Table 2.
Challenges with potential solutions | Best to pursue (%) |
---|---|
Challenge A: Different payers have different evidentiary standards for assessing clinical utility, which leads to inconsistent policies on coverage and reimbursement for NGS-based tests | |
Multistakeholder consensus panels that include payers and patients should be convened to set evidentiary standards | 37 |
Expert panels (e.g., ACMG, NAM, EGAPP, etc.) should develop recommendations for evidentiary standards for all payers to use | 33 |
Fund research on methods of establishing standards, and pilot different approaches to determine the best one | 15 |
All payers, public and private, should cooperate to develop consistent standards | 7 |
No policy action needed. Accept variability in evidence standards and coverage inconsistency among payers and focus on other challenges | 7 |
There should be a government or legislative mandate for payers to cover all NGS tests | 0 |
There should be a legislative mandate for payers to cover FDA-approved or cleared tests only | 0 |
Challenge B: Diagnostic companies are able to maintain proprietary databases on a substantial variety of clinically meaningful mutations found in patients. Refusal to share this type of information could impede the development of clinically useful NGS tests. | |
Make data sharing and the possibility of independent verification a condition of approval/clearance, certification or accreditation (specifically, a requirement set forth by FDA, CMS/CLIA and/or CAP) | 54 |
Use positive-economic incentives so that payers reimburse more for tests from laboratories that share data | 18 |
Use negative incentives. For example, payers refuse to pay, or healthcare providers refuse to order tests, if there is no data sharing | 14 |
Make data sharing and sufficient transparency for independent verification a condition of funding (specifically, a requirement for NIH funding) | 14 |
Public shaming of companies that do not share | 0 |
Do nothing. You cannot or should not compel data disclosure in this space | 0 |
Challenge C: There is a lack of consensus about what mechanisms should be used to address the clinical risks to patients from NGS-based laboratory-developed tests. For example, there is continued debate as to whether FDA oversight should be used to address these risks | |
Use FDA oversight as a mechanism to address the risks to patients from NGS-based LDTs | 41 |
Use laboratory accreditation and proficiency testing by professional societies as a mechanism to address the risks to patients from NGS-based LDTs | 1 |
Use payers to address certain risks to patients from NGS-based LDTs, specifically, restrict payment to accredited laboratories | 7 |
Use payers to address certain risk to patients from NGS-based LDTS, specifically, condition coverage on consultation with a genetic counselor | 7 |
Rely on state regulation to address the risks to patients from NGS-based LDTs | 4 |
Use payers to address certain risks to patients from NGS-based LDTs, specifically, restrict reimbursement to FDA-approved or cleared tests | 0 |
Rely on self-regulation to address the clinical risks to patients from NGS-based LDTs | 0 |
Challenge D: There is a lack of standardization for reporting NGS test results (e.g., determining which results to report, how to effectively communicate findings, and to whom those findings should be communicated | |
A consensus panel could designate a general framework and nomenclature for how to present information (formatting reports) | 82 |
No action at this point. It is premature to come out with any guidelines on formatting reports | 14 |
Standardize communication to patients for providers and genetic counselors | 4 |
ACMG: American College of Medical Genetics; CAP: College of American Pathologists; CLIA: Clinical Laboratory Improvement Amendment; CMS: Centers for Medicare and Medicaid Services; EGAPP: Evaluation of Genomic Applications in Practice and Prevention; NAM: National Academies of Medicine; LDT: Laboratory-developed test; NGS: Next-generation sequencing.