Transcript des Epigenomics AG Calls aufgrund der 'Preliminary CMS decision' am 20.10.2020 Teil 2
Operator
[Operator Instructions] And the first question comes from Mr. Dennis Berzhanin from Pareto Securities.
Dennis Berzhanin
Dennis Berzhanin from Pareto Securities. Just a couple of questions from me. Number one, could you provide some color why CMS did not consider the microsimulation models despite the expectation that it would? Have they provided any feedback as of the rationale? And why they haven't looked at the adherence at all?
And then also, it looks like one of CMS requirements is for inclusion into professional society or guidelines. Is this something that you would still have to do? Or is there a possibility to avoid this requirement?
Gregory Hamilton
Okay. Yes, we have discussed this issue with CMS in regards to why did they ignore all of the microsimulation model data when that is the gold standard there -- where we're at is they acknowledge that, and that will be a major talking point during the comment period. We can't go into any more detail about it. But clearly, that is just an underlying theme that is a major, major driver in our goal to, in essence, turn this around and get coverage.
Because at the end of the day, the clinical data is there, and it needs to be part of the conversation. So we are doing everything possible to make that happen. In regards to the guideline requirement, this is something that is inconsistent with previous approval. So Cologuard was when it was approved, it was not required to be in a guideline nor was it in a guideline when it was approved. So that is something else we will discuss with CMS.
The reality is that in the latest version of the NCCN guideline, we were included in there for patients who refuse other screening modalities, and that is aligned with our FDA label. So we do believe we meet a requirement of a professional guideline. The language needs to be tweaked in the NCD for that, but we do believe we meet that. And then in addition, we believe with the microsimulation data published by the Sisnet Group, that is the input for all future guidelines, so the next USPSTF decisions utilize those models. That's how they make their decisions. So we also feel confident about upcoming guidelines as well.
Dennis Berzhanin
Okay. Just a quick follow-up. Could you just talk a little bit more about the process? What are some of the steps there? And historically speaking, how often have these appeals been successful?
Gregory Hamilton
Well, in general, Dennis, just so you know, most NCDs are positive anyways. It's actually pretty rare to getting negative NCD. So in the end, I mean, we still got to get to the final NCD. This is only proposed. So for example, as we discussed in the presentation, the CAR-T proposed NCD was considered negative by most people. And that coverage would only be given to patients who enrolled in a CMS approved study.
So basically, people would be denied therapy unless they enrolled in a trial. That was a major shift at the end to -- basically, they covered that therapy for all patients with that medical indication. So we do believe we have a fighting chance to get the switch. Now once it goes final, if it's still negative, then there is an appeal process. The first is a departmental appeal process. And then the second is a formal appeal process, what's called reconsideration. That reconsideration process takes longer. Typically, you can be looking at time lines of about a year for appeal.
People who have been shareholders for a long time will remember, in essence, we had to do the same appeal process for the rate. We initially were given a rate of $83 from CMS. We went through the appeal process and ultimately one and got a rate of $192. It took a while, but in the end, we were successful. So as we want to be realistic with everyone, the NCD process in this 90 days is challenging. But at the end of the day, we feel that the evidence is on our side and that it is inappropriate for Medicare to ignore the gold standard on that evidence. And if we think if we can get over that hurdle, it changes the entire complexion of the conversation.
Operator
The next question comes from Mr. Simon Scholes from First Berland.
Simon Scholes
So -- I mean my information is that CMS used microsimulation studies to evaluate FIT, Cologuard and CT colonography. So -- and I share your astonishment that they haven't -- they don't deem it a FIT method for use with Epi proColon. I mean did CMS give any indication of their aversion to microsimulation studies with regard to Epi proColon when you met them in March for the consultation?
Gregory Hamilton
I mean, absolutely not. I mean, that's why we're in shock. And I mean the reality is CMS has commissioned microsimulation to do various analysis for CRC screening methods. So actually, members of that group are authors on microsimulation model papers. So it's again incomprehensible. It's been a very, very challenging 72 hours as we've digested this NCD. Because at the end of the day, Cologuard did not have any direct or indirect outcome data when it got approved. We actually haven't we actually have data that shows Epi proColon reduces mortality in an independent, scientifically validated peer-reviewed publication. That day didn't even exist for Cologuard and Cologuard got approval. And we are currently recommended for noncoverage.
