The American Association of Diabetes Educators filed public comments on proposals by the Centers for Medicare & Medicaid Services (CMS) to cover prediabetes education via a Medicare Diabetes Prevention Program (MDPP) and to expand utilization of the diabetes self-management training (DSMT) benefit. Both proposals were released in the July 2016 Physician Fee Schedule (PFS).

AADE is one of two National Accredited Organizations approved by CMS to certify DSMT programs for Medicare, and is one of six organizations under a cooperative agreement with the Centers for Disease Control and Prevention (CDC) to scale and sustain the National Diabetes Prevention Program (National DPP). This makes AADE uniquely qualified to comment on both these areas.

Expansion of Medicare to include Diabetes Prevention

Based on the successful clinical outcomes, AADE fully supports coverage of the National DPP for the Medicare population. In its comments, AADE asked CMS to consider the following:

1. Increase the number of high-quality MDPP suppliers.
2. Modify the MDPP reimbursement structure.
3. Ensure quality program delivery and staffing requirement considerations.
4. Increase outreach to potential and current DPP participants with diagnosed diabetes.
5. Modify MDPP session duration guidance.

Increased Access to DSMT

AADE is encouraged that CMS recognizes that the DSMT benefit is significantly underutilized, adding to the overall costs of treating diabetes and the associated complications as a result of uncontrolled diabetes. AADE believes that modifications to the proposed rule that would increase DSMT utilization and remove barriers to access and referrals are essential.

AADE asked that CMS consider the following to improve access to this benefit:

1. Eliminate out of pocket expenses for participants, such as the copayment and deductible for DSMT. 
2. Increase Medicare payment for billing codes G0108 and G0109.
3. Allow eligibility for additional DSMT hours when change in medical condition warrants additional education, i.e. similar to the Medical Nutrition Therapy benefit.
4. Adhere to American Diabetes Association and American Association of Clinical Endocrinologists guidelines and include A1C as one of the criteria for the diagnosis of diabetes.
5. Allow hospital-accredited DSMT programs to provide DSMT in off-site locations more convenient to participants.  
6. Allow for self-referral or expand who can refer for DSMT.

The letter was signed by Charles MacFarlane, Chief Executive Officer; Leslie E. Kolb, RN, BSN, MBA, Vice President of Science and Practice; and Joanna Craver, BS, MNM, Director of Prevention.

Read the comments in full: www.diabeteseducator.org/cms-comment