Our Request of CMS: Bundling and PET Scan Issues

May 2, 2024

Ms. Chiquita Brooks-LaSure, Administrator

Centers for Medicare & Medicaid Services

7500 Security Boulevard

Baltimore, MD 21244-1850

Dear Administrator Brooks-LaSure:

On behalf of the undersigned supporting organizations, and the millions of Americans living

with Alzheimer’s disease, we urge the Centers for Medicare and Medicaid Services (CMS)

to expeditiously take action to address the known issues related to payment bundling for

PET scan tracers, unpackaging diagnostic radiopharmaceuticals and paying for them

separately from other procedure costs. The current policies inadequately support access

to these tests, which is preventing people living with and at risk of Alzheimer’s from

receiving the appropriate scans and subsequent diagnoses.

For years, we lacked the ability to diagnose and treat Alzheimer’s effectively and many went

without that confirmation. But now, the tools exist to help support and improve the lives of

people with Alzheimer’s, and CMS must do everything possible to ensure timely access to

these solutions. Lack of progress related to payment bundling for innovation that assist

diagnosis is a delay that has significant negative impacts our community.

Early diagnosis allows affected individuals a wider range of effective treatment options and

more time to develop comprehensive, personalized care and treatment plans. Yet, despite

the proven benefits of early detection and diagnosis, the rate of undetected dementias in

the U.S. is estimated at 61 percent, and only 11 percent of people with incident mild

cognitive impairment (MCI) report receiving a timely diagnosis. Access to beta-amyloid PET

scans is crucial to ensuring timely and accurate diagnosis. Estimates indicate that about

half of the capacity for beta-amyloid PET scans in the United States today is inaccessible

because of current barriers, including a payment bundling structure that disincentivizes

these tests.

This problem has existed since my wife Geri was diagnosed with Alzheimer’s disease in

2012; she is now in the late stage of the disease, and I very much wish to tell her that this

issue has been resolved. Every day, more than 2,000 people transition to a more advanced

stage of Alzheimer’s, where they are no longer eligible for existing treatments. Better

access to beta-amyloid PET scans allows people to receive an accurate diagnosis of

Alzheimer’s more quickly and, when eligible, begin one of the available disease-modifying

therapies that can slow the onset of the disease, extend independence, and improve

quality of life.

Now is the time to solve the remaining issues that are delaying and preventing access for

so many.

Thank you for your consideration.

Sincerely,

Jim Taylor

President & CEO

Voices of Alzheimer’s

Joined by:

Alliance for Aging Research

Partnership to Fight Chronic Disease

UsAgainstAlzheimer’s