My comment to CMS’ proposed Medicare regulations that will impact DSMT

Today at 5pm Eastern is the deadline for submitting comments to CMS on their proposed Medicare regulations that will impact DSMT (Diabetes Self-Management Training) and DPP (Diabetes Prevention Program). I submitted the comment below.

My name is Manny Hernandez. I have lived with diabetes since 2002, at age 30. Since then, I have engaged in diabetes advocacy, co-founding the Diabetes Hands Foundation (where I now serve as a Board Member), and always looking to bring the voice of people with diabetes anywhere there’s a policy or decision made on our behalf.

Since I was diagnosed, Diabetes Self-Management Training has given me the tools to take the best care of myself as I live with diabetes, and I have gone back for more training over the years, as I have changed therapies, changed providers, changed plans… as life has gone on. I have been fortunate to have access to DSMT when I needed it, but copayments and deductibles get in the way of scores of people who need it (and could see their long term outcomes improve drastically) but cannot afford it.

Having met hundreds of Diabetes Educators over the years as part of my advocacy work, I have become painfully aware of the challenging and limiting circumstances in which they operate, always putting the patient’s needs first. We should make their work easier, not harder. They should be able to deliver Diabetes Self-Management Training in a sustainable way, which they often cannot do given the reimbursement structure faced today and even the proposed one (G0108 and G0109).

The journey of people with diabetes is not linear: it’s full of valleys and peaks, as the condition evolves, life happens (with its challenges), and you need to adjust to new realities, in- and outside of diabetes. While you may not need Diabetes Self-Management Training all the time, or every year, beneficiaries should not lose their initial 10 hours of DSMT if it is not completed within the first 12 months after referral. You will ALWAYS have things to learn and adjust with diabetes, and not acknowledging this reflects an approach that overlooks the realities of people living with diabetes.

Similarly, people with diabetes should be able to access Diabetes Self-Management Training in their communities, not HAVE to be constrained as to the setting in which they can receive it. How do you best impact people you want to help? Meeting them where they are: so constraining options for them limits access too. Let’s not do this.

Diabetes Self-Management Education needs to become a benefit that ALL people with diabetes have access to. It has the potential to turn the tides of this epidemic in the US, and its associated cost, by empowering people with diabetes with the tools to make the best possible decisions about their day-to-day care, AS they go about their lives. But this can only happen if we effectively remove barriers to it, and make it affordable to patients throughout their entire diabetes journey, sustainable to providers, and accessible in as many possible formats and settings as possible.

As a result, I appeal to CMS to consider the above elements from the perspective of the person with diabetes and I express my full support of the proposals of AADE, ADA, and Academy of Nutrition and Dietetics, AADE to help increase access to Diabetes Self-management Education for people with diabetes in the United States.