Re: NCA Tracking Sheet for Bariatric Surgery for the Treatment of Morbid Obesity (CAG-00250R)
Thank you for the opportunity to make comments regarding the NCD request for bariatric surgery for the treatment of obesity. We are writing on behalf of NAASO, The Obesity Society. We are the leading scientific organization in the field of obesity. Founded in 1982, our mission is: "To promote research, education and advocacy to better understand, prevent and treat obesity and improve the lives of those affected."
NAASO membership is comprised of the 2,000 leading scientists and clinicians in the field. Our journal, Obesity Research is the leading journal in obesity and our Annual Meeting is the world's largest scientific meeting dedicated to obesity.
Over the past ten years a consensus has emerged that surgery can produce substantial weight loss and may markedly improve a number of health outcomes. This consensus is supported by the findings of the National Heart, Lung and Blood Institute (NHLBI) in 1998, the AHRQ 2003 Technology Assessment, and the CMS MCAC panel in November of 2004, among others. NAASO supports these conclusions, and believes that surgery does have its place in the obesity treatment continuum.
In response to your questions posted in the NCA Tracking Sheet for Bariatric Surgery for the Treatment of Morbid Obesity (CAG-00250R)
Is the evidence adequate for evaluating health outcomes of the bariatric surgery procedures listed in the request?
We do agree that the evidence is adequate to support the safety and effectiveness of the surgical options included in the requested NCD.
Should CMS define the list of co-morbid conditions that qualify a patient for bariatric surgery?
We agree that it is appropriate to include as examples the list of currently known co-morbid conditions of obesity. However, obesity is a complex disease and through research, we are continuing to expand our knowledge of its effects. As we learn of new co-morbid conditions, obese patients with these conditions should not be denied access to care because the condition is not included on the list.
Should CMS adopt criteria for facilities or surgeons who deliver these procedures?
Data support the fact that patients are more likely to have successful surgical outcomes if the surgery is performed in a facility that is adequately equipped and staffed and by a surgeon who is properly trained and has performed a number of surgeries. [Flum D 2004. Impact of gastric bypass on operation survival: A population based analysis.] We support the inclusion of criteria for facilities and surgeons, and suggest that these criteria be based on those currently being used by the surgical societies.
Is there a need for routine data collection on the delivery or outcomes of bariatric surgery?
We believe there is a need for routine data collection, particularly in certain populations such as the elderly. There is a lack of data for elderly obese patients. However, we do not wish to see unnecessarily burdensome procedures implemented that may increase the complexity of the process and may reduce the number of participating providers. We recommend that the data collection process be developed in collaboration with affected physician societies.
Finally, we were also pleased to see included in the request the coverage for long-term post-operative care. NAASO believes that without proper pre and post-operative care patients may develop serious complications or may not maintain their weight loss. We strongly encourage inclusion of coverage for perioperative care to help ensure the best outcomes possible.
Thank you for your consideration.
Louis J. Aronne, M.D. FACP, President
Thomas A. Wadden, Ph.D, President-elect
Eric Ravussin, PhD, Vice-President
Gary Foster, PhD, Secretary/Treasurer