Att 2b - Public Comments and Response

Attachment 2B
Summary of Public Comments and CDC Response

Public Comment #1

1414 Prince Street, Suite 204
Alexandria, VA 22314
703.548.1225
www.FightColorectalCancer.org

October 19, 2012

Thomas R. Frieden, MD, MPH
Director
Centers for Disease Control and Prevention
1600 Clifton Road
Atlanta, GA 30333
RE: Proposed Data Collections Submitted for Public Comment and Recommendations; CDC’s
Colorectal Cancer Control Program
Dear Dr. Frieden:
On behalf of Fight Colorectal Cancer, I appreciate the opportunity to comment on the
Centers for Disease Control and Prevention’s (CDC) proposed impact evaluation of the
Colorectal Cancer Control Program (CRCCP).
Fight Colorectal Cancer is a colorectal cancer advocacy organization based near Washington,
DC. We offer support for patients, family members, and caregivers, and we serve as a
resource for colorectal cancer advocates, policymakers, medical professionals, and health
care providers. Additionally, we do everything we can to increase and improve research – at
all stages of development and for all stages of cancer.
Advocating for federal funding for the CRCCP has been a longstanding priority for Fight
Colorectal Cancer and its volunteer advocates, and funding for colorectal cancer prevention
has a long history of bipartisan support in Congress. However, federal budget constraints put
the CRCCP and other cancer control programs at risk for funding cuts. We believe that
understanding the impact that the CRCCP programs have had on colorectal cancer screening
rates is vital to advocating for future funding for and expansion of the program. Further, as
noted in the Office of Management and Budget’s (OMB) Supporting Statement, because the
CRCCP is the first cancer prevention and control program funded by the CDC that
emphasizes both direct screening services for underserved populations and screening
promotion for the at-large population, the CDC is presented with an important opportunity
to evaluate this new public health model for potential application to other prevention

programs.
In addition to the 25 states and four tribal organizations that receive funds under the CRCCP,
we hope our advocacy will lead to the expansion of the program so that additional statewide
initiatives across the country are able to effectively implement programs to increase
colorectal cancer among those 50-64 years of age. We strongly support the proposed impact
evaluation of the CRCCP, as we believe that the findings will serve to inform the
development, implementation, and refinement of future and ongoing colorectal cancer
screening and education programs. We recognize that local cancer control divisions are
facing difficult resource decisions in the coming years. We hope the findings from this report
will help highlight effective systems to implement in colorectal cancer screening programs in
unfunded CRCCP states.
We understand that CDC plans to conduct two cycles of information collection over a threeyear period, with the first collection initiated in 2012 and the second in 2014. The OMB’s
Supporting Statement notes that at the close of the evaluation, findings will be presented to
participating states as well as the other states and tribes in the CRCCP. The statement
further notes that CDC will conduct presentations on the evaluation at professional
conferences. We ask the CDC to consider an interim evaluation presentation with key
colorectal cancer stakeholder organizations, such as Fight Colorectal Cancer and the
American Cancer Society, following the first program evaluation cycle. Understanding the
initial evaluation results can aid us in periodic refinement of our outreach and educational
tools.
I applaud your leadership and vision to systematically address the challenges faced by
communities and states to reduce the incidence and mortality due to colorectal cancer, a
largely preventable disease. If you would like Fight Colorectal Cancer to assist your efforts by
raising awareness of the survey in the targeted states, please let us know.
Fight Colorectal Cancer strongly supports the CDC’s proposed CRCCP impact evaluation.
Please do not hesitate to call upon my organization for future CRCCP endeavors. I can be
reached at [email protected].
Sincerely,

Carlea Bauman
President

Response to Public Comment #1
CDC sent a letter to Carlea Bauman, President of Fight Colorectal Cancer, thanking her for the strong
support offered by the organization for the CRCCP Impact Evaluation Study. In response to Ms.
Bauman’s specific request for an interim evaluation presentation based on wave one data collection,
CDC agreed to convene a meeting of key stakeholders to present a summary of these data when they
are available. A copy of the CDC letter is attached.

Public Comment #2

1520 Kensington Road, Suite 202
Oak Brook, Illinois 60523
Phone: 630-573-0600 / Fax: 630-573-0691
Email: [email protected]
Web site: www.asge.org

2012-2013 GOVERNING BOARD
President
THOMAS M. DEAS JR., MD, FASGE
Gastroenterology Associates of North Texas, LLP –
Fort Worth
[email protected]
817-361-6900

October 19, 2012

Thomas R. Frieden, MD, MPH
Director
Centers for Disease Control and Prevention
1600 Clifton Road
Atlanta, GA 30333

President-elect
KENNETH K. WANG, MD, FASGE
Mayo Clinic – Rochester
[email protected]
507-284-2174

RE: Proposed Data Collections Submitted for Public Comment and
Recommendations; CDC’s Colorectal Cancer Control Program

President-elect-elect

Dear Dr. Frieden:

COLLEEN M. SCHMITT, MD, MHS, FASGE
Galen Medical Group – Chattanooga
[email protected]
423-643-2500

Secretary
KENNETH R. McQUAID, MD, FASGE
VA Medical Center – San Francisco
[email protected]
415-221-4810

