Can a practice bill DSMT without special accreditation?

No. DSMT can only be billed by a program holding current accreditation from a recognized body, such as the American Diabetes Association's Education Recognition Program or a comparable CMS-recognized organization. Billing without current, site-appropriate accreditation is treated as a non-covered service, and because sessions accumulate toward a ten-hour benefit per patient, a lapse can affect every claim billed during that gap.

Is DSMT the same service as medical nutrition therapy?

No. They're distinct, separately billable Medicare benefits with their own hour allotments and referral requirements. DSMT covers broader self-management skills like glucose monitoring and medication management, delivered by a DSMT-accredited program, while MNT is nutrition-specific counseling delivered by a registered dietitian. A patient can receive both in the same year under separate referrals.

Does a patient need a new referral every year for DSMT follow-up training?

The referral needs to specify whether training is initial or annual follow-up, since these draw from different hour allotments — ten hours initially, two hours annually thereafter. Practices should confirm a current, valid referral is on file before each new benefit period's training begins, tracked against that patient's specific utilization rather than assumed to carry over automatically.

Coding & Reimbursement

DSMT Billing 2026: G0108/G0109, the Accreditation Requirement, and Why It's Not the Same Service as MNT

By Rcmaxis Revenue Cycle Team · September 2026 · 12 min read

Patient performing a self-administered blood glucose test as part of diabetes self-management education

Diabetes self-management education and support is billable as its own service, separate from medical nutrition therapy and separate from CGM device billing — and practices that fold it into a general diabetes visit instead of billing G0108 or G0109 directly are leaving a distinct, ten-hour-per-patient revenue stream almost entirely on the table.Source: CMS Medicare Learning Network, Diabetes Self-Management Training benefit

Diabetes self-management education and support is a specific, separately billable Medicare benefit — up to ten hours of initial training in the first twelve months, plus two hours of follow-up training in each subsequent year — and it's routinely confused with, or absorbed into, two other diabetes-adjacent services that bill completely differently: medical nutrition therapy and continuous glucose monitor management. The result is a service that's fully covered and fully billable under its own code family, delivered informally as part of a general visit, and never billed as the distinct service it actually is.

This guide covers the G0108/G0109 code structure, the accreditation requirement that has to be in place before a practice can bill DSMT at all, and exactly where this service starts and stops relative to MNT and CGM billing so none of the three get billed as though they cover the same thing.

G0108 and G0109: Individual vs. Group Training

DSMT bills under HCPCS codes G0108 and G0109, structured around individual or group training sessions, with the hour allotment and physician referral requirement forming the core of the coverage rule.

Code	Description	Setting
G0108	DSMT, individual, per 30 minutes	One-on-one training session
G0109	DSMT, group session (2 or more), per 30 minutes	Group training session

Medicare generally expects group training to be used when clinically appropriate, with individual sessions reserved for situations where group training isn't suitable — a hearing-impaired patient, a language barrier the group setting can't accommodate, or a physician-documented reason group training won't work for that specific patient. Billing every session as individual training by default, without documenting why group training wasn't appropriate, is a pattern payers specifically look for.

The Accreditation Requirement That Comes Before Any of This

DSMT can only be billed by a program that holds current accreditation from a recognized body — the American Diabetes Association's Education Recognition Program or a comparable CMS-recognized accrediting organization. This isn't a background administrative detail; it's a coverage prerequisite that has to be verified and current before a single session gets billed.

Billing G0108 or G0109 through a program whose accreditation has lapsed, was never obtained, or doesn't cover the specific site where training was delivered is a straightforward non-covered-service denial — and because DSMT sessions accumulate across a ten-hour initial benefit per patient, an accreditation gap discovered after the fact can affect every DSMT claim billed during the lapse across the entire patient panel, not just one visit. Practices adding a new training location or a new instructor need to confirm that specific site or credentialing update is covered under the existing accreditation, not assumed to extend automatically.

The practical safeguard is treating accreditation status as something the billing team actively tracks and confirms on a recurring schedule — expiration date, site coverage, instructor credentialing — rather than a one-time setup step that gets filed away and never revisited until a payer questions it.

Where DSMT Stops and MNT Starts

DSMT and medical nutrition therapy are both diabetes-related, both separately billable, and routinely confused as the same service or billed as though one substitutes for the other — they don't, and Medicare treats them as genuinely distinct benefits with their own hour allotments and referral requirements.