So like I said, we are not going to stand on the sidelines here. We are going to challenge this with everything we have. And at the end of the day, we believe we will be successful. It will be challenging. The process is not one that is transparent as anyone would like. But it's one that we just have to follow.
Simon Scholes
Okay. And I mean, presumably, you'll make your response to CMS public.
Gregory Hamilton
Yes, we will do a response in the public comment period, but we are also encouraging all supporters of evidence-based decisions to comment as well in the public comment period on the CMS website.
Simon Scholes
Okay. And I mean, you said that -- you said just now that by far the majority of NCDs are positive. I know you mentioned this CAR-T case. I mean, is that the only -- I mean, how many cases have been -- how many negative decisions have there been?
Gregory Hamilton
I mean I don't know the specific number, but they're pretty rare. I mean you got to remember, for them to even accept and open the NCD, they have to believe there's a reasonable amount of evidence for coverage. So that's the criteria for them to even accept it and open it. So again, it's hard for us to express how shocked we were not only based on the strong body of evidence that we do have. But our interactions previously with CMS and walking them through the data, I mean, we -- they are fully aware of the Harvard data. The NCI data came out, obviously, very late in the process. It came out in August. So maybe that's one of the reasons why it wasn't in the proposed, but hopefully...
Simon Scholes
I mean, they also say that they only consider documents up to February.
Gregory Hamilton
Yes. I mean, they said that, but for some reason, they listed the JNCI paper from August in the But again, did not reference it anywhere in the decision. So it's challenging for us to rationalize how that could happen, but it's our job right now to try and get that fixed.
Simon Scholes
Yes. As I said thing is that they seem to gage their methodology, and they use microsims for all the other tests, but not for you?
Gregory Hamilton
Yes.
Simon Scholes
That is
Jorge Garces
Hello, can you hear me?
Gregory Hamilton
Yes, Jorge, we can hear you.
Jorge Garces
Yes, this is Jorge. I just want to clarify. So the NCD proposal is actually positive and that they say they will cover blood-based CRC screening. However, the criteria that they set in order for them to cover the blood test, led to noncoverage for our test of Epi proColon. So we're not trying to flip a negative NCD to a positive. We're trying to modify the criteria so that Epi proColon can get coverage. So it's a positive NCD, and we're pushing to change the criteria so that it would lead to coverage of Epi proColon. So I just want to make sure everybody is clear on that.
Operator
The next question comes from Hogan Mulally from Encode IDS.
Hogan Mullally
You obviously have some powerful competition out there with Exact Sciences, Freenome and Guardant. This sort of arbitrary 74% sensitivity, 90% specificity that CMS has put in the proposed decision memo. To the best of your knowledge of your competitors out there, can any of them achieve this sensitivity, specificity bar based on the liquid biopsy data they've generated thus far?
Gregory Hamilton
Hogan, it's unknown. The data that's been presented so far by Freenome and Guardant has all been kind of case-control data that, as we know, can vary pretty substantially between that and prospective trial data. So so we don't know. I mean, their initial data that they presented, yes, clearly would meet these hurdles. But also got to remember that those tests are designed on sequencing machines and are going to be very, very expensive. So they need a 3-year interval. So the only way that they actually can work is if they have a sensitivity level and a specificity level that would justify a 3-year interval.
So meaning, the key to this disease state is the sensitivity, specificity interval, all work together to, in essence, determine whether a -- the assay works. So for lower sensitivity assays, they're extremely effective, but the interval needs to be more frequent, hence, FIT is every year. The optimal interval for our test in both the Harvard and the NCI papers a year, right? And both of those show that each of our tests is more effective FIT and Septin9 is more effective, for example, than Cologuard at a 92% sensitivity because Cologuard is 3-year interval.
So again, we are encouraging CMS not to issue an incredibly dangerous precedent of just cherry picking random numbers from various tests and inferring it somehow that's going to lead to reduced mortality. So in the end, they need to make decisions based upon evidence, not upon cherry picking.
Hogan Mullally
Right. I guess I'm just sort of curious -- sorry, go ahead, Jorge.
