Assessment of Scientific Information for the Radiation Exposure Screening and Education Program: Interim Report (2003)

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APPENDIX A 23 APPENDIX A Comments on Methods Proposed by HRSA and its Grantees COMMENTS ON BPHC POLICY INFORMATION NOTICE 2002–17 General Comments These comments were developed during this review and are not intended to be exclusive. 1. This is an effort to be responsive to the RECA legislation that would be more appropriately couched in terms of a good and cost-effective health-care program (rather than in terms of a screening program, which would have the potential to do more harm than good) that offers an initial comprehensive medical evaluation to establish baseline data for individuals, many of whom now are likely to be in the older age groups and who live in medically underserved communities. 2. Cancer of the female breast is the only one of the conditions identified as “radiogenic” for which there is a proven effective screening mode, and even that is useful only for defined “at-risk” population groups. 3. Given that none of the conditions identified (in the BPHC Policy Information Notice) is causally associated exclusively with radiation, the categorization of “For Non-Malignant Radiogenic Diseases” (2a) and “For Malignant Radiogenic Diseases” (2b) for the purposes of the Notice is inappropriate, is unnecessary, and could be misconstrued as implying that all such conditions that may be detected in the proposed “screening” program unquestionably would be attributable to exposure to radiation during one of the RECA events or activities specified. “Non-malignat compensable disease” and “malignant compensable diseases” would be a more appropriate categorization. 4. Clinical tests and procedures should be based on findings in the individual consistent with good medical practice, and follow-up should be scheduled in accordance with good medical practice, irrespective of exposure history. 5. Presumably, RECA covers the cost of “screening” for the specified diseases and for any indicated medical follow-up, treatment, and care for compensable diseases or conditions. But what happens if a participant has a coincidental diagnosis (as the result of the screening process) of a noncovered disease or condition and is uninsured or otherwise unable to pay for further recommended testing, treatment, and so on. What is the responsibility (including ethical) of the program to manage or treat the person in such a situation? Is the possibility of such a coincidental diagnosis and its potential consequences explained to the person?