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November 2, 2015
USPSTF Coordinator
c/o USPSTF
540 Gaither Road
Rockville, MD 20850
Re:
Draft Recommendation Statement: Colorectal Cancer Screening
Dear USPSTF Coordinator:
The Oncology Nursing Society (ONS) appreciates the opportunity to provide comments on the draft recommendation
statement and draft evidence review for colorectal cancer screening. Our comments on key issues of interest to
oncology nurses and the cancer patients we serve are discussed below.
The recommendations are based on an extensive analysis of the evidence. Implementation of the recommendations
would result in a movement toward less frequent and less invasive colorectal cancer screening options. ONS views this
as a positive change, given the gap that still exists in the percent of eligible individuals who participate in screening and
the identification that adherence with non-invasive strategies is better. Although there is no direct information in this
evidence review regarding patient preferences, differences noted in adherence rates suggest that individuals prefer noninvasive screening methods.
ONS supports the USPSTF’s recommendations, and would like to provide USPSTF with the following suggestions.

The evidence review identifies a number of areas for ongoing research. In addition to those identified, it would
be helpful if future work enabled a better understanding of risk-based strategy use and effectiveness,
consideration of the impact of screening methods on all-cause mortality as well as colorectal cancer mortality,
and direct head to head comparisons of the screening strategies recommended.

The recommendation and rationale for screening every 10 years for individuals aged 50 - 75 years (exclusive of
those with positive family histories) is consistent with current screening recommendations from other
organizations. However, given life expectancies, it is not clear why the recommendations do not consider
individuals over the age of 85. The recommendation of weighing benefits vs. harms of screening aged 76-85
years (exclusive of those with positive family histories) recognizes that patient values and overall health status
are key variables in determining the benefits of screening in this age bracket. This recommendation
acknowledges that data regarding screening past age 74 is scarce, but that data models consistently predict the
relatively few additional life years gained with screening past age 75 in average-risk people. Given the improved
overall survival of many septuagenarians without significant comorbidities, it seems feasible that those 76-84 in
good health should be encouraged to consider screening. Therefore, ONS suggests that recommendations be
directed toward the population aged 75 and above.

Additionally, it is important that these recommendations, which show essentially equivalent alternative
strategies for colorectal cancer screening, be well communicated to the public. As colonoscopy is still often
suggested by health care providers as the only screening method, the public needs to clearly know that there
are viable non-invasive alternatives available to them.
*****
We thank you for your commitment to improving the health of all Americans by making evidence-based
recommendations about clinical prevention services. We would be happy to discuss ways in which ONS may be of
assistance to USPSTF, and would encourage you to contact Alec Stone, MA, MPA, Director of Health Policy, at
[email protected] to coordinate a time to discuss our concerns and collaborate on potential solutions. We look
forward to engaging in an ongoing dialogue to address issues of importance to cancer patients.
Sincerely,
The Oncology Nursing Society