Biogen, Inc. (Biogen) appreciates the opportunity to comment on the proposed national coverage determination (NCD) for monoclonal antibodies directed against amyloid for the treatment of Alzheimer's disease (CAG-00460N).1

The introduction of amyloid-directed monoclonal antibody therapies (mAbs) heralds a new, exciting era for the Alzheimer's disease community. The Food and Drug Administration's (FDA's) approval of ADUHELM (aducanumab-avwa) is the first approval in almost two decades of a new treatment for Alzheimer's disease. ADUHELM provides a first-ever option to treat the underlying pathology of this disease, and we are committed to constructively engaging with the Centers for Medicare & Medicaid Services (CMS) to ensure appropriate access for patients to this novel FDA-approved therapy and others that may follow. As is the case with any new medical innovation, we agree that ongoing data generation should continue to characterize the benefit-risk profile for this class of therapies. Specifically, we agree that there is a need for large scale real-world data generation to answer questions about efficacy and safety of amyloid-directed mAbs outside of a randomized controlled trial (RCT).

Contact:

Phone: 781-464-2000

WEB: www.biogen.com

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