I submit comments as the Executive Director of Malecare, America’s leading men’s cancer survivor support and advocacy national nonprofit organization. My comments are also informed by my experience as a primary and co-investigator on NIH/NCI and private industry funded prostate cancer research projects, as a patent holding bio-tech inventor and as a social worker who has led more prostate cancer support groups (1-3 per week, aprox. 47 weeks per year for over 18 years) than anyone, anywhere.
Malecare asks that you delay implementation of this project until the completion of the recently initiated self-review by the USPSTF of their 2012 recommendation against the use of the PSA test for prostate cancer screening. Since this CMS project is premised by the USPSTF recommendation, delay is appropriate until the USPSTF can report their current understanding of the efficacy of PSA testing for prostate cancer. CMS fails to display wisdom if it initiates a study based on disputed findings from 2012, when a current review of those findings by the USPSTF is currently in progress.
Should you dismiss any delay, than Malecare asks that you modify your criteria for instrument design.
• Supplemental Data Elements: We ask that Gender and Sexual Identity be added as criteria for Supplemental Data Elements. A growing body of peer reviewed papers and NIH funded research is showing that Gay men with prostate cancer have higher levels of psych-social and physical post diagnostic distress. These men may appropriately receive a PSA test for diagnostic or surveillance purposes.
Malecare further asks that criteria and participation of non gender specific males and transgender women be included in your study.
• Denominator Exclusions: We ask that men who have at least one first degree biologic parent of African Descent be excluded from the denominator. African American men are presenting with more advanced stage diagnosis at younger ages than are caucasion men. Further, Prostate cancer kills African American men at more than 2.4 time the rate as it kills caucasion men. These men may appropriately receive a PSA test for diagnostic or surveillance purposes.