Policy Positions & Statements

In response to the calendar year 2025 Medicare Outpatient Prospective Payment System (OPPS) proposed rule, ADCES submitted comments supporting the agency’s proposal to align telehealth coverage rules between OPPS and the Medicare Physician Fee Schedule to allow DSMT and MNT to continue to be delivered via telehealth from the hospital outpatient department setting.

As part of a bill that would provide fiscal year 2025 funding for the Department of Health and Human Services, the House Appropriations Committee put forth a proposal to completely restructure the National Institutes of Health. ADCES joined a large coalition of other organizations on a letter opposing both the contents of the proposal and the process of it being slipped into a funding bill rather than considered by an authorizing committee through a careful process involving key stakeholder input.

On June 27^th, the House Ways & Means Committee held a legislative markup to consider several health care bills including the Treat and Reduce Obesity Act. The committee ultimately decided to advance a much narrower version of the bill than was originally introduced. ADCES joined others from the Obesity Care Advocacy Network on a letter to committee leadership supporting this amended version of TROA that will serve as a first step towards broader coverage of obesity treatments in Medicare.

The House Energy & Commerce Committee was originally scheduled to hold a legislative markup on June 27^th to consider several bills including the PREVENT DIABETES Act, which would make the Medicare Diabetes Prevention Program a permanent benefit and expand access to all delivery modalities of the program. In advance of the markup — which ultimately did not take place that day — ADCES joined the Diabetes Advocacy Alliance and others on a letter supporting the legislation ahead of the scheduled markup.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.