Treasurer
DOUGLAS O. FAIGEL, MD, FASGE
Mayo Clinic – Scottsdale
[email protected]
480-301-6990

Past Presidents
MICHAEL BRIAN FENNERTY, MD, FASGE
Portland, Oregon
GREGORY G. GINSBERG, MD, FASGE
Philadelphia, Pennsylvania

Councilors
AMITABH CHAK, MD, FASGE
Cleveland, Ohio
STEVEN A. EDMUNDOWICZ, MD, FASGE
Saint Louis, Missouri
KLAUS MERGENER, MD, PhD, MBA, FASGE
Tacoma, Washington
BRET T. PETERSEN, MD, FASGE
Rochester, Minnesota
WILLIAM M. TIERNEY, MD, FASGE
Oklahoma City, Oklahoma
JOHN J. VARGO II, MD, MPH, FASGE
Cleveland, Ohio

ASGE Foundation Chair
ROBERT A. GANZ, MD, FASGE
Minneapolis, Minnesota

Gastrointestinal Endoscopy – Editor
GLENN M. EISEN, MD, MPH, FASGE
Portland, Oregon

Chief Executive Officer
PATRICIA V. BLAKE, CAE
Oak Brook, Illinois

On behalf of the American Society for Gastrointestinal Endoscopy (ASGE), I
appreciate the opportunity to comment on the Center for Disease Control and
Prevention’s (CDC) proposed impact evaluation of the Colorectal Cancer Control
Program (CRCCP).
The ASGE is a 12,000-member, professional medical society whose mission is to
advance patient care and digestive health by promoting excellence in
gastrointestinal endoscopy. Among the primary services provided by
gastroenterologists is colorectal cancer screening colonoscopy.
ASGE is dedicated to educating those between 50 and 75 years of age or who may
be at high-risk for colorectal cancer about the importance of colorectal cancer
screening. ASGE is also committed to fostering adherence to colorectal cancer
screening guidelines, including performance of screenings at recommended
intervals.
As a proponent of the CRCCP and as an advocate of program funding increases,
ASGE strongly supports the proposed CRCCP impact evaluation. We hope the
findings from the evaluation will serve to benefit existing and future colorectal
cancer awareness and screening programs, as well as help ASGE and other
stakeholder organizations understand where knowledge gaps exist for the purpose
of improving educational and outreach efforts.
As stated in the August 22 Federal Register notice, the general population survey
will include questions related to the barriers to screening. ASGE has been an
aggressive advocate for removing financial barriers to colorectal cancer screening.
The Affordable Care Act (ACA) waives the coinsurance for Medicare beneficiaries
who receive a colorectal cancer screening. However, if a beneficiary chooses a
screening colonoscopy and a polyp or other tissue is removed, the patient is liable
for the coinsurance. Similarly, while cost sharing for colorectal cancer screening is
now waived for most commercially insured patients as a result of the ACA,

cost-sharing policies are variable across payers and many patients face high out-of-pocket costs
when their screening colonoscopy turns therapeutic. ASGE has been working to change current
policies so the threat of an unexpected charge for this otherwise “free” preventive service does
not serve as a financial barrier to screening. As the CDC prepares to conduct its surveys, it would
be helpful to know whether primary care providers are counseling patients regarding potential
cost-sharing obligations and whether the prospect of a financial obligation is a deterrent to
colorectal cancer screening colonoscopy.
The Office of Management and Budget (OMB) Supporting Statement notes that at the close of
the evaluation, findings will be presented to participating states, as well as the other states and
tribes in the CRCCP. The statement further notes that CDC will conduct presentations on the
evaluation at professional conferences and prepare articles for submission to peer-reviewed
journals. ASGE invites the CDC to consider submission of its evaluation and findings to the
journal Gastrointestinal Endoscopy.
ASGE believes that there would be value in including additional intervention states in the impact
analysis; however, we understand that budget constraints limit the evaluation to three
intervention states and three control states. We believe it is important, as proposed, that the
population survey includes a state-based, representative, cross-sectional sample of adults aged
50-75. We suggest that the benefits of the CRCCP extend beyond the populations that are
targeted by many of these programs. For example, a beneficiary of a CRCCP-funded screening
may tell friends and family about his/her experiencing, making them more inclined to receive a
screening.
ASGE thanks the CDC for undertaking this important evaluation of the CRCCP. Please do not
hesitate to call upon ASGE should you have any questions or require assistance on this or future
CRCCP endeavors. Please direct any communications to Lakitia Mayo, ASGE’s Assistant
Director of Health Policy and Quality, at [email protected] or (630) 570-5641.
Sincerely,

Thomas M. Deas, Jr., MD, MMM, FASGE
President
American Society for Gastrointestinal Endoscopy

Response to Public Comment #2
CDC sent a letter to Dr. Thomas Deas, President of the American Society for Gastrointestinal Endoscopy,
thank her for the strong support offered by the organization for the CRCCP Impact Evaluation Study. Dr.
Deas made a specific request for the inclusion of question(s) on the provider survey related to primary
care physicians’ counseling of patients on financial obligations (e.g., co-pays) for colorectal cancer
screening using colonoscopy. In response, CDC contacted the organization and enlisted their assistance
in crafting appropriate questions to include on the provider survey. These questions have been added
to the provider survey.