Cable Car Capital LLC ("Cable Car") is a limited liability company with principal place of business in San Francisco, California. Cable Car is registered as an investment adviser with the state of California and may be required to register in other jurisdictions where it does business in the future. Registration with the Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. This website is intended only for persons in jurisdictions where Cable Car is authorized to provide investment advice, and no content should be construed as an offer to provide investment advisory services in any location where such offer would be unlawful. Moreover, provision of information about Cable Car's services does not constitute an offer to provide investment advisory services. Such offer can be made only by means of a written advisory agreement. No content herein should be viewed as advice regarding the value of any securities or the advisability of investing in, purchasing, or selling securities. In particular, Cable Car is the General Partner of The Funicular Fund, LP, a private fund. Interests in The Funicular Fund, LP and the feeder fund, The Funicular Fund (BVI), Ltd. are available only to accredited investors. Cable Car may from time to time publish research reports with the aim of receiving feedback from the broader investment community. Published material in written reports and on the blog is not intended to be investment advice and should under no circumstance be considered a recommendation to take action with respect to any security or commodity interest. Cable Car, its principals, and its clients may hold positions, long or short, in such securities or commodity interests, and Cable Car may trade without informing readers. Investing involves risks and may result in the loss of some or all of the principal invested. Before investing, prospective clients should consider their investment objectives and the costs and risks associated with Cable Car's investment program. Investments are not FDIC insured and may lose value. Past performance may not be indicative of future results. The material on this website should be read only in conjunction with the disclosures in Cable Car's Brochure on Form ADV.
Disclosure: No position in EXAS.
This month’s draft recommendation by the United States Preventative Services Task Force on colorectal cancer screening was deeply validating. The task force highlighted the specificity reduction introduced by combining FIT with a diagnostic DNA assay, a point emphasized by many market participants and independent observers over the years. Cable Car submitted comments supporting the task force’s recommendation.
I will have more to say about the impact on Exact Sciences and Cable Car’s positioning in the forthcoming third quarter investor letter.
In the meantime, I had one more public comment to research and submit first. Cable Car’s final public comment on the reconsideration request, which was preliminarily denied in August, is now available. The comment is styled as a compromise and follows an enlightening conversation with the staff at CMS regarding their constraints.
Cable Car has advanced a new crosswalk proposal: 82274 (FIT) + 81275 (KRAS) + 81288 (MLH1 methylation). As a diagnostic assay that is explicitly excluded from reimbursement for screening purposes, KRAS still has no business in the crosswalk, in my opinion. However, it appears Exact Sciences is going to get away with its clever exploitation of policy, which makes it virtually impossible to argue on methodological grounds that a KRAS assay is not a KRAS assay. This is no different from the old abuses of “code stacking” and is one of the many shortcomings of the current process the new PAMA procedure will seek to address. 81288 is a far better comparator for the methylation assay than any previous proposal, but it was only recently priced through the gapfill process.
I am hopeful that at this point in the process CMS will still be able to give the compromise crosswalk its full consideration.
Read the comment letter.