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<strong>CMS</strong>-1403-FC<br />

individual MNT (or any other services currently <strong>approved</strong><br />

for telehealth). Due to the statutory requirement that<br />

DSMT services include teaching beneficiaries the skills<br />

necessary for the self administration of injectable drugs,<br />

we believe that DSMT, whether provided to an individual or<br />

a group, must be evaluated as a category 2 service.<br />

Because we consider individual and group DSMT to be<br />

category 2 services, we needed to evaluate whether these<br />

are services for which telehealth can be an adequate<br />

substitute for a face to face encounter. After reviewing<br />

studies <strong>submitted</strong> with the request, we determined that we<br />

do not have sufficient comparative analysis that either<br />

individual or group DSMT delivered via telecommunications<br />

is equivalent to DSMT delivered face to face. We did not<br />

find evidence that providing DSMT via telehealth is an<br />

adequate substitute for providing DSMT in person.<br />

Therefore, we proposed not to add individual and group DSMT<br />

(as described by HCPCS codes G0108 and G0109) to the list<br />

of <strong>approved</strong> telehealth services.<br />

Comment: Some commenters disagreed with our proposal<br />

and noted that adding DSMT to the list of <strong>approved</strong><br />

telehealth services would provide a physician or<br />

practitioner with an additional tool for supporting patient<br />

compliance with management of diabetes. One commenter<br />

97

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