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The American Society for Microbiology (ASM) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services National Coverage Analysis on Screening for Sexually Transmitted Infections (STIs) and High-Intensity Behavioral Counseling (HIBC) to Prevent STIs (CAG-00426N) issued on February 24, 2011. The ASM is the largest educational, professional and scientific society dedicated to the advancement of the microbiological sciences and their application for the common good. The Society represents over 38,000 microbiologists professionally employed in a variety of areas, including biomedical, agriculture and environmental microbiology, as well as public health and clinical microbiology and immunology.
ASM members play important roles in many areas of clinical laboratory medicine. ASM professionals include directors of clinical microbiology, immunology and molecular diagnostic laboratories; individuals licensed or accredited to perform laboratory testing; researchers involved in developing and evaluating laboratory diagnostic tools; and industry representatives marketing products for clinical use. The ASM also includes clinician members involved in infectious disease prevention and management. Therefore, the ASM has significant interest in the process of establishing national coverage decisions for medically necessary procedures including infectious disease screening and prevention in select circumstances to ensure the health of all Medicare beneficiaries.
The ASM strongly supports the proposals outlined in CAG-00426N to cover screening for designated STIs and HIBC in Medicare beneficiaries who are at risk for STIs to include both younger disabled individuals as well as older Americans in whom continued sexual activity and risk for STIs is an emerging concern.1,2 The best practices defined in existing United States Preventive Services Task Force (USPSTF) guidelines support all of the preventive services proposed for coverage including screening for chlamydial and gonococcal infection in at-risk women, screening for hepatitis B infection in pregnant women, screening persons at risk for syphilis, and HIBC to promote prevention of STIs in all beneficiaries at increased risk.
A key component of implementation of an effective screening program for STIs relies on allowing a broad and inclusive definition of risk factors. Risk factors for screening and behavioral intervention are defined in a number of guidelines3-8 and include a history of STIs in the recent past, recent new sex partners, multiple sex partners, failure to use barrier protection, and contact with individuals with recent STIs. As these factors emerge or evolve with time, it would be difficult to impose frequency limitations on laboratory testing, and ASM would strongly discourage such limitations (i.e. annual testing may need to be supplemented with additional testing if a new risk factor is noted). Laboratory testing should be orderable by any Medicare authorized healthcare professional, and it will likely be necessary to establish procedure codes for screening benefit documentation as was done for the recently adopted HIV screening benefit. Although the ASM supports HBIT as a screening benefit, we offer no recommendations on frequency or service level.
STI screening in at-risk patients and prevention through behavioral intervention are mainstays of public health efforts to control the spread of these diseases which carry significant consequences, clinically, emotionally, and financially. A Medicare National Coverage Decision offering STI screening and HIBT in appropriate at-risk patient populations is a critical component of a national strategy to control STIs in support of the Healthy People 2020 objective to “promote healthy sexual behaviors, strengthen community capacity, and increase access to quality services to prevent sexually transmitted diseases (STDs) and their complications.”9
Thank you for your attention. Please feel free to contact the ASM if there are additional questions or concerns.
Vickie Baselski, Chair, Committee on Professional Affairs