See the attached response document from the Washington State Urology Society.

•Quality measures must demonstrate appropriate consideration of severity, complexity, appropriate indications and outcomes.
•The proposed "Non-Recommended PSA-Based Screening" measure discourages PSA screening in all men over age 18, with the exception of an insufficiently narrow range of risk factors.
•Exceptions for this recommendation should include additional factors, including: ethnicity, family history, and testosterone supplementation.
•The methodology of determining quality measures should include input from experts in the pathophysiology of the disease state.
•Mathematica Policy Research has insufficient specialty expertise in prostate cancer diagnosis and treatment, and like the USPSTF, does not solicit specialty society input before making their recommendations public.
•The clinical value of prostate cancer screening across a broad age range has been scientifically validated and endorsed by the American Urological Association, American Cancer Society, National Comprehensive Cancer Network, American Society of Clinical Oncology and American College of Physicians-American Society of Internal Medicine.
•CMS must not implement quality measures and screenings recommendations derived without input from medical expertise that is relevant to the disease state or health condition.