June 1, 2023

The Honorable Xavier Becerra
Secretary Health and Human Services
200 Independence Avenue, SW Washington, DC 20201

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244

Dear Secretary Becerra and Administrator Brooks-LaSure,

On behalf of the National Hispanic Council on Aging (NHCOA), the leading national organization that works to improve the lives of Hispanic older adults, their families, and caregivers, I am writing to express our concerns regarding the Centers for Medicare and Medicaid Services draft coverage with evidence development (CED) for monoclonal antibodies that target amyloid for the treatment of Alzheimer’s disease.

These coverage restrictions have harsh implications for communities of color, and if finalized, could severely limit their access to current and future FDA approved treatments for Alzheimer’s. Moreover, we strongly suggest revisiting the non-coverage determination for monoclonal antibodies for the treatment of Alzheimer’s Disease (AD).

Hispanics/Latinos are 1.5 times as likely to develop Alzheimer’s when compared to non-Hispanic White Americans. Despite the prevalence of this disease in our community, there are major gaps when it comes to diagnostics, treatment, and research. Hispanic/Latino older adults are one of the fastest growing populations in the nation, but they are often neglected by health research and face hurdles when attempting to access health care.

Although we commend CMS for requiring the diversity of patients in clinical trials to be representative of the national population diagnosed with Alzheimer’s disease, the way the CED is currently structured may actually undermine CMS’ health equity objective. Due to long-standing health disparities, the detection and diagnosis of dementias among Hispanics/Latinos and other communities of color have lagged behind non-Hispanic Whites.

As it is, the CED framework effectively denies access to an entire class of drugs that is reasonably likely to affect the course of Alzheimer’s. Every day, more and more patients progress to later stages of the disease and become ineligible for these therapeutics—people with Alzheimer’s and their loved ones cannot wait while CMS further delays access to the treatment that could change their lives. Patients and families should be given the option to access approved AD treatments in consultation with their doctors. By 2060, 14 million people are expected to have Alzheimer’s. Now is the time to stem the tide of this disease, and it must be done with health equity in mind. We urge you to ensure that CMS makes changes that will help the next generation have access to the Alzheimer’s treatments they and their families desperately need.

Sincerely,

Yanira Cruz, DrPH, MPH

President & CEO