

The Perfect Storm of Disincentives.... 


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He is also author of the book, Precision Diagnostics [views from the trenches].



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AI CORNER
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Chat GPT 5 summarizes "Building the Case - Investments in Dx" Parts 1 & 2.

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Below is a ~400-word integrated summary of both essays for graduate-level readers of your diagnostics strategy blog, synthesizing Part 1 (entrepreneur perspective) and Part 2 (investor perspective).


Summary (≈400 words)

The two essays argue that diagnostics are systematically undervalued, not because they generate weak economic returns, but because entrepreneurs and investors apply frameworks borrowed from biotech, SaaS, and medtech that misinterpret the category’s timelines, value drivers, and risk profile. Diagnostics occupy an unusual middle ground: development cycles of 7–10 years, regulatory complexity (IVDR, FDA, CLIA), and reimbursement friction make them slow to scale, yet their commercial upside rarely achieves drug-like revenue multiples. Because venture models are calibrated for either hyper-scaling software or blockbuster therapeutics, diagnostics appear to suffer from “ugly duckling” economics.

The author argues this perception is outdated. Precision medicine is producing captive markets for companion diagnostics, validated datasets create defensible assets, regulatory complexity functions as a barrier to entry, and high-value diagnostics can support premium reimbursement when positioned as clinical decision infrastructure rather than commodity testing. Additionally, risk-adjusted returns compare favorably to pharma: diagnostics require 1/10 the capital and offer higher hit rates with shorter cycles to revenue, even if individual exits are smaller. This creates a genuine arbitrage opportunity for disciplined capital.

Part 1 offers strategic guidance for founders: build with pharma rather than parallel to it; treat data as the product, not exhaust; embrace regulatory barriers as moat; price based on clinical and economic impact, not cost-per-test; and build platforms that enable expansion of indications and revenue streams. The central thesis is that diagnostic businesses should be understood as infrastructure for precision therapeutics, rather than isolated products.

Part 2 shifts to an investor framework, arguing conventional staging models fail because they focus on validation checkpoints rather than business model de-risking. The standard linear progression—analytical validation, clinical trials, regulatory approval, commercialization—ignores the much harder work of market adoption, including guideline inclusion, physician behavior change, reimbursement, workflow integration, and payer contracting.

The author proposes diagnostics-specific evaluation criteria based on explicit business model archetypes (single-test, platform, data-as-product, companion diagnostic) and on identifying and de-risking 3–4 core assumptions that determine value creation. Investors should intentionally structure portfolios to leverage technology, data, commercial, and evidence-sharing synergies, and provide ecosystem-level capabilities in regulatory strategy, clinical evidence architecture, payer engagement, pharma partnerships, and health-system integration.

Ultimately, the essays contend that diagnostics are mispriced assets, not weak assets, and that founders and investors who adopt category-specific strategies can exploit a major market inefficiency as precision medicine becomes standard of care.


If you’d like: a shorter “executive version,” a more polemical version for Substack, or a version with takeaway bullets for board presentations, I can tailor it.

Tuesday, December 2, 2025

Senator Escalates Concerns about AMA "Monopoly" (Coding)

On December 2, 2026, Washington Post features a story on Sen. Cassidy's escalating tensions with AMA, regarding coding and the RVU payment system.  The Senator kicks off by asserting that AMA's response to an October 6 letter "was anything but open and transparent."

  • See our October 29 blog on this topic here.
  • See updates, December 2 at Washington Post,here.
  • See the new 5-page Senate letter to the FDA, dated December 1, here.
    • Tangent: Negative article in WSJ about ABMS American Board of Medical Specialities, here.

AMA Summit on Digital Medicine

The exchanges come as AMA is on the brink of holding a major summit meeting in Chicago, December 8, on the future of new technologies coding and reimbursement, covering digital medicine, digital pathology, and AI.   More here.

CMS Innovative Work-arounds for Digital Reimbursement

And the letters, and that AMA meeting, come just as CMS announces its CMMI "ACCESS" model, under which some new, FDA-approved software-based or software-intensive interventions like remote monitoring will be reimbursed directly by Medicare as part of its new comprehensive approaches to chronic disease management, potentially outside the usual CPT coding channels.  Entry point here.


