Diabetes prevention program marketing rules

The Medicare Diabetes Prevention Program is a year of group or online sessions for people with Medicare who have prediabetes. It is delivered by enrolled suppliers, which can be medical practices, health systems or community organizations, and it runs under its own set of federal rules: who qualifies, what a supplier has to tell people before the first session, which formats count, and what a supplier may give participants to keep them engaged. Several of those rules reach straight into marketing. One of them says that the availability of an engagement incentive must not be advertised at all. This guide walks through the rules a supplier’s website, flyers, ads and outreach have to respect, using the regulation text, the CMS model page and the Medicare.gov coverage page.

Two related topics have their own guides and are not repeated here. Diabetes self-management training for people who already have diabetes, including accreditation wording and referrals, is covered in our diabetes education program marketing guide. Weight loss clinics, medication programs and before and after claims are in our weight loss clinic marketing guide.

This is general information, not legal or medical advice. Sources cited were checked on October 30, 2026: 42 CFR 410.79, 424.205 and 424.210, the CMS Innovation Center page Medicare Diabetes Prevention Program (MDPP) Expanded Model, the CMS 2026 MDPP social media toolkit, the Medicare.gov page Medicare Diabetes Prevention Program, 42 CFR 1001.952(ii), 45 CFR 164.501 and 164.508, 47 CFR 64.1200, 42 U.S.C. 1320a-7a and 1320a-7b, 15 U.S.C. 45 and 52, and the FTC policy statements on deception and advertising substantiation. Payment amounts are not covered here. Medicare Advantage plans and state rules can add their own conditions, set plan by plan and state by state.

What the program is, in the words CMS uses

The CMS Innovation Center page describes the program as an evidence-based behavior change intervention to delay or prevent the onset of type 2 diabetes among people with Medicare, covered under Part B as a preventive service. The regulation at 42 CFR 410.79 defines the services as structured health behavior change sessions that follow a CDC-approved curriculum and provide practical training in long-term dietary change, increased physical activity and problem-solving strategies for maintaining weight loss and a healthy lifestyle.

The structure is fixed. Under 410.79(c)(2), the core services period is the first 12 months: up to 16 core sessions at least a week apart in months 1 through 6, then up to 6 core maintenance sessions at least a month apart in months 7 through 12. The CMS page adds that suppliers may offer more than 22 sessions, but Medicare pays for up to 22 per eligible person. Under 424.205(c)(10), a supplier must offer no fewer than the 16 core sessions and the monthly maintenance sessions, except in the narrow cases where it may decline access.

For marketing, this means the program description on your page can be specific without guessing. Say it is a 12 month program, say there are 16 weekly sessions followed by 6 monthly sessions, and say what the sessions cover in the regulation’s terms. Avoid describing it as a diet, a weight loss treatment or a medical program for diabetes. It is a prevention program for people who do not have diabetes.

Who can offer it, and how to describe your recognition

An MDPP supplier is an entity enrolled in Medicare to furnish these services under 424.205. To enroll and stay enrolled, the supplier must hold preliminary, full or full plus recognition from the CDC Diabetes Prevention Recognition Program, keep a roster of coaches that CMS screens, and revalidate its enrollment every 5 years. The regulation defines full recognition as CDC’s designation that an organization has consistently furnished CDC-approved sessions and met CDC’s performance and reporting requirements, and full plus as full recognition with additional retention criteria met.

Those are the terms to use. If your organization holds preliminary recognition, say preliminary recognition. Do not shorten it to CDC certified, CDC approved or endorsed by CDC, since the regulation uses approved for the curriculum, not for the organization, and recognition is a status that can change. Put the recognition level on the program page and update it when it changes. The Medicare.gov page tells patients that suppliers may be traditional health care providers or organizations like community centers or faith-based organizations, so a supplier that is not a medical practice should not dress itself up as one.

Coaches matter here too. Under 424.205(b)(4) and (d), coaches are listed on the enrollment and screened by CMS, and an ineligible coach may not furnish services. If your page introduces coaches, introduce the people who are actually on the roster, with their real training, and do not call them clinicians, dietitians or nurses unless they hold those licenses.

Eligibility, in words a reader can check

Under 410.79(c)(1)(i), a person is eligible if all of these are true: they are enrolled in Part B; on the date of the first core session they have a body mass index of at least 25, or at least 23 if they self-identify as Asian; within the 12 months before that session they had a hemoglobin A1c between 5.7 and 6.4 percent, a fasting plasma glucose between 110 and 125 mg/dL, or a 2-hour plasma glucose between 140 and 199 mg/dL; they have no previous diagnosis of diabetes other than gestational diabetes; and they do not have end-stage renal disease. The Medicare.gov page lists the same criteria in plain language.

This list is the best piece of content a supplier page can carry, because it lets a reader check for themselves before they call. Give it in full, link to the Medicare.gov page, and say that a recent blood test result is part of the check. Medicare.gov tells patients to check with their doctor to find out if they are eligible, which gives you a natural line to use: ask your doctor about your latest blood sugar test, or bring the result to your first call.

Two cautions. First, eligibility is a medical fact about the person, so your screening questions collect health information; see the privacy section below. Second, do not reword the criteria into something