CLC Commends Development of NCCN Compendium
Dear Dr. McGivney:
Thank you for your recent presentation to the Cancer Leadership Council (CLC) regarding development of a compendium of drug usage by the National Comprehensive Cancer Network (NCCN). The accumulation of cancer care expertise among the NCCN institutions represents a valuable resource for the cancer community, as well as for policy makers and third-party payers, and we commend NCCN for its efforts to develop this new compendium.
As you know, drug compendia like that being developed by NCCN play an important role in the determinations to cover off-label uses of by Medicare, Medicaid and other payers under §§1861(t)(2)(B) and 1927(k)(2) of the Social Security Act. While the statute specifies the compendia to be used for this purpose, authority is also provided for the Secretary of Health and Human Services (HHS) to designate additional compendia to support coverage of off-label uses of drugs utilized in cancer treatment.
The use of compendia to identify appropriate off-label uses of cancer drugs is a well-established and necessary policy; indeed, many of the members of the CLC participated in the legislative effort to establish the compendia-based system in 1991-93. We believe that the system will work best if it is flexible and responsive enough to include qualified compendia beyond those specifically mentioned in the statute. Accordingly, at the appropriate juncture, we encourage the Secretary to consider favorably the qualifications of the NCCN compendium to act as a reference for off-label coverage decisions by Medicare and Medicaid.
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