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

acknowledged that training patients in the<br />

self-administration of injectable drugs, a required<br />

component of DSMT programs, would be difficult to perform<br />

via telehealth. However, the commenter disagreed that this<br />

concern should prevent diabetes patients from accessing the<br />

DSMT benefit through telehealth. The commenter believes<br />

that educating a patient on diet, exercise, medications,<br />

managing stress and illness, and managing blood sugar can<br />

be taught via telehealth.<br />

Another commenter agreed that telehealth should not<br />

serve as a substitute for initial DSMT training that may<br />

involve hands-on teaching of injectable medications or<br />

appropriate usage of glucose monitors. However, the<br />

commenter believes that follow-up telehealth encounters can<br />

help to quickly identify any potential problems or health<br />

concerns.<br />

Response: The request we received was to add<br />

individual and group DSMT as described by HCPCS codes G0108<br />

and G0109 to the list of Medicare telehealth services. As<br />

discussed above, teaching beneficiaries the skills necessary<br />

for the self administration of injectable drugs is a<br />

statutorily required element of DSMT (and is typically<br />

provided as part of an individual DSMT session). <strong>This</strong> skill<br />

based training is typically not a component of any of the<br />

current Medicare telehealth services.<br />

98

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