DSMT (G0108/G0109) covers broader self-management skills — glucose monitoring technique, medication management, recognizing and responding to hyper- and hypoglycemia, lifestyle and behavior change — delivered by a DSMT-accredited program.
MNT (97802-97804) is specifically nutrition therapy delivered by a registered dietitian, covering an initial assessment and follow-up nutritional counseling, billed under its own separate benefit with its own separate hour allotment.
A patient can receive both DSMT and MNT in the same year, under their own separate referrals and hour limits, but one doesn't substitute for or reduce the other's covered hours — billing an MNT session as though it exhausts part of the DSMT benefit, or the reverse, misrepresents what was actually delivered.
CGM device and supply billing (its own HCPCS/CPT code family, covered in a related guide) is a third, entirely separate service — device supply and data interpretation, not education — that shouldn't be confused with either DSMT or MNT for billing purposes.

The confusion usually isn't malicious — a diabetes educator delivering a session that touches on both self-management skills and dietary guidance in the same conversation is delivering genuinely overlapping clinical content, but the billing still needs to reflect which specific benefit that time was documented under, based on who delivered it and under which program's accreditation.

The Referral Requirement and Timing

DSMT requires a physician or qualified provider referral stating the diagnosis and confirming the need for training, and getting the referral's timing and content right avoids one of the more common technical denials in this code family.

The referral needs to be obtained before training begins, not backdated or obtained retroactively after sessions have already started.
The referral should specify the diabetes diagnosis and, where applicable, note whether this is initial training or annual follow-up training, since the two draw from different hour allotments.
Track each patient's hours used against their specific benefit period — the ten-hour initial allotment runs across the twelve months following the first training session, and the two-hour annual follow-up allotment resets each subsequent year — so a patient doesn't get billed past their available hours for that period.

A program that tracks referral dates and hours used per patient, rather than treating DSMT billing as a flat per-session charge without reference to the individual patient's remaining benefit, is the one that avoids the denials that come from exceeding an allotment nobody was actively tracking.

OIG and Payer Focus: Accreditation and Referral Documentation

DSMT billing reviews tend to focus on two specific things: whether the billing program's accreditation was genuinely current and site-appropriate for every billed session, and whether a valid, timely physician referral exists supporting the training. Both are binary, verifiable facts rather than clinical judgment calls, which makes them straightforward for a reviewer to check and straightforward for a practice to get wrong through simple administrative drift.

Reviews have found DSMT billed under lapsed accreditation, billed at sites not covered under the program's accreditation scope, and billed without a valid referral on file predating the training — each a documentation gap rather than a clinical dispute, meaning these findings are difficult to successfully appeal once identified. The standard 36-month lookback period means an accreditation or referral gap from early in the review window can still surface in a current audit, with recoupment calculated across every affected claim during the gap period.

Because these two requirements are entirely administrative rather than clinical, the fix is entirely process-based: a recurring accreditation-status check on a fixed schedule, and a referral-on-file verification built into the DSMT intake workflow before the first session is ever scheduled, not discovered as missing when a claim is already under review.

Common DSMT Denial Patterns

DSMT billed under lapsed, missing, or site-inappropriate accreditation: Fixed by tracking accreditation status, expiration, and site coverage on a recurring schedule.
Individual sessions billed by default without documenting why group training wasn't appropriate: Fixed by defaulting to group training and documenting the specific reason whenever individual sessions are used instead.
DSMT and MNT hours confused or billed as substituting for one another: Fixed by tracking each benefit's hours separately, tied to which program and provider actually delivered the session.
Sessions billed without a valid, timely physician referral on file: Fixed by verifying a dated referral exists before scheduling the first training session, not after.

DSMT is one of the more overlooked corners of diabetes billing precisely because it doesn't fit neatly next to the higher-profile device and technology billing — CGM supplies, RPM codes — that gets more attention as diabetes care becomes more connected and data-driven. The education and support work behind actually managing the condition day to day is still a distinct, well-defined, separately payable benefit, and the practices capturing that revenue are the ones treating accreditation status and referral documentation as fixed administrative checkpoints rather than assumptions carried over from whenever the program was first set up. None of this requires new clinical work — it requires billing the self-management training that's likely already happening as the specific, named benefit it actually is.

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References

CMS. Medicare Learning Network: Diabetes Self-Management Training. cms.gov
American Diabetes Association. Education Recognition Program Accreditation Standards. diabetes.org
Association of Diabetes Care & Education Specialists. DSMT Billing and Accreditation Guidance. diabeteseducator.org
American Medical Association. HCPCS Coding Guidelines: G0108 and G0109. ama-assn.org
HHS Office of Inspector General. Work Plan: Diabetes Self-Management Training Billing Review. oig.hhs.gov
MLN Matters. Medical Nutrition Therapy and DSMT Benefit Distinctions. cms.gov
Academy of Nutrition and Dietetics. Medical Nutrition Therapy Coverage and Coding Guidance. eatrightpro.org