Comment Letter to USPSTF on Lancet Study

August 14, 2015

Albert L. Siu, M.D.. M.S.P.H.
United States Preventive Services Task Force
540 Gaither Road
Rockville, MD 20850

Dear Chairman Siu:

The Medical Imaging & Technology Alliance (MITA) would like to draw your attention to a recently published study in The Lancet titled “Effect of mammographic screening from age 40 years on breast cancer mortality in the UK Age trial at 17 years’ follow-up: a randomised controlled trial.”

While this study was published after the opportunity for public comment closed on the recently issued United States Preventive Services Task Force (USPSTF) Draft Recommendation Statement on breast cancer screening, we strongly urge you to take it into consideration due to the fact that it clearly and conclusively demonstrates that mammography reduces mortality for women younger than age 50.

You are already familiar with some of this data as it was an input into the Draft Recommendation Statement. What was not taken into consideration, however, was the conclusion drawn from this data: “[The] results support an early reduction in mortality from breast cancer with annual mammography screening in women aged 40–49 years.”

In light of this significant new study, we urge you to not finalize your Draft Recommendation Statement and fully take this new evidence into account. Your recommendations, if finalized as drafted, would assign a C grade to screening mammography for women ages 40 to 49 years. This would potentially strip these women of the ability to receive screening mammography from their insurance provider without cost sharing.

It is our concern that these recommendations would lead to reduced breast cancer screening and, therefore, a greater incidence of breast cancer, particularly in women ages 40 to 49. Breast cancer accounts for 40,000 deaths every year in the United States and has a devastatingly low survival rate when not detected early. Annual screening mammograms allow for tumors to be detected earlier when they are more treatable.

Early and accurate detection of tumors is the most effective way to extend and improve the lives of women with breast cancer. By shifting the age of initial mammogram from 40 to 50 years, many tumors will go undetected until they have increased in size, metastasized, or become symptomatic. This will lead to more lives lost and lower quality of life due to more intense treatment for women whose tumors are detected later.

Further, given that the majority of women ages 40 to 49 years have at least one risk factor associated with a greater chance of developing breast cancer, MITA again urges the USPSTF to recommend that all women in this age group receive annual screening mammograms.

It is your duty to fully consider the available evidence when assigning a grade to a preventive service. In light of this new study, you should rescind your Draft Recommendation Statement and take into account this new research which shows that mammography saves the lives of women ages 40-49.

* * * *

We would be pleased to answer any questions you might have about these comments. Please contact me at (703) 841-3238 if MITA can be of any assistance.


Peter M. Weems
Director of Policy, MITA

cc: Senator Kelly Ayotte (R-NH)
Senator Barbara Mikulski (D-MD)
Representative Renee Ellmers (R-NC-2)
Representative Debbie Wasserman Schultz (D-FL-23)