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Policy Positions & Statements

We issue statements, sign letters and submit comments on behalf of diabetes care and education specialists.

Legislative Positions

ADCES Policy Positions and Statements

Alone or as part of a coalition of organizations, we regularly issue statements, sign letters and submit comments that are designed to improve access to diabetes self-management education and support or other aspects of diabetes care and prevention. Some refer to legislative issues and others relate to regulations issued by a federal department such as the CDC or the Centers for Medicare & Medicaid Services. The statements, letters and comments below reflect the legislative positions and policy positions of ADCES®


Statements, Letters & Regulatory Comments

The most recent ADCES policy positions and statements issued in 2023 and 2024 are listed below.

Data Collection in Medicare Advantage

In response to a Request for Information from CMS on data collection within Medicare Advantage, ADCES worked with the Diabetes Technology Access Coalition to submit comments on the types of data that CMS should be collecting on MA plans to better understand how they are promoting or hindering access to DSMT, MNT, diabetes technologies and other critical diabetes care services and devices.

FDA Consideration of Weekly Basal Insulin

A biologics license application has been filed with the FDA for the first-ever once-weekly basal insulin for use by adults with Type 1 or Type 2 diabetes. In advance of a hearing by the FDA’s Endocrinologic and Metabolic Drugs Advisory Committee, ADCES submitted written testimony highlighting the potential for this novel medication to reduce the burden of diabetes management.

Obesity Care in Medicare

ADCES joined a coalition of 58 organizations in sending a letter to HHS Secretary Becerra and CMS Administrator Brooks-LaSure urging the administration to provide coverage of obesity medications under Medicare Part D and to expand access to the Medicare Part B benefit for intensive behavioral therapy for obesity.

Indian Health Service Funding

ADCES signed onto letters from the American Indian/Alaska Native Health Partners coalition to the House and Senate Appropriations subcommittee leadership requesting additional funding for the Indian Health Service in Fiscal Year 2025. The coalition is requesting higher funding for health professionals loan repayment and staff housing to help reduce the provider shortages within IHS and for funding to replace outdated medical and diagnostic equipment and EHRs so that people using the IHS can receive better and more timely care.

Endpoints for Clinical Trials of Diabetes Devices

The Medicare Evidence Development and Coverage Advisory Committee (MEDCAC) is examining what clinical endpoints should be of interest to CMS in studies of new devices for self-management of Type 1 and insulin-dependent Type 2 diabetes in older adults. Two coalitions to which ADCES belongs submitted comments to inform MEDCAC’s deliberations: The Diabetes Technology Access Coalition and the Time in Range Coalition.

Telehealth DSMT in the HOPD Setting

The Medicare program’s telehealth policies continue to operate through 2024 under temporary waivers put in place in early 2020. To ensure that telehealth DSMT can continue in Medicare post-2024, ADCES and ADA submitted a joint letter to CMS outlining regulatory changes we think are needed to avoid disruptions to care specifically in the hospital outpatient department setting.

Obesity Bill of Rights

The National Consumers League and National Council on Aging worked with health leaders and obesity specialists to develop an Obesity Bill of Rights that calls for evidence-based screening, diagnosis and treatment to be available from a respectful, qualified interdisciplinary team. ADCES joined dozens of other organizations in endorsing the Obesity Bill of Rights.

USPSTF Recommendation on Child & Adolescent High BMI

The US Preventive Services Task Force has released a draft updated recommendation on High Body Mass Index in Children and Adolescents: Interventions. ADCES joined other members of the Diabetes Advocacy Alliance in supporting this draft recommendation overall and offering areas for improvement.

Updates to Prescription Drug Coverage Requirements for ACA Marketplace Plans

CMS has issued its 2025 Notice of Benefit and Payment Parameters regulation. Amongst many other changes, HHS plans to switch out the classification system they use to benchmark prescription drug coverage under Essential Health Benefits, which ADCES called for in our 2023 Essential Health Benefits comments. ADCES signed a letter from the Diabetes Advocacy Alliance supporting this change, which we believe will improve access to anti-obesity medications in ACA Marketplace plans.

Fiscal Year 2024 Funding

In response to proposals to cut federal funding for research, education and social service programs, ADCES joined over 1,000 organizations in a letter urging Congressional leadership to adopt the bipartisan Senate funding framework and finish the fiscal year 2024 appropriations process.

Treat and Reduce Obesity Act

As part of the Obesity Care Advocacy Network, ADCES signed onto a letter to House and Senate committee leadership calling on Congress to address the obesity epidemic and pass the Treat and Reduce Obesity Act.

New Diagnosis Codes for Hypoglycemia Levels

ADCES submitted initial comments and a second set of comments to the CDC’s ICD-10 Coordination and Maintenance Committee in support of a recent proposal to create new diagnosis codes for hypoglycemia level 1, level 2 and level 3.

Expanding Access to Diabetes Self-Management Training Act

ADCES and six other national organizations submitted a letter for the Congressional record in support of the DSMT Act’s inclusion in the Energy & Commerce Health Subcommittee hearing Examining Policies to Improve Seniors’ Access to Innovative Drugs, Medical Devices, and Technology.

New Diagnosis Codes for Type 1 Diabetes Stages

ADCES submitted comments to the CDC’s ICD-10 Coordination and Maintenance Committee in support of a recent proposal to create new ICD-10 diagnosis codes for stages 1, 2 and 3 of Type 1 diabetes to distinguish the development of Type 1 from the development of Type 2, which is coded as prediabetes.

CY2024 Medicare Physician Fee Schedule

In response to the calendar year 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, ADCES submitted in-depth comments supporting the myriad improvements to diabetes care coverage the administration was proposing and offered constructive feedback to improve the proposals further. ADCES also signed onto MPFS comments from the Diabetes Advocacy Alliance. See the Final Rule, which incorporated some of ADCES’s suggestions.

Recommendations to Improve the Medicare DSMT Benefit

In response to statements from the Centers for Medicare & Medicaid Services stating that improving utilization of the Medicare DSMT benefit was a priority for the agency, ADCES submitted an extensive list of recommended improvements to streamline referral to and use of the benefit and to simplify participation and billing for suppliers.

Amputation Reduction and Compassion Act

As part of the Amputation Prevention Alliance, ADCES joined a letter to the sponsors of the Amputation Reduction and Compassion Act (ARC Act) supporting the legislation and thanking them for their leadership on amputation prevention.

Special Diabetes Program and Special Diabetes Program for Indians

As part of the Diabetes Advocacy Alliance, ADCES signed onto a letter to House and Senate leadership urging them to reauthorize and fund the Special Diabetes Program and the Special Diabetes Program for Indians in advance of its September 2023 expiration.

Strengthening Medicare for Patients and Providers Act

In response to the introduction of the Strengthening Medicare for Patients and Providers Act, ADCES and a coalition of health care provider associations representing over one million clinicians sent a letter of support to the bill’s original sponsors in the House.

Essential Health Benefits

ADCES responded to the Centers for Medicare & Medicaid Services’ request for information about updating its Essential Health Benefits regulations and guidance. 

CONNECT for Health Act

ADCES submitted comments to the Office of U.S. Senator Schatz (HI) on recommended changes to the CONNECT for Health Act to ensure that Medicare DSMT programs can permanently continue to deliver services via telehealth.