Jorge Garces
No. If we could refer to Slide 6 in the presentation where we look at the number of deaths, Greg, I don't know if you could project that. Yes. So Hogan, if you can look at the slide, I want to make sure the message wasn't missed. So the orange bar would be kind of the -- a test with the performance that Medicare is suggesting is acceptable. So 74% sensitivity, 90% specificity done every 3 years. And here, the number of deaths that are averted with -- would would be averted with such it has. One bar above it is Epi proColon done every year. And you can see that our tests with our clinical performance parameters performed every year is expected to do much, much better at averting a lot more deaths for patients.
In fact, Cologuard and FIT every year would be better than that test. So they're proposing actually a task that would be inferior in terms of outcomes, even though it's 74% sensitive, 90% specific. So again, the clinical performance alone does not measure what the clinical outcomes are going to be. So as Greg said, this is a dangerous precedent because they're pushing for an inferior outcome for patients over what Epi proColon could provide.
Hogan Mullally
Right. I guess where I would start leading with this is that the -- it almost seems like CMS is foreshadowing a test that they want to approve as opposed to looking at the evidence in its totality for Epi proColon. It almost looks like the large muscular competitors out there have created a bar or influenced a bar, which is rather arbitrary. I know that's a leading question. I won't ask you to sort of opine on that per se, but it certainly is a decision by CMS and it just looks like the bigger players here have had some influence as far as the levels of sensitivity, specificity that are thrown out by CMS.
Jorge Garces
Yes, Hogan, I mean, obviously, that would be challenging for us to confirm or not. I mean -- so all we can go on is what they've written in the proposed NCD. And clearly, what they've written, we just know to be categorically false. So we just have to move forward with what's in front of us and bring enough eyeballs and people to the table to for CMS to make decisions based upon clinical and scientific evidence. And to your point, not some theoretical assay that doesn't exist, and quite honestly, clearly wouldn't even work.
Operator
Next question comes from Mr. Bruce Jackson from The Benchmark Mark Company.
Bruce Jackson
So you're still FDA approved. You've done a fair amount of work with HMOs like Geisinger. Is there anything to prevent in HMO or a commercial plan from running the Septin9 test as part of a colon cancer screening option?
Gregory Hamilton
Bruce, yes, no, there's not. I mean -- but the realistic challenge here is that Medicare is the dominant payer in this space, about 40% of the available population is Medicare. So what you've seen historically is all of the other payers, commercial, et cetera, look to Medicare to be the first mover. So if you look at Cologuard, I mean Cologuard was launched successfully because they got FDA approval and 2 months later, they got Medicare approval.
And then after that, then the commercial payer started lining up. And that took a bit of time after Medicare did it. But if you look at the initial days of Cologuard. I mean, I think they announced that typically, they were like 60% to 65% of their samples in their first couple of years were Medicare simple. So it is challenging for commercial payers to lead in this space when Medicare is the dominant player. And ultimately, they're seen as the leader because the average onset of this disease is actually at 67. So when patients are Medicare age.
So Medicare is more incentivized than anybody to increase screening rates and reduce the burden of this disease. So that's why they play such an important role. And this NCD is -- that's why it's so critical to us to get it because it really then is the launching pad to commercialize then across the entire payer spectrum.
Operator
The next question is Mr. Randy Baron from Pinnacle.
Randy Baron
You mentioned that you spoke to Medicare. I'd be curious to get a little more color on the conversation that they had in terms of what seems to the previous questioner's point about arbitrary kind of picking and choosing is it? And then by them referencing the that August study, did they just come out and say we didn't consider? I just want to get a little more color on the conversation. And then in terms of the open comment period, I mean, this has a lot of ramifications almost beyond CRC. Do you think you'll get more open comments in this next month than you did in the initial ones?
Gregory Hamilton
Well, Randy, I mean, first of all, in the comment period, I mean, the initial comment period, I mean, even CMS and the proposed decision acknowledged that a vast, vast majority of the comments were positive. And so we are fully expecting a very active comment period because, yes, we are in agreement with you that the precedent that CMS is setting here could be very dangerous. And so we are highly encouraging people to get involved and to support the clinical and scientific evidence. And so we do believe that there is an opportunity to get this moved. I mean CMS made it very clear to us. This is only a proposal. And I think the more attention we can bring to the fact that they just made an absolute statement that no direct or indirect evidence exists for the reduction in mortality of the disease is just completely false.
