The Medicare telehealth landscape has changed dramatically in response to COVID-19. Congress and the Administration have worked together to enact a series of laws and regulations waiving many of the existing statutory and regulatory restrictions around providing healthcare services remotely or via telehealth. As these changes were taking shape, ADCES began working with its members, partner organizations, coalitions, congressional champions, and contacts at the Centers for Medicare & Medicaid Services (CMS) to ensure that people with diabetes continue to have access to the services, devices, and supplies they need to self-manage their diabetes during the COVID-19 pandemic. ADCES took immediate action, advocating before CMS and Congress to relax the regulations and requirements around diabetes care.
Diabetes care and education specialists sent close to 700 letters to CMS requesting that the agency immediately allow all DSMT providers, including registered nurses (RNs) and pharmacists, to furnish DSMT via telehealth. ADCES joined its coalition partners like the Diabetes Advocacy Alliance, the Diabetes Technology Coalition, and the Health Innovation Alliance to address critical access issues for people with diabetes. Our Senate champions sent letters to CMS expressing their support for these proposed changes.
As a result of these advocacy efforts, CMS waived a number of existing telehealth and regulatory requirements for DSMT and diabetes technologies. These changes are in effect for the duration of the COVID-19 public health emergency (PHE). A summary of those changes as of 5/8/20 is below.
- CMS is allowing all of the initial 10 hours of DSMT to be provided one-on-one either in-person or via telehealth.
- DSMT is one of only a limited number of telehealth services that can be provided via audio only, in cases when audio and video telecommunications technology is not available.
- CMS waived geographic and originating site requirements to allow eligible diabetes care and education specialists to provide services to a beneficiary in the beneficiary’s home. Providers may also provide services from their homes in many cases.
- CMS addressed issues in the hospital outpatient setting to allow clinical staff, including RNs and pharmacists, to furnish DSMT to a beneficiary in the beneficiary’s home. This was critical as traditionally RNs and pharmacists have not been eligible to furnish services via telehealth.
- CMS provided a mechanism for providers in a hospital outpatient setting to bill for services remotely. This addressed billing limitations on the UB-04 (CMS 1450 form) that created barriers to providing care.
- CMS released guidance allowing all DSMT providers to furnish DSMT via telehealth in Federally Qualified Health Centers and Rural Health Centers.
- CMS waived in-person requirements for continuous glucose monitors (CGM) and insulin pumps so that people with diabetes could continue to get necessary supplies without having to have an in-person appointment with their healthcare provider.
- CMS announced they will not be enforcing the clinical indications for CGM.
- The U.S. Food and Drug Administration (FDA) issued emergency use authorization for some CGM devices to be used in hospital settings.
To learn more about these changes and how they affect your practice, please review ADCES’ updated COVID-19 and Telehealth FAQ here. ADCES has also posted our latest Q&A session here.
Despite these advancements, our advocacy work is not done. ADCES continues to seek clarity and resolution in the following areas:
- As DSMT programs bill as an entity rather than at the individual provider level, ADCES wants to confirm that DSMT programs, eligible to Medicare Part B, are considered distant site practitioners approved to furnish telehealth services. This is in line with the rationale provided in the IFC and the updated blanket waiver.
- For calendar year 2020, waive the requirement that the initial 10 hours of DSMT training must be furnished within a continuous 12-month period. Currently, many Medicare beneficiaries have been unable to participate in DSMT and have already lost valuable time in utilizing their full DSMT benefit within the calendar year, especially those that have reached the end of this 12 month period since COVID-19 began.
- ADCES also continues to advance the Expanding Access to DSMT Act (H.R. 1840, S. 814), which addresses additional barriers that Medicare beneficiaries face when accessing DSMT.
ADCES is working to ensure that the changes achieved during the pandemic, are sustained. We cannot “unlearn” the lessons learned during this unprecedented time. The widespread use of telehealth and technology has changed diabetes care as we know it and we have been presented with the opportunity to shape the future of policy and practice.
- ADCES and the ADA urge CMS to allow RNs and pharmacists to furnish DSMT via telehealth during the COVID-19 pandemic.
- ADCES, ADA, and the Endocrine Society submitted a request to CMS urging action and clarification around Medicare telehealth requirements for DSMT during the COVID-19 pandemic.
- May 5 ADCES Q&A session
- Updated FAQ Regarding Medicare Telehealth Requirements.
- Letter to CMS from Senator Shaheen and Other Senate Champions