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The Honorable Mehmet Oz
Administrator
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201
Dear Administrator Oz:
We, the undersigned organizations representing people living with diabetes and health professionals, write to encourage the Centers for Medicare & Medicaid Services (CMS) to support expeditious action by (1) the Coverage and Analysis Group (CAG) on a February 28, 2022, reconsideration request to update the National Coverage Determination (NCD) for insulin pumps (NCD 280.14) and (2) the Durable Medical Equipment (DME) Medicare Administrative Contractors (MACs) to issue proposed updates to the continuous glucose monitor (CGM) coverage criteria (LCD L33822) consistent with a February 28, 2025, reconsideration request. Prompt action on these requests would bring Medicare coverage into alignment with current clinical evidence and standards of care, remove outdated barriers to clinically appropriate treatment, and expand beneficiaries’ access to technologies that improve diabetes outcomes and quality of life.
We urge CAG to issue a proposed revised NCD 280.14 for insulin pumps and move it off the waitlist. This NCD has not been updated in more than two decades, is unnecessarily confusing, and is significantly misaligned with the current clinical evidence and standards of care. For example, the requirement that coverage be conditioned on the results of a C-peptide/beta-cell autoantibody test relies on an imperfect metric to determine whether an insulin pump would be medically appropriate for an individual with diabetes and should be abandoned in favor of more dispositive evidence that demonstrates that insulin pumps improve clinical outcomes. Increasingly, this test is no longer required for coverage under commercial insurers, imposing a new and different test for Medicare beneficiaries that is no longer considered meaningful or relevant to whether an insulin pump is needed. The current insulin pump NCD also is misaligned with Medicare’s coverage for CGMs. Misaligned coverage between insulin pumps and CGMs particularly limits access to automated insulin delivery (AID) systems, which use an algorithm alongside CGM data and an insulin pump to automatically adjust insulin delivery. We note that the use of AID systems is part of the diabetes standards of care as articulated by the American Diabetes Association (ADA) and the American Association of Clinical Endocrinology (AACE).1
We appreciate that the DME MACs have modified CGM coverage criteria in the past to try to keep Medicare coverage current with the latest clinical evidence and standards of care. Access to CGM can provide individuals living with diabetes the timely information needed to understand glucose trends, make informed decisions about their care, and more actively manage their condition. CGM data are indispensable to clinicians’ ability to effectively treat people with diabetes. We also want to thank CAG for its acceptance of the NCD 280.14 reconsideration request in 2022.
As noted in the February 28, 2025, reconsideration request of LCD L33822, the evidence now supports expanding CGM coverage to all individuals with diabetes. Reflecting this evolving evidence base, on December 9, 2024, the ADA revised its Standards of Care in Diabetes to recommend that providers consider CGMs for diabetes management in individuals with type 2 diabetes who are using glucose-lowering medications other than insulin.2 ADA reaffirmed and strengthened this recommendation in its most recent edition of the Standards of Care in Diabetes, released on December 8, 2025, which recommends CGM for adults “on any diabetes treatment where CGM aids in management.”3 Medicare coverage should not lag behind this important evolution in the clinical evidence and standards of care. Instead, Medicare coverage should enable beneficiaries and their providers to jointly determine whether CGM is appropriate based on each beneficiary’s unique clinical circumstances and physiology.
Given the demonstrated clinical benefits of CGMs, insulin pumps, and AID systems, we respectfully request that you urge the DME MACs and CAG act expeditiously on the CGM LCD and insulin pump NCD reconsideration requests, respectively. Doing so will ensure that Medicare coverage policies reflect the latest clinical evidence and standards of care and allow beneficiaries timely access to technologies that improve diabetes outcomes and quality of life.
Sincerely,
American Diabetes Association
Alliance for Aging Research
American Association of Clinical Endocrinology
Association of Diabetes Care and Education Specialists
Blue Circle Health
Children with Diabetes
Diabetes Leadership Council
Diabetes Patient Advocacy Coalition
diaTribe
National Association of Hispanic Nurses
National Black Nurses Association
The Diabetes Link
T1D Exchange
1 Standards of Care in Diabetes – Diabetes Technology: Standards of Care in Diabetes—2026. Diabetes Care 49 (2026) S150-S165, https://diabetesjournals.org/care/issue/49/Supplement_1; George Grunberger, et. al., American Association of Clinical Endocrinology Clinical Practice Guideline: The Use of Advanced Technology in the Management of Persons With Diabetes Mellitus, 27 Endocrine Practice 505 (2021), https://www.endocrinepractice.org/action/showPdf?pii=S1530-891X%2821%2900165-8; Lawrence Blonde, et. al., American Association of Clinical Endocrinology Clinical Practice Guideline: Developing a Diabetes Mellitus Comprehensive Care Plan—2022 Update, 28 Endocrine Practice P923 (2022), https://www.endocrinepractice.org/article/S1530-891X(22)00576-6/fulltext; Ronan Roussel, et. al., Important Drop in Rate of Acute Diabetes Complications in People With Type 1 or Type 2 Diabetes After Initiation of Flash Glucose Monitoring in France: The RELIEF Study, 44 Diabetes Care 1368 (2021), https://diabetesjournals.org/care/article/44/6/1368/138708/Important-Drop-in-Rate-of-Acute-Diabetes.
2 Standards of Care in Diabetes – Diabetes Technology: Standards of Care in Diabetes—2025. Diabetes Care 48 (2025) S146-S166, https://diabetesjournals.org/care/issue/48/Supplement_1.
3 Diabetes Technology: Standards of Care in Diabetes—2026 - Pharmacologic Approaches to Glycemic Treatment: Standards of Care in Diabetes—2026, 49 Diabetes Care S183 (2026), https://diabetesjournals.org/care/article/49/Supplement_1/S183/163934/9-Pharmacologic-Approaches-to-Glycemic-Treatment.
