Sunday, July 26, 2020

The 2018 NCD on Next Generation Sequencing: Too Little, Too Late?


      The Standard of Care for Cancer Should be Somatic Sequencing at Diagnosis


Because the Standard of Care Should be Better

by John J. Otrompke, JD 


               Within five years, tumor sequencing at the time of a patient’s cancer diagnosis will be the standard of care, according to a number of speakers at several 2020 oncology conferences, including ASCO, BIO and Cancer Progress.

                Both somatic and germline sequencing already form an important part of cancer care, but too often cancer patients do not receive targeted therapies until they have failed on other drugs, at which point it might be too late. (Somatic sequencing is the sequencing of cells from a tumor, while germline sequencing applies to a patient’s normal DNA).

In 2018, a National Coverage Determination (NCD) from CMS provided coverage from federal health payors for somatic sequencing, but it was only conclusive for patients in the late stages of cancer. (Another NCD from January 2020 applied to germline sequencing for breast and ovarian cancer genes).

                But it is important to do sequencing at the time of a patient’s initial diagnosis, so that patients can receive targeted therapies up-front; oncologists hope that up-front treatment with the new therapies will reduce acquired tumor resistance, and substantially improve patients’ results.

                When a patient has experienced an adverse medical result, they can sometimes file suit against their provider, alleging that the provider was less careful than a reasonable provider would have been (in other words, that the provider’s treatment in the case fell below the standard of care). Medical malpractice cases are usually governed by state law, but in some states, it’s possible that triers of fact could consider a federal regulation like a NCD in deciding whether the conduct of an oncologist was reasonable. Under the circumstances forecasted above, a few years from now, the failure to sequence a patient’s tumor at diagnosis could render a provider liable for professional negligence.

“Somatic sequencing at the time of cancer diagnosis will be declared the standard of care within two years. We see alterations in all solid tumors that mandate molecular profiling in everybody,” said  Ezra Cohen, MD, professor of medicine at University of California at San Diego.

“I would consider it the standard of care now for a few cancers, such as acute leukemias and myelodysplastic syndromes,” added Cohen, who participated in a June 10 session called ‘What Was Hot at ASCO?’ at the virtual BIO 2020 conference.

Time for a Scientific Reimbursement Policy

“We have targeted therapies against several low-frequency alterations that occur, such as NTRK fusions which occur in up to 3% of lung cancer cases. The response rates to those therapies are 80% and higher, so not detecting those rare alterations would have a substantial negative effect on the patient,” added Cohen.

“It would be malpractice for a patient to come in with suspected cancer and for us not to have the pathologist look at the tissue and make a diagnosis.  At some point, not doing the fundamental diagnosis to understand cancer would not be acceptable,” explained Razelle Kurzrock, MD, professor of medicine at UCSD.

                But notwithstanding the new drugs like entrectinib, larotrectinib and pembrolizumab, which enjoy tissue-agnostic approval from the FDA under certain circumstances, the importance of early somatic sequencing has not caught on yet in some quarters.

“I’m guessing that the majority of cancer patients in the country are still not sequenced,” said Kurzrock, who is also co-author of articles such as “Challenging Standard-of-Care Paradigms in the Precision Oncology Era,” Subbiah V and Kurzrock R (Trends Cancer. 2018 February ; 4(2): 101–109) (“Between 2003 and 2013, new cancer drugs approved by the European Medicines Agency (EMA) or the Food and Drug Administration (FDA) produced a total mean improvement in overall survival of only 3.4 months relative to the treatments that were available in 2003”).

The recent FDA approval of pembrolizumab for patients with tumor mutational burden high is a case in point. “For all intents and purposes, that approval on June 16 requires sequencing, but the approval is for patients who have failed standard therapy. It’s not going to be a rationale for sequencing up front,” added Kurzrock, who noted that the FDA often approves drugs based on studies done in patients who had already failed other therapies.

“If we’re going to use targeted therapies, we have to learn the lesson of chronic myeloid leukemia (CML), and treat at diagnosis. If you wait two or three years to use therapies we know work on CML, the treatments that give you a 100% response rate and normal life expectancy will encounter much more resistance, and you might get a life expectancy of a year,” explained Kurzrock. “Acquired tumor resistance always happens when you let the cancer evolve.”