November 20, Ms. Seema Verma Administrator Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244

Similar documents
Background USPSTF Guideline

UPDATE: Screening and Coverage for Diabetes and Prediabetes. Karin Gillespie, Changing Diabetes Policy, Novo Nordisk

Medicare Diabetes Prevention Program

Diabetes Prevention in. Massachusetts: Prediabetes and the Diabetes Prevention Program. Diabetes Prevention and Control

Making Diabetes Prevention a Reality: The National Diabetes Prevention Program

December 18, Submitted Electronically

Delaware Oral Health Plan 2014 Goals and Objectives VISION

Shaping our future: a call to action to tackle the diabetes epidemic and reduce its economic impact

PREVENTATIVE COMMUNITY PHARMACY DIABETES MANAGEMENT PROGRAMS BROOKE HUDSPETH, PHARMD, CDE, MLDE KROGER DIABETES CARE

Mercy Diabetes Prevention Program

Diabetes Prevention Program. Cynthia E. Miller, MD, FACP Senior Corporate Medical Director of Pharmacy WellCare Health Plans, Inc September 8, 2018

Alex Azar Secretary, Department of Health and Human Services

Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016

219 Dirksen Senate Office Building 219 Dirksen Senate Office Building. 219 Dirksen Senate Office Building 219 Dirksen Senate Office Building

Working Together to Prevent Diabetes

National Diabetes Prevention Program Centers for Medicare & Medicaid Service Expansion. Tribal Leaders Diabetes Committee September 22, 2016

February 1, The Honorable Jeanne Shaheen United States Senate 520 Hart Senate Office Building Washington, DC Dear Senator Shaheen:

Insurance Providers Reduce Diabetes Risk Through CDC Program

Implementing and Sustaining Chronic Disease Self-Management Education Programs

Statement Of. The National Association of Chain Drug Stores. For. U.S. Senate Finance Committee. Hearing on:

Working Together to Prevent Diabetes

CANCER LEADERSHIP COUNCIL

Overview of the NC Diabetes Prevention and Management Guide. Ronny Bell, Ph.D., MS, Chair Jan Nicollerat, MSN, RN, ACNS-BC, CDE, Vice Chair

Montana s Experience. Telehealth Delivery of the Diabetes Prevention Program (DPP)

Physician Engagement and Prediabetes

The Academy Capitol Forum: Meet the Experts. Diagnosing Which Health Treatments Improve Outcomes: A PCORI Overview and How to Get Involved

Disclosure. I have no relevant financial relationships with commercial interests to disclose American Medical Association. All rights reserved.

CHANGE TODAY FOR A HEALTHIER FUTURE DIABETES PREVENTION PROGRAM OVERVIEW

January 16, Dear Administrator Verma:

VIA ELECTRONIC SUBMISSION: September 10, 2018

Diabetes Self-Management Education and Support Joint Position Statement

September 10, To Whom It May Concern:

REVIEW AND FREQUENTLY ASKED QUESTIONS (FAQ) 8/5/2015. Outline. Navigating the DSMT Reimbursement Maze in Todays Changing Environment

Dear Representative Burgess, Representative DeGette, Senator King, Senator Crapo, and Senator Cardin:

Webinar Series: Diabetes Epidemic & Action Report (DEAR) for Washington State - How We Are Doing and How We Can Improve.

NEW BUSINESS. (To be submitted and introduced by Delegates only) Introduced by: LT Kinbo Lee (Name) 2/13/2018 United States Public Health Service

ADVOCATING FOR PATIENTS WITH DIABETES

The Role of Physicians and Care Teams in Preventing Diabetes

Addressing Gaps in MS Care. November 6, :00 AM - Noon

Mary Ann Hodorowicz RDN, MBA, CDE, CEC (Certified

HRSA Oral Health Programs 2010 Dental Management Coalition June 27, 2010 Annapolis, MD

DIABETES ACTION PLAN LEGISLATION: POLICY CHANGE FOR DIABETES PREVENTION AND CONTROL

AIDS Foundation of Chicago Strategic Vision

About the Highmark Foundation

Why is oral health important?

Sandhya Mehta, 1 Michelle Mocarski, 2 Tami Wisniewski, 2 Karin Gillespie, 2 K M Venkat Narayan, 3 Kathleen Lang 1. Original research.

Medicaid s Role in Combating the Opioid Crisis

Transforming Public Health: Health Reform and the National Prevention Strategy

STATE AND COMMUNITY MODELS FOR IMPROVING ACCESS TO DENTAL CARE FOR THE UNDERSERVED

If DSME* were a pill, would you prescribe it?

Medicare s Current Diabetes Self-Management Training (DSMT) Coverage and Proposed Diabetes Prevention Program (DPP) Rule

1. Introduce the Culture of Health Framework. 2. Become acquainted with the the Robert Wood Johnson Foundation Public Health Nurse Leadership Program

OCTOBER EOEA and the Alzheimer s Association have organized implementation of the plan around its five major recommendations:

Increasing Adult Immunization Rates in the US Through Data and Quality: A Roadmap

State of Rhode Island. Medicaid Dental Review. October 2010

2016 United Nations Political Declaration on Ending AIDS sets world on the Fast-Track to end the epidemic by 2030

February 13, The Honorable Fred Upton 2183 Rayburn House Office Building Washington, DC Dear Chairman Upton:

House Committee on Energy and Commerce House Committee on Energy and Commerce. Washington, DC Washington, DC 20515

March 1, RE: 2020 Medicare Advantage and Part D Advance Notice and Draft Call Letter (CMS )

March 26, The Honorable Richard Durbin United States Senate 332 Dirksen Senate Office Building Washington, DC Dear Senator Durbin:

US H.R.6 of the 115 th Congress of the United States Session

RE: CMS-4130-P (Medicare Program; Policy and Technical Changes to the Medicare Prescription Drug Benefit)

TRUE Hospice Utilization Project Hospice Access Research References

August 15, Dear Administrator Verma:

AHIP Webinar: Top Tips for a Successful National Diabetes Prevention Program

Implementing the National Diabetes Prevention Program: Intensive Lifestyle Modification for Diabetes Prevention and Diabetes Self-Management Education

Engaging Physicians & Care Teams to Prevent Diabetes. Kate Kirley, MD, MS Janet Williams, MA. CME Information

Dissemination and Implementation Research in Diabetes and Obesity. Christine Hunter National Institute of Diabetes and Digestive and Kidney Diseases

What can we do for seniors?

National Blueprint: Achieving Quality Malnutrition Care for Older Adults

1. The World Bank-GAVI Partnership and the Purpose of the Review

1:45 pm - 2:15 pm How is the NOVA Alliance Addressing These Issues? Structure Mission/vision and purpose Goals, outcomes, and strategies

National Blueprint: Achieving Quality Malnutrition Care for Older Adults

Submitted electronically to:

Diabetes Care begins with Diabetes Prevention. Neha Sachdev, MD Janet Williams, MA

June 22, The Honorable Orrin Hatch Chairman, Senate Finance Committee United States Senate Washington, D.C

CHI Franciscan. Matt Levi Director Virtual Health Services. March 31, 2015

Oral Presentation to the H.E.L.P. Committee on February 14, 2012 Philip A. Pizzo, MD

The Affordable Care ACT (ACA) Association of State and Territorial Dental Directors Webinar Wednesday, November 20, 2013

Health Care Reform Update and Advocacy Priorities

Statement Of. The National Association of Chain Drug Stores. For. U.S. Senate Committee on Finance. Hearing on:

Malnutrition Health Impacts and Healthcare Costs

1-Appropriate Use Criteria for Advanced Diagnostic Imaging Services

Recommendation 1: Promote Kidney Disease Prevention Research

Nutrition and Physical Activity Situational Analysis

5. Expand access to proven, effective treatments for tobacco addiction

Access to Dental Services in. Reimbursement Rates and Administrative Streamlining

Re: Trust for America s Health Comments on Biennial Implementation Plan for the National Health Security Strategy

Achieving Quality and Value in Chronic Care Management

Submitted to the House Energy and Commerce Committee. Federal Efforts to Combat the Opioid Crisis

Early Childhood Mental Health and Homelessness

HIV Testing Reimbursement Subcommittee of the HIV Health Care Access Working Group (Affiliated with the Federal AIDS Policy Partnership)

The Journey towards Total Wellbeing A Health System s Innovative Approach

HEALTH REFORM & HEALTH CARE FOR THE HOMELESS POLICY BRIEF JUNE 2010

Cardiometabolic Disorder and Diabetes Management in the U.S.

Washington State Collaborative Oral Health Improvement Plan

a call to states: make alzheimer s a policy priority

Thank you for joining today, please wait while others sign in.

RE: Draft CMS Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System and Alternative Payment Models

Transcription:

November 20, 2017 Ms. Seema Verma Administrator Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 Dear Administrator Verma: The Diabetes Advocacy Alliance (DAA) appreciates the opportunity to provide comments on the Centers for Medicare & Medicaid Services (CMS) Innovation Center New Direction Request for Information (New Direction/RFI) released on September 20, 2017. The DAA is a coalition of 22 diverse member organizations, representing patient, professional and trade associations, other non-profit organizations, and corporations, all united in the desire to change the way diabetes is viewed and treated in America. Since 2010, the DAA has worked to increase awareness of, and action on, the diabetes epidemic among legislators and policymakers. The organizations that comprise the DAA share a common goal of elevating diabetes on the national agenda so we may ultimately defeat diabetes. As you know, both the human and economic toll of diabetes is devastating. Over 30 million Americans have diabetes and an additional 84 million adults are at risk of developing the disease. By 2050, it is estimated that one out of every three Americans will have diabetes. In addition, the annual cost of this public health emergency has skyrocketed to $322 billion and will continue to rise unless something is done. Further, the Medicare program and older adults are disproportionately affected by diabetes. Approximately 12 million Americans over the age of 65 (nearly 30 percent) have diabetes and half of all those over the age of 65 have prediabetes. In addition, Medicare currently spends one out of every three dollars on care for people with diabetes. 1 Given the burden diabetes places on seniors and the Medicare program, the DAA strongly recommends the Innovation Center focus attention on this serious and costly disease as it develops and tests innovative approaches and models to improve quality and value of care for Medicare beneficiaries. Medicare Diabetes Prevention Program Expanded Model First and foremost, the DAA would like to recognize the work of the Innovation Center in moving forward with an expanded model test that will allow seniors at risk for diabetes to participate in an evidence-based diabetes prevention program. Through a pilot that enrolled more than 8,000 Medicare beneficiaries, the Innovation Center found seniors can prevent or delay onset of type 2 diabetes by participating in a community-based diabetes prevention program and save the Medicare programs approximately $2,650 over 15 months. 2 The 1 Centers for Medicare and Medicaid Services. Medicare Health Support Overview. Baltimore, MD: CMS. Available at: http://www.cms.gov/ccip.downloads/overview_ketchum_70116.pdf 2 Spitalnic P. Certification of medicare diabetes prevention program. Office of the Actuary at the Centers for Medicare & Medicaid Services, March 2016. Available online: https://www.cms.gov/research-statistics-data-and-systems/research/actuarialstudies/downloads/diabetes-prevention- Certification-2016-03-14.pdf

Medicare diabetes prevention program (MDPP) expanded model clearly illustrates the Innovation Center s potential to bring effective, cost-saving new models of care and prevention to our nation s seniors. As expressed in our comments related to the 2018 Medicare Physician Fee Schedule proposed rule, the DAA is disappointed that virtual delivery of MDPP was not included in the proposed rule. The DAA would like to reiterate that virtual and other innovative forms of DPP delivery is essential for beneficiary choice as well as access (particularly for vulnerable populations, individuals with transportation needs or those in rural areas with no access to an in-person program.) We stand ready to work with the Innovation Center on a separate model test of virtual and other innovative delivery of DPP services conducted in parallel with the MDPP expanded model as was described in the proposed rule. Coverage of virtual and other innovative programs will ensure Medicare beneficiaries have access to MDPP regardless of where they live and in the format of their choosing. Although we emphasize the need for the virtual model test to happen quickly to assure full access, we also urge the Innovation Center to be as transparent as possible in the development of the virtual model test (ideally, opening it for public comment) and work closely with stakeholders to ensure a successful test and future implementation. The DAA looks forward to working with CMS to implement the new MDPP benefit beginning April 2018. Guiding Principles The new direction outlined in the RFI for the Innovation Center is of particular interest to the DAA given its emphasis on patient-centered care and focus on reforms that increases choices that drive quality, improved outcomes, and reduced costs. The DAA strongly supports the guiding principles related to patient-centered care and transparent model design and evaluation. It is critical that patients be at the center of these important health care decisions and models which will help empower beneficiaries and their families. In addition, the DAA strongly believes patients should not be harmed by model tests and urges the Innovation Center to safeguard patient access and quality of care. The DAA has been fortunate to engage with the Innovation Center over the last several years and believes a strong partnership and collaboration between the Innovation Center and external stakeholders will yield the best ideas and ultimately improved care for patients. While the statute establishing the Innovation Center required broad stakeholder engagement, the DAA encourages the Innovation Center to develop a formal strategy for stakeholder engagement so that external parties, particularly patients and/or consumers, have the opportunity to contribute to model development and testing. Gaps in Diabetes Care As previously mentioned, diabetes is an epidemic affecting an increasing number of Americans and consuming more and more healthcare dollars. The Medicare diabetes prevention program expanded model filled a gap that previously existed in the Medicare program; that diabetes prevention was not a covered service for seniors. The DAA is pleased the Innovation Center s model test will result in Medicare coverage for diabetes prevention beginning April 2018 but there is more the Innovation Center can do in terms of filling gaps that exist in diabetes care. A few examples are highlighted below.

Diabetes Screening As previously mentioned, over 30 million Americans have diabetes. Unfortunately, 7.2 million are undiagnosed which includes over 2 million Medicare beneficiaries who are not getting the care they need to manage their disease. In addition, only 11.6% of the 84 million Americans with prediabetes know they have it. Despite the fact that the U.S. Preventive Services Task Force (USPSTF) recommends screening adults aged 40 to 70 years who are overweight or obese for diabetes 3 and Medicare covers two diabetes screening tests a year for eligible beneficiaries, millions of Americans remain undiagnosed and are not receiving the care and treatment they need. Given the sheer number of people living with diabetes or at risk of the disease and the hundreds of billions of dollars spent on diabetes, the DAA recommends the Innovation Center test new approaches to outreach and screening to improve diabetes screening rates. Improving Medicare diabetes screening rates may also help drive uptake of the new Medicare diabetes prevention program benefit by seniors with prediabetes which goes into effect in 2018. Related to diabetes screening, the Medicare program currently covers and reimburses fasting plasma glucose (FPG) tests to screen for diabetes. However, the hemoglobin A1c test is only covered and reimbursed under Medicare if a patient has already been diagnosed with diabetes and it s ordered by a doctor. The hemoglobin A1c test is often preferred by physicians for its convenience 4 and research suggests the FPG may underestimate the burden of undiagnosed diabetes compared to the A1c test. 5 The DAA urges the Innovation Center to test using the hemoglobin A1c test for diabetes screening which may help reduce the number of Medicare beneficiaries with undiagnosed prediabetes and diabetes and get them the care they need. Patient Centered Diabetes -Management Diabetes is a complex disease that requires ongoing self-management by patients, including integrating lifestyle modifications and making numerous decisions throughout the day, as part of their management and treatment regimen. Two out of three Medicare beneficiaries have diabetes or prediabetes. Because of the impact the disease has on the program, people with diabetes should not be treated in a one-size-fits all manner. There are many great examples of evidence-based services and programs, including some that are community-based, that lead to improved health outcomes for people with type 2 diabetes. The DAA recommends that the Innovation Center develop a robust set of pilots to test innovative models and programs that delivery patient centered diabetes management including new approaches to delivery of Medicare diabetes self-management training (DSMT) and community based programs that lead to improved outcomes. Diabetes Self-Management Training new delivery models Medicare covers DSMT which is an evidence-based service that teaches people with diabetes how to effectively self-manage their diabetes and cope with the disease. Studies have found that DSMT is associated with improved diabetes knowledge and self-care behaviors, lower hemoglobin A1c, lower weight, improved quality of life, healthy coping and reduced health care costs 6, and it is a 3 Sui AL, on behalf of the U.S. Preventive Services Task Force. Screening for abnormal blood glucose and type 2 diabetes mellitus: U.S. preventive services task force recommendation statement. Ann Intern Med 2015; 163(11):861-868. 4 Mehta S, Mocarski M, Wisniewski T, Gillespie K, Narayan KMV, and Lang K. Primary care physicians utilization of type 2 diabetes screening guidelines and referrals to behavioral interventions: a survey-linked retrospective study. BMJ Open Diab Res Care 2017;5:e000406. doi:10.1136/bmjdrc-2017-000406. 5 Ho-Pham LT, Nguyen UDT, Tran TX, Nguyen TV. Discordance in the diagnosis of diabetes: comparison between HbA1c and fasting plasma glucose. PLoS ONE 2017; 12(8): e0182192. https://doi.org/10.1371/journal.pone.0182192 6 American Diabetes Association. Standards of Medical Care in Diabetes 2017. Diabetes Care 2017; 40 (Suppl.1): S34.

recommended component of care in a joint position statement of the American Diabetes Association, American Association of Diabetes Educators, and Academy of Nutrition and Dietetics 7 Unfortunately, despite its critical importance for people with diabetes and the fact that DSMT has been a covered benefit under Medicare for over 15 years, a recent study found only five percent of Medicare beneficiaries with newly diagnosed diabetes used DSMT services. 8 CMS highlighted the significant underutilization of DSMT in the CY 2011 and CY 2017 Medicare Physician Fee Schedule, and solicited public comment on barriers contributing to access and the underutilization of the benefit. The DAA provided comments to the agency on existing barriers and recommends the Innovation Center test new approaches to delivering DSMT, including virtual delivery, in an effort to increase utilization of this important benefit. New, community based, models of patient centered diabetes management Community-based programs have many benefits compared to those delivered in a clinical setting including greater scalability, accessibility, and affordability. One example of an innovative model of care for people with type 2 diabetes found that combining community based and online diabetes education with popular commercial weight loss, resulted in greater A1c reduction and weight loss compared to standard nutrition and diabetes education. 9 In addition, the interventions led to improvements in psychosocial outcomes often seen in individuals with type 2 diabetes. 10 The MDPP expanded model is helping to establish community health workers role in the Medicare program as it relates to diabetes prevention; however, the Innovation Center should look further and consider a model test based on the aforementioned intervention to help explore the role of these workers in the care and treatment of people with diabetes. *** Thank you for the opportunity to comment on this Request for Information for the new direction of the Innovation Center. We support the Agency s efforts to promote patient-centered care and drive quality and improve outcomes. We look forward to working with CMS to address critical gaps in diabetes care and ensuring our healthcare system is affordable, accessible, and puts patients first. If you have any questions or need additional information, please free to contact one of us: Meghan Riley at mriley@diabetes.org; Karin Gillespie at kgil@novonordisk.com; or Dr. Henry Rodriguez at hrodrig1@health.usf.edu. 7 Powers MA, Bardsley J, Cypress M, et al. Diabetes self-management education and support in type 2 diabetes; a joint position statement of the American Diabetes Association, American Association of Diabetes Educators, and the Academy of Nutrition and Dietetics. Diabetes Care 2015;38:1372-1382. 8 Strawbridge LM, Lloyd JT, Meadow A, et al. Use of medicare s diabetes self-management training benefit. Health Education Behavior 2015;42:530-8. 9 O Neil PM, Miller-Kovach K, Tuerk PW, Becker LE, et al. Randomized controlled trial of a nationally available weight control program tailored for adults with type 2 diabetes. Obesity 2016;24:2269-2277. 10 Holland-Carter L, Tuerk PW, Wadden TA, Fujioka KN, et al. Impact on psychosocial outcomes of a nationally available weight management program tailored for individuals with type 2 diabetes: results of a randomized controlled trial. Journal of Diabetes and Its Complications 2017, http://dx.doi.org/10.1016/j.jdiacomp.2017.01.022

Sincerely, Academy of Nutrition and Dietetics American Association of Diabetes Educators American Diabetes Association American Podiatric Medical Association Endocrine Society Healthcare Leadership Council National Kidney Foundation Novo Nordisk, Inc. Omada Health Pediatric Endocrine Society VSP Vision Care Weight Watchers International, Inc. YMCA of the USA