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Comments to CMS Supporting Inclusion of HSCT for Sickle Cell Disease in the National Coverage Determination

​May 29, 2015

Dear Dockets Manager:

The AABB Center for Cellular Therapies strongly supports including hematopoietic stem cell transplantation (HSCT) for sickle cell disease (SCD) in National Coverage Determination (NCD) 110.8.1. Coverage in the NCD is crucial to ensure access to curative therapy for patients with sickle cell disease, and we appreciate that CMS has opened the National Coverage Analysis to allow stakeholders to provide valuable feedback on this important topic. 

Allogeneic HSCT is currently the only curative therapy available for patients with Sickle Cell Disease. Unfortunately, the lack of CMS coverage prevents patients from receiving the treatment they need. This is especially problematic because a high percentage of patients with SCD participate in governmental payer health care coverage plans. This barrier to receiving potentially curative therapy has been cited as one of the factors responsible for the significant underutilization of this therapeutic modality in management of patients with severe sickle cell disease. AABB requests that CMS expand the National Coverage Determination to include HSCT in patients with SCD.

AABB is an international, not-for-profit association representing individuals and institutions involved in the field of transfusion medicine and cellular therapies including hematopoietic stem cell transplantation. The association is committed to improving health by developing and delivering standards, accreditation and educational programs that focus on optimizing patient and donor care and safety. AABB membership consists of nearly 2,000 institutions and 8,000 individuals, including physicians, nurses, scientists, researchers, administrators, medical technologists and other health care providers. AABB members are located in more than 80 countries.

The AABB Center for Cellular Therapies appreciates the opportunity to comment on the National Coverage Determination. If you have additional questions please contact me at nkamani@aabb.org.

Sincerely,

Naynesh Kamani, MD
Vice President, Center for Cellular Therapies & Research