March Is Colorectal Cancer Awareness Month: Why CMS’s Proposed NCD 210.3 Update Could Accelerate Patient‑Centered Screening Access

Colorectal cancer (CRC) screening saves lives, but only when patients are able to access care in a way that meets their personal needs. Every March, CRC awareness month blue ribbons remind us that prevention and early detection are among the most powerful tools we have in public health today. It is also an ideal moment to examine whether coverage policy is keeping pace with the realities of patient behavior, clinical workflow, and diagnostics innovation.

On March 10, 2026, the Centers for Medicare & Medicaid Services (CMS) released a proposed decision memo to update National Coverage Determination (NCD) 210.3 for colorectal cancer screening tests, kicking off a 30‑day public comment period running from March 10 through April 9, 2026. The proposal focuses on non‑invasive biomarker tests and signals a potentially important evolution in how Medicare approaches coverage for newer screening modalities that could meaningfully impact patients if implemented thoughtfully.

The patient imperative: screening works, but access and follow‑through can lag

CRC remains a major burden in the United States, with nearly 159,000 new cases projected in 2026¹. At the same time, incidence and mortality trends among adults under 65 continue to raise concern, reinforcing the need for screening pathways that align with how patients actually engage with care. Clinical guidelines are only effective if patients are willing and able to complete screening.

In reality, barriers such as procedure aversion or wait times, limited access to specialists, work time constraints, transportation challenges, and continued uncertainty around insurance coverage continue to affect screening uptake. These barriers disproportionately affect patients in underserved communities and those who get most of their care in primary care settings. Non‑invasive screening modalities are not just a matter of convenience. For many patients, they represent the difference between getting screened or simply opting out.

What CMS is signaling in the proposed NCD 210.3 update

I see several signals embedded in CMS’s proposed decision memo point toward a more patient‑centered approach to screening access.

First, CMS understands that CRC screening occurs at the point of care, often in primary care settings, by including physicians as well as advanced practice providers such as nurse practitioners, physician assistants, and clinical nurse specialists as appropriate ordering clinicians. For patients, broader ordering authority creates more opportunities to initiate screening during routine visits and fewer delays caused by unnecessary handoffs.

Second, CMS appears to be moving away from a test‑by‑test coverage framework toward category‑based coverage grounded in performance criteria. This shift has important patient implications. Category‑based coverage can reduce future “access friction” by enabling validated technologies to reach patients more efficiently once evidence standards are met, vs. requiring repeated policy reconsiderations for each new test that enters the market.

Third, CMS reinforces that evidence, not novelty, drives coverage. FDA authorization alone will not guarantee access. Clinical validity, cancer stage‑specific performance, and relevance to the Medicare population remain central to coverage determinations. This continued emphasis helps ensure that expanded access does not come at the expense of clinical rigor or lead to inappropriate downstream patient care.

Finally, CMS’s proposal is consistent around key guardrails, including screening intervals, average‑risk definitions, and preventive intent. Screening policy predictability matters for patients and healthcare providers alike, as confusion or inconsistency about what screenings are “covered” can become an invisible barrier to screening completion.

Why reimbursement strategy is a good patient strategy

Diagnostics reimbursement is often framed as a commercial consideration, but it is one of the strongest determinants of patient access. When evidence generation, coverage narratives, coding strategy, and payer engagement are misaligned, the consequences are felt by the patients through the possibility of claim denials, prior authorization burden, and delayed or abandoned screening.

The proposed NCD 210.3 update underscores a critical reality for diagnostics innovators and laboratories: coverage is earned through thoughtful alignment with payer expectations, not just via regulatory clearance. Evidence strategies that anticipate CMS requirements and real‑world utilization are essential to ensuring that screening innovations translate into a meaningful patient benefit.

From a patient perspective, successful access strategies share common features. Optimal screening options align with patient preferences and practicalities of real life. Coverage criteria are clear, consistently implemented, and well understood, minimizing uncertainty and financial surprises. Clinical workflows at point-of-care support appropriate follow‑up and referral to a specialist when needed, so that screening leads to timely diagnosis and intervention.

How ADVI helps diagnostics innovators translate policy into patient access

ADVIs’ work in laboratory reimbursement and commercial strategy is grounded in a patient‑first mindset…innovation only matters if patients can access it. As CMS continues shifting toward performance‑based, category‑oriented coverage frameworks, laboratories and diagnostics innovators face both opportunity and responsibility.

ADVIs Precision Medicine Solution helps translate evolving CMS policy signals into actionable access roadmaps. This includes designing evidence strategies that anticipate coverage requirements, aligning coding and pricing approaches to reduce access friction, and supporting payer and policy engagement during critical windows such as public comment periods. By engaging with ADVI on reimbursement strategy early, innovators can shorten the path between clinical validation and real‑world patient access.

It’s always a perfect time for a timely call to action

Colorectal Cancer Awareness Month is about more than education and raising awareness; it is about breaking down barriers between patients and their ability to receive potentially life‑saving screening. CMS’s current public comment period represents an important opportunity for stakeholders across the healthcare ecosystem to help shape coverage policy in ways that preserve clinical rigor while improving real‑world access.

The most constructive engagement will focus on ensuring that evidence standards remain high, ordering pathways reflect real‑world care delivery during a time of ever tightening healthcare resources, and coverage rules help minimize avoidable friction for patients.

References:

1. American Cancer Society. Colorectal Cancer Statistics | How Common Is Colorectal Cancer? www.cancer.org. Published 2023.

---

Stacey Gilbert, MPH, MBA
Director, Precision Medicine