CMS Coverage Decision on Pharmacogenomic Testing for Warfarin Response – Consistent With ASH Recommendations

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The Centers for Medicare & Medicaid Services (CMS) posted a decision memo noting that the available evidence does not demonstrate that pharmacogenomic testing of CYP2C9 or VKORC1 alleles to predict warfarin responsiveness improves health outcomes in Medicare beneficiaries. CMS has determined that pharmacogenomic testing of CYP2C9 or VKORC1 alleles to predict warfarin responsiveness is not reasonable and necessary, but the available evidence supports that Coverage With Evidence Development is appropriate.

The final decision is that pharmacogenomic testing of CYP2C9 or VKORC1 alleles to predict warfarin responsiveness is covered only when provided to Medicare beneficiaries who are candidates for anticoagulation therapy with warfarin who:

  1. have not been previously tested for CYP2C9 or VKORC1 alleles;
  2. have received fewer than five days of warfarin in the anticoagulation regimen for which the testing is ordered; and
  3. are enrolled in a prospective, randomized, controlled clinical study when that study meets specific standards. 

In September 2008, ASH submitted comments to CMS on this issue. There was significant uncertainty regarding this new and emerging technology and ASH did not support the use of pharmacogenomic testing to guide initial dosing or ongoing treatment of warfarin, but was supportive of the use of pharmacogenomic testing for warfarin responsiveness in the context of randomized prospective clinical trials to establish the efficacy and safety of this approach. The CMS final decision is consistent with the ASH letter.

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