Now if CMS says they want to ultimately ignore that data for some reason, then they should have to come out and justify why that is that they will now want to ignore microsimulation modeling data when they've used that as a standard throughout their history. So we believe that it's going to be a very active 90 days. And ultimately, we do believe there's a path forward for us to get the positive decision.
Now that said, we are realistic that it is going to be challenging, right, that it is -- this is not easy. But again, at the end of the day, we feel confident that it is very hard to ignore the -- one of the graphs we showed on this presentation from the NCI experts that says Epi proColon works, and it works really well.
Randy Baron
Yes. There's no doubt, this is not a logical decision. What is the exact date for 90 days out? And then related to that, let's just drill into the strategic review a little bit. Obviously, you have less than a year of cash. I just love a little more color into timing when you think kind of the next potential strategic decision could be? Is it going to be before that 90 days? Is it -- to a previous questioner, it certainly seems like some of the bigger players in the space through some political weight around? You have basically the future of testing. So what happens if they come and knock on the door at a high level?
Gregory Hamilton
Yes. So Randy, I mean, we have to face the reality that we are a micro-cap company who is basically banging down the door of a space that is dominated by only companies that are worth billions of dollars and have raised either billions or hundreds of millions to be into this space. And so in regards to the strategic options, we can't go into too many details other than the fact of the matter is that our balance sheet requires us to do that right now.
We have to create as much value for shareholders as possible. And the fact of the matter is that we do not have the balance sheet to withstand, go through and potentially a negative final decision and then go through an appeal. We don't have enough cash to last that long. So this negative decision or proposed decision forces us to look at all strategic alternatives.
Now ultimately, we want to flip this and in 90 days, get a positive coverage decision for Epi proColon. And then the outcome can be very different, but we have to look at all strategic alternatives right now.
Randy Baron
I totally agree with that. But as a shareholder, I would just encourage you if this ends up being some sort of negotiating ploy by one of the bigger players to at least carve out some sort of contingent value right, so that if you do a strategic decision in the next 89 days, existing shareholders benefit as well from the overturning of an decision?
Gregory Hamilton
Yes. No. And Randy, we are in complete alignment that we are going to look at doing whatever we can to maximize the shareholder value for all of us.
Operator
[Operator Instructions] So the next question comes from Mr. Dennis Berzhanin from Pareto Securities.
Dennis Berzhanin
Greg, just a couple of follow-up questions. I want to ask, given all the challenges with Epi proColon, I know you've had some other tests in the pipeline to just deliver cancer test. Is it possible to given some of the positive data in the past, maybe focus on of your efforts of getting that? And then also, I appreciate the situation, the clarity about the funding situation. It appears to me that you won't actually have enough funding to get you through the entire the appeal process and so forth. So could you just confirm when exactly you actually need to raise cash by when?
Gregory Hamilton
Yes. Thank you, Dennis. So first off, what I would say is we've been very clear that we have enough liquidity to get through Q1 2021. So as we evaluate all strategic alternatives, capital -- raising capital is part of those strategic alternatives because we need to look at that as well. So hopefully, that answers the question.
And then what was the other part of your question, Dennis?
Dennis Berzhanin
Yes. Just wondering if it was possible at all to -- given challenges Epi proColon to maybe focus or rejuvenate your efforts again with the other tests in the pipeline such as the deliver cancer test, given the positive data you had in the past?
Gregory Hamilton
Yes. So right -- so the reality is that we don't feel any of the value of our pipeline is reflected in our stock nor the 300 granted or applied for patents we have in epigenetic markers, et cetera. And considering liquid biopsy is such a hot space, we have a lot of IP in this area. So the challenge is that, clearly, we do not have the capital resources to take those those assays that we have in development to the next level. They're there. The data looks very promising, as we've talked about and have published to date, and we have other publications that we believe are coming out, hopefully, in the near future.
But as you know, publications are hard to estimate when they come out. So ultimately, there is additional value, we believe in the organization that is not reflected in our stock price at this time. But as we look at strategic alternatives, part of is to, in essence, unlock that value so that shareholders can realize that value.