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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