Alliance Comments at August 2024 Alzheimer’s Advisory Council Meeting

On August 5th, Adina Lasser, Public Policy Manager, provided public comments to the National Alzheimer’s Project Act. Her comments focused on three key elements having to do with patient access to care: the need for an A or B recommendation from the United States Preventative Services Task Force (USPSTF), the need for transparency from the Centers for Medicare and Medicaid Services (CMS) regarding their coverage with evidence development (CED) policy for monoclonal antibodies, and the need to ensure that patients in long-term care facilities have appropriate access to antipsychotics. Read Lasser’s full comment below.

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Hello, everyone. My name is Adina Lasser. I serve as Public Policy Manager at the Alliance for Aging Research. Today, I would like to talk through three recommendations.

First, with regards to screening for cognitive impairment. The federal government needs to prioritize screening for cognitive impairment as an A or B recommendation with the USPSTF. It is inexcusable that the USPSTF has maintained an “insufficient” recommendation since 1996—despite scores of published studies showing the benefits of cognitive screening and early diagnosis. In the past, one of the main reasons given for this low score was the lack of available medical therapies. Now, there are two disease-modifying treatments that have received traditional approval from the FDA; as well as an on-label treatment for Alzheimer’s disease agitation—with more on the way. This must be included in NAPA’s official 2024 recommendations.

Second, CMS should be required to be transparent regarding its Medicare “coverage with evidence development” policy for monoclonal antibody treatments. Since they introduced the mandatory registry and clinical studies in July 2023, there has been no reporting or transparency by the agency. Instead, we have overblown estimates regarding the cost impact on the Medicare program which assume uptake numbers that have not materialized and place undue blame on AD patients for premium increases. CMS should be held responsible for the patient impact of this policy.

Lastly, CMS uses a poorly-targeted quality measure related to the use of antipsychotics to treat neuropsychiatric symptoms of ADRD. These measures unfairly penalize smaller, rural facilities and facilities that focus on treating complex cases of neurocognitive decline. The measures used do nothing to distinguish between appropriate and inappropriate use of these medications. There is now an FDA approved treatment for agitation in AD patients, but patients have limited access to that care due to the outdated star rating metrics. We are also concerned the Agency has not disclosed data on how many residents are involuntarily discharged from nursing homes each year due to these policies and no transparency regarding residents being turned away at the door.

Thank you very much for your time and the opportunity to present.