Monday, December 1, 2025

El-Khoury & Zaatari: Pathologist, AI, and the Future. Plus lots of great citations.

I probably saw this post via someone at Linked-In, but I've mislaid how I heard about it.  

Worth reading, a new open-access paper, which projects into the future and asks if pathologists will be "partners" or "bystanders" to AI.

Find the September 2025 paper by El-Khoury and Zaatari online at Diagnostics, here:

https://www.mdpi.com/2075-4418/15/18/2308

In addition to the main story, the article offers an excellent bibliography of nearly 100 references, some of them hard to find (history of microscopes), many others up-to-date through 2025.


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Sidebar:
I asked Chat GPT to compare the history of autopilots in airlines (1940-2025) to the future of pathologists in the AI lab (2025-2050).  Here.

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AI CORNER

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El-Khoury and Zaatari provide a sweeping, historically anchored analysis of how digital pathology and AI are jointly reshaping diagnostic practice, culminating in the provocative question of whether pathologists may eventually become “bystanders” in workflows they once wholly governed. They trace the discipline’s evolution from early microscopy and microtechnique innovations to contemporary whole-slide imaging (WSI)—establishing digital pathology as the essential substrate upon which AI systems now depend. This historical framing underscores that AI represents not merely another tool but a structural inflection analogous to the rise of cellular pathology itself.

Communications Expert Assesses Trump-Mamdani Conference, Line by Line

On YouTube, communications expert Chris Miller goes through the Trump-Mamdani Oval Office meeting and describes his view of how each politician handled framing, seizing initiative, dodging conflict, etc.

You don't have to buy into every single idea the communications expert has, to benefit from this magnifying-glass view of the dialog.    Watch it online - 15 minutes - or I've included a transcript below.

https://www.youtube.com/watch?v=Ju0URMztrzs


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Transcript from Rev.com from link.

Chris Miller:

Okay, no one would expect this, but President Trump and New York City Mayor like Mamdani just met in the Oval Office at the White House. And the presentation they just gave to the media and the question and answer portion was surprising.

 

LegislationWatch: Proposed: Bill for Alzheimer Blood Testing in Medicare, H.R. 6130

Legislation watch:  A bill is introduced which would cover preventive screening with blood tests for Alzheimer's disease.   

The legislation -as proposed - would create a new benefit at 1861(s)(2), under KK, Alzheimer early detection test (follows the recently added JJ, lymphedema compression services).  And (nnn) defines these as proteomic, genomic, etc - very broadly. 

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See also this week:

JAMA Meta-Analysis of Tau217 plasma diagnostics, Malek-Ahmadi et al.  

JAMA Op-Ed, 'Blood Tests for Alzheimer Disease - What to Do with the Holy Grail' by Grill.

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Repr. Buchanan (R-FL) had early publicity November 7 at AXIOS - here.

See the November 19 press release about the bill - here.

Read the bill posted at Congress.gov as HR 6130 - here.


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Humor: When Medicare Pays for a Covid Test / Nursing Home

From time to time I have work related to Medicare's 14-day-rule, which is difficult to explain even with graphics and charts.

This looks like comparable complexity: When does Medicare pay for a nursing home Covid test?   Sit down and take your hat off, this will be a while.


See link for several pages of additional explanation.
https://www.cms.gov/files/document/covid-medicare-payment-covid-19-viral-testing-flow-chart.pdf

Saturday, November 29, 2025

Noted: Luis Cano's Essay on "Invisible War in Digital Pathology"

 Luis Cano MD PhD is a Paris-based expert on digital pathology.  Find his Linked in here.  His article feed here.   His Substack articles, "Beyond the Slide," here.

His new 5000-word mega-essay about digital pathology system dynamics:

https://beyondtheslide.substack.com/p/the-invisible-war-in-digital-pathology

By the way, the bibliography of his new article is quite impressive too.

Enjoy the original essay but here's a 300 word summary (AI):

Digital pathology, Cano argues, is less a neat “digital upgrade” and more an invisible war: a messy, protracted collision between technology that already works and systems that are nowhere near ready to absorb it. The microscope era was stable, tactile, and culturally entrenched; digital workflows turn glass into data, demanding scanners, clouds, networks, standards, and cybersecurity. 

COVID accelerated adoption by necessity, proving feasibility but also exposing fragile infrastructure and improvisational workflows, especially in low-resource settings where digital tools could help most but basic prerequisites—power, bandwidth, capital—are lacking. The result is a tug-of-war between an analog world that won’t die and a digital one not yet fully born.

The conflict is driven less by algorithms than by misaligned incentives and timelines. Startups sprint on 18-month venture clocks; hospitals move on 5–10-year cycles; pathologists, as final signatories, face an identity and liability crisis. 

Economics form a central minefield: capital costs are huge, ROI is mostly indirect efficiency, and reimbursement for digitization or AI is nascent and fragmented. Technologically, proprietary formats, weak interoperability, domain shift, and brittle real-world performance keep AI stuck in “demo mode.” Regulatory fog deepens the tension: the FDA’s PCCP and the EU AI Act try to tame evolving, data-hungry models with frameworks built for static devices, while liability for AI-driven errors remains unclear.

Cano’s core thesis is that progress hinges on alignment, not more clever models. He points to federated and swarm learning, shared infrastructures like BigPicture, and human-centered design as early blueprints for cooperation. The future pathologist becomes an integrator of multi-modal information, not a human scanner; AI should amplify rather than replace. The “war” ends, he suggests, when stakeholders stop behaving like rival armies and start acting as architects—building standards, economic models, regulations, and lab designs that are interoperable, explainable, and explicitly human-centered.

Not Bad for a Machine: Chat GPT Offers to Review CMS & AI for Me

For almost three years, I've had a $20 a month subscription to Chat GPT.  Like other AI's, the home page me offers me topics for the AI to discuss (as if I could think of none, myself?)

This morning the home page of Chat GPT offered me:

  • What are the latest CMS policy updates on AI reimbursement and digital health? Any new regulations or pilot programs worth noting?

I thought, OK, it's a holiday, I'll bite.   

Here's what I got.  

NOTE: I would not necessarily make the same recommendations or emphasize the same things as Chat GPT.  What follows is offered only as an example of automated internet research and automated conclusions and summaries.

I asked it about turnkey venders for remote monitoring; in that section, I've stripped the websites it found but left the AI text.

Remarkable Series of Articles on Digital Medicine from Flavio Angei (Linked In)

I've started noticing the rapid flow of articles highlighted every week by Flavio Angei at Linked-In.

Find his home page here:

https://www.linkedin.com/in/flavio-angei-b5476841/


This should take you to his Linked-In postings:

https://www.linkedin.com/in/flavio-angei-b5476841/recent-activity/all/

He highlights top papers in digital medicine from a wide range of journals.

  • Evolving health technologies: Aligning with and enhancing the NIH Care Excellence Standards Framework.
  • Success factors for sclaing patient-facing digital health technologies: Leaders' insights
  • Navigating regulatory challenges across the life cycle of SaMD
  • LSE: Evaluation framework for health professionals' digital health and AI technologies.
  • Rethinking clinical trials for emdical AI with dynamic deployments of adaptive systems.
  • AI policy in healthcare; A checklist-based methodology for structured implementation.
  • Artificial intelligence in key pricing, reimbursement, market access processes.  Faster better cheaper - Can you really pick two?
  • Systematic review of cost effectiveness and budget impact of AI in healthcare.
  • Commercialization of medical AI technologies: Challenges and Opportunities

Etc etc etc....


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Goranatis et al. Weigh In on "Value & Valuation" of Genomics

  • First, updating some links on new reviews of MCED.  
  • Then, we look at a new paper by Goriatis, Buchanan, et al in Nature Medicine on valuation of genomics in healthcare.

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Reviews of MCED come out regularly in major journals; here is the latest one.  

See the latest in Annals of Internal Medicine, Kahwati et al. (November issue; ahead of print 9/16/25).   Sponsored by AHRQ, it comes with an op ed by Weinberg.  See the May 2025 AHRQ output, by Kahwati, at 139pp - here.

I think most of us are used to seeing "MCED" - Multi-cancer early detection.  These articles are headlining with "MCDT" - Multi-cancer detection tests.

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I'd put those articles in context of a major new paper by a health economics team on "determining the value of genomics in healthcare."  See the home page here:

https://healtheconomicsandgenomics.com/

And see Goranitis et al. in Nature Medicine, dateline November 27:

https://www.nature.com/articles/s41591-025-04061-3

Below, find Chat GPT 5 on Goranitis and on Buchanan, Goranitis.

Tuesday, November 25, 2025

CMS Issues "Request for Information" - Strategic Directions for Medicare Advantage

 CMS has issued its CY2027 proposed rule for Medicare Advantage.  It includes a "request for information" about future strategic directions for the program.

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CMS issues four major Medicare rules each year.  In the spring, we have the Inpatient Rule, which finalizes in August, ahead of the October fiscal year.  In the summer, we have the Physician and the Hospital Outpatient rules, which publish November 1, ahead of the new calendar year.

And around November, we get the Medicare Advantage proposals, which finalize in the spring, and of the next MA contract year.

Find the MA press release here:
https://www.cms.gov/newsroom/press-releases/cms-proposes-new-policies-strengthen-quality-access-competition-medicare-advantage-part-d

Find the fact sheet here:
https://www.cms.gov/newsroom/fact-sheets/contract-year-2027-medicare-advantage-part-d-proposed-rule

Find the actual proposed rule here (paginated publication on 11/28):
https://www.federalregister.gov/public-inspection/2025-21456/medicare-program-contract-year-2027-policy-and-technical-changes-to-the-medicare-advantage-program

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The word "coverage" occurs 726 times, but I don't see the words LCD or NCD this year. Prior Authorization 17 times, denial 3 times.  Artificial intelligence, twice.

The request for information on "Future Directions in Medicare Advantage" starts on inspection copy page 6-11.  

Comment to January 26, 2026.

Big News: FDA to Down-Classify Many Companion Diagnostics as Class II (510k)

Last year, when FDA was sparring with stakeholders and courts over its LDT regulations, FDA promised to downclassify many types of diagnostics from Class III to Class II.   They went radio-silent from April to November, but now, the regulation is in print.

This is big news because it changes the landscape of how hard it is to get an FDA label as a companion diagnostic.  It also means that new ranges of tests will qualify for Medicare benefits.  NCD 90.2, for NGS testing in cancer, automatically covers NGS tests that are "cleared or approved" as CDx.   And sole-source tests (run from one lab) are eligible for ADLT pricing rules if they are "cleared or approved."   Now the range of "cleared" tests will be larger.

See an early essay at Linked In by Karin Hughes PhD here.  A 5-page PDF from AgencyIQ here. By Lawrence Worden here.  At Genomeweb here.  Kahles et al. review EU and US IVD regulations - prior to this FDA change - here.

See the Fed Reg regulation proposal here.  Comment in 60 days until January 26, 2026.

The rule runs 14 pages and covers many considerations and details.  The regulation for 510K aka Class II CDx will be at 21 CFR 866.6075, as “Nucleic Acid-Based Test Systems for Use with a Corresponding Approved Oncology Therapeutic Product.”  Within the 14-page publication, the actual regulation at 21 CFR will be about 680 words long (two full columns of the Federal Register).


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AI CORNER

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FDA Down-Classifies 
Key Oncology Companion Diagnostics:
A Policy-Level Summary

In a significant regulatory shift, FDA has proposed reclassifying a cluster of oncology companion diagnostics (CDx) and CDx-adjacent molecular tests—from Class III (PMA) to Class II with special controls. The 14-page notice marks FDA’s first broad structural change to CDx oversight in more than a decade and reflects the agency’s conclusion that these technologies are now mature, well-characterized, and manageable within the 510(k) framework.

Rationale for Reclassification

FDA’s justification rests on two main pillars: