As Diabetes Specialists, we want to ensure the safety of patients and colleagues, while providing diabetes care to those who may be the most vulnerable and isolated during this pandemic.

According to the CARES Act, Diabetes Self-Management Training (DSMT) can be provided to patients via telehealth during the pandemic. Though the original regulations had many gaps.

Previously, the CARES Act required that telehealth visits must include both audio and video, while many hospital outpatient clinics were running into billing barriers. In addition, under the original guidelines, RNs and Pharmacists were not included in the approved list of telehealth DSMT Providers.

See: ADCES Summary Sheet of DSMT and Telehealth FAQ for more information.

Though as of April 23, 2020 the guidelines have been updated.

Good News – these updates to the CARES Act now expand blanket waivers under the 1135 waiver.

For any of the information below, please check with your compliance team for clarification and share the important resource links below with your billing department.

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How do CMS Updates Affect Our Ability to Provide DSMT Training?

DSMT Can Now be Audio-Only

DSMT services may be billed for audio-only, but only if the video is not available or possible. Make sure to document the mode of instruction and the rationale if using audio-only. 

See: COVID-19 Emergency Declaration Waiver for more information.

Can RNs & Pharmacists Now Provide Telehealth and Bill for DSMT?

The ADA and ADCES have been working hard to decipher the language and intent in the updated guidelines. It seems that RN and Pharmacists are now included based on an assessment of the wording in the new documents. CMS continues to expand the definition of providers eligible to furnish telehealth services during the COVID-19 public health emergency.

As DSMT programs bill as an entity, rather than at the individual provider level, the American Diabetes Association is seeking confirmation that DSMT programs that are eligible through Medicare Part B, are considered distant site practitioners approved to furnish telehealth services.

See: Blanket Waivers for HealthCare Providers Fact Sheet for more information.

Hospital-Based Programs Can Bill for Telehealth DSMT on the UB-04 (Medicare Claims) Form

Hospitals may now bill for education and management services (i.e. DSMT) as if they were furnished in the hospital and consistent with any specific requirements for billing Medicare in general, including any relevant modifications in effect during the COVID-19 PHE.

In summary:

• DSMT services can be provided in the hospital outpatient setting remotely to a patient in their home.
• The patient’s home can serve as a temporary provider-based department of the hospital (CMS’ Hospitals Without Walls initiative).
• If you previously billed using the UB-04, continue to bill the same way.
• The patient must be a registered outpatient of a hospital.
• DSMT and scope of practice requirements must be met.

See: CMS Hospitals Without Walls Initiative for more information.

Important to note: Please consult with your organization’s billing department and compliance team if you have questions.

Sources and Links

• CMS Press Release Summarizing April 30 Guidance.
• Hospitals CMS Flexibilities to Fight COVID Fact Sheet.
• Blanket Waivers for HealthCare Providers Fact Sheet
• Telehealth Information: List of billing codes are available here.

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Accreditation: Diabetes Education Services is an approved provider by the California Board of Registered Nursing, Provider 12640, and Commission on Dietetic Registration (CDR), Provider DI002. Since these programs are approved by the CDR it satisfies the CE requirements for the CDCES regardless of your profession.*  

The use of DES products does not guarantee the successful passage of the CDCES exam. CBDCE does not endorse any preparatory or review materials for the CDCES exam, except for those published by CBDCE.