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[IP] Proposed HCFA Final Ruling on Diabetes Self Care Management Regulations

Below you will find a copy of the letter that I have sent to HCFA today
regarding the proposed final ruling on Diabetes Self-Care Management

The proposed final ruling requires that all Diabetes education given to
patients must be by a Certified Education provider as set forth under the
regulation.  That is the program must be certified.  The current proposed
ruling requires that program meet the ADA Standard, which is not a bad
thing, but it takes twelve months of data to be eligible for this
certification.  Most physicians have not had ample time to gather this data
as such, Many new diabetics will be required to travel a great distance to
get the appropriate diabetes education.

Further, the regulations only allow 10 hours over the first year and only
one additional hour each year thereafter.  They also require group teaching
unless it can be documented that a physical limitation exists.

These are issues that we as individuals need to make HCFA Aware of.  Please
forward your comments to them ASAP as public comment closes at 1700 hrs
(5:00 pm) on April 12, 1999.

Help all Diabetics who are also Medicare recipients.

---- Begin HCFA Letter ----

February 23, 1999

Health Care Financing Administration
Department of Health and Human Services
Attention: HCFA-3002-P
PO Box 31850
Baltimore  MD  21207-8850

Re: 42 CFR Parts 410.414.424.476 & 498

In regards to the regulations proposed by HCFA for Expanded Coverage for
Outpatient Diabetes
Self-Management Training Services, the regulations delay fails to take into
consideration that all
local and national certifying agencies and authorities require a collection
of data for twelve
months.  That twelve month period begins on the date of application, it is
not nor can it be

As such, this requirement excludes current physicians and other
practitioners from being able to
provide diabetes education to their patients and requires them to refer
their patients to those
national organizations which have: 1. Been able to afford and have had ample
to time prior to this
regulation to request this voluntary recognition and accreditation and 2.
have had it in their best
interest from a marketing standpoint to have such recognition and

The regulation fails to grant the Primary Care Physician and the patient
care team enough
available time to meet the requirements of the standards without
jeopardizing the care and
availability of certified programs.

In Massachusetts alone the availability of programs is limited to major
urban cities, i.e., Boston,
Worcester, Brockton, Lynn, Winchester, Stoughton and Lawrence.  That is
eleven programs total
with no programs accredited or recognized in the western, southeastern or
Cape and islands
portion of the Commonwealth of Massachusetts.  Are these Medicare recipients
to remain
unserved and without Diabetes Education and Self Management.

I feel that HCFA has failed to recognize that the certification of programs
section of the law
requires a period of time for compliance and should be granted to all
Physician, Medical groups
and practices and those individuals whom are able to properly and
effectively teach Diabetes
Self-Care Management.

I have been a diabetic for 21 years and was required to travel over 50 miles
for diabetes education
back then, is it the position of HCFA to again require me to travel over
fifty miles to gain appropriate education.  I feel that this is most unfair
to me, the consumer and patient living with
this disease for over 20 years.

What would it cost for HCFA to postpone implementation of a section of the
regulation that
requires national certification.  What would it cost to not postpone it?
How many million must be
spent on unnecessary diabetes crisis management over the next 2 years that
could have been
avoided, had HCFA granted a postponement to the certification requirement.

I firmly believe that ALL programs should be certified, but within a
specified time frame after the
implementation of the regulation.  It seems to me that 18 month to 24 months
would be a good
time frame to require said accreditation. This time frame would allow people
to still receive
education from individual practitioners that they choose and allow the
practitioner time to obtain
the necessary certification.

It is my hope and prayer that HCFA will see this as a viable plan for


CJ Ferry

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