Wednesday, March 6, 2024

Timeline: NCD Request to Final Change, 2.5 Years (!)

Header: How long did it take to get an NCD changed?  2.5 years.


In October 2021, the American Society of Hematology and other major groups requested CMS to expand coverage of stem cell transplantation in myelodysplastic syndrome (MDS), and remove a CED requirement dating back to 2010.

The 9-page letter is a good example of a clear request.

CMS initiated public review in June 2023, about 18 months later.   A draft NCD was produced in December 2023, and finalized in March 2023.

CMS made a number of detailed changes based on the December 2023 comment period, generally accepting proposals for broader coverage (some of them nuanced).

Kimberly Long was the lead analyst and Dr James Rolllins the lead medical director.