Included in the Calendar Year 2026 Medicare Home Health Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) proposed a change to their coverage policies for diabetes technology that may restrict access to critically important technologies like continuous glucose monitors (CGMs), insulin pumps, and automated insulin delivery (AID) systems for Medicare beneficiaries.
As you know, diabetes technologies such as these have transformed the diabetes management landscape by improving outcomes and making the condition easier to live and thrive with. Advancements in diabetes technology have better enabled people to effectively manage their condition.
The Standards of Care in Diabetes—2025 (Standards of Care) of the American Diabetes Association® (ADA) states that technology is rapidly changing, but there is no universal approach to technology use in people with diabetes. The type(s) and selection of devices should be individualized based on a person’s specific needs, circumstances, preferences, and skill level.
The ADA is concerned that the payment and coverage proposals related to CGMs and insulin pumps laid out in this rule—along with CMS’ intent to apply CGMs and insulin pumps to the next, or a future, round of competitive bidding—may unintentionally restrict access to these critically important technologies for Medicare beneficiaries with diabetes.
Please join us in our efforts to help oppose this regulatory change by submitting a public comment in opposition to the proposed CMS policy by 5:00 p.m. ET on Friday, August 29.
To assist you with this process, we have included the seventh chapter of the ADA's 2025 Standards of Care, Diabetes Technology, to use as a resource.
How To Submit A Public Comment Letter:
- Visit the Federal Register and select the green “Submit a Public Comment” button.
- In the comment box, you may choose to copy and paste the contents of your letter or simply upload your letter as an attachment (see step 5). If you choose to upload your letter, write, “Please see attached comments from (name/organization),”in the comment box.
- When asked what your comment is about, choose from the drop down the subject of your comment letter.
- If you choose to upload your letter as an attachment, you may do so here, along with any other supportive documentation/research you would like to share.
- Include your email for confirmation purposes (this will not be posted publicly on regulations.gov). You may also choose to receive email confirmation of submission and a tracking number.
- When asked to tell them about yourself, please select whether your letter represents (a) an individual, (b) an organization, or (c) anonymous.
- Select the option that confirms you have read and understand that you are filing a document to an official docket and that any personal information included may be publicly viewable on the web.
- Submit your comment. (You may also preview your comment here before submitting.)
Sincerely,
Laura Friedman
Vice President, Regulatory Affairs
American Diabetes Association
Sample Text for Letter
Below is a sample letter. Please personalize your comment as much as possible so CMS understands your specific perspective.
August XX, 2025
Mehmet Oz, MD
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244
Attention: File Code: CMS–1828– P
Submitted via regulations.gov
Re: Medicare and Medicaid Programs; Calendar Year 2026 Home Health Prospective Payment System (HH PPS) Rate Update; Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Updates
Dear Administrator Oz:
Introduce yourself, include who you represent, the patient population you serve, or any specifics about yourself or your practice that you would like to share.
Coverage of Diabetes Technology in Medicare
(I/organization) am/is writing to comment on the proposal by the Centers for Medicare & Medicaid Services (CMS) to include continuous glucose monitors (CGMs), insulin pumps, and automated insulin delivery (AID) systems in any future Medicare Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) competitive bidding program.
Diabetes technologies, like CGMs, insulin pumps, and AID systems, have transformed the diabetes management landscape by improving outcomes and making the condition easier to live and thrive with. Advancements in diabetes technologies have better enabled people to effectively manage their condition. The American Diabetes Association® states that the type(s) and selection of devices should be individualized based on a person’s specific needs, circumstances, preferences, and skill level.1
To that end, (I/we/name of entity) (am/are) concerned that the proposals laid out in this rule may restrict Medicare beneficiaries’ access to these critically important technologies. This proposal lacks the recognition of the functional benefits of the full range of diabetes technologies, which reflect the reality that each individual with diabetes who uses one of these devices determines, with their health care provider, the proper device based on personal factors and the specific needs they must meet to manage their condition.
Share your story:
- Share your or a loved one's experience with diabetes and how diabetes technology helps with the management of this disease.
- Share how diabetes technology has impacted your patients’ experience with diabetes.
- Share how coverage changes and/or barriers have impacted your patients and you as a health care professional.
Other potential points for your letter:
- Competitive bidding programs, like the one proposed in the CY 2026 Home Health Proposed Rule, historically limit the number of suppliers and devices available to individuals. Applying this type of program to CGMs and insulin pumps may force patients to potentially switch from a device that works well for them to one that does not.
- Forcing patients to switch devices that they are already used to may lead to confusion, data loss, or worse clinical outcomes. This is especially difficult for older Medicare beneficiaries who may not be as comfortable switching technologies.
Thank you for the opportunity to submit these comments. Should you have any questions or seek additional information, please reach out to (name/contact information).
1American Diabetes Association: Standards of Care in Diabetes 2025, Diabetes Care 48: Supp. 1 (January 2025), p. S146
Sincerely,
Name
Title (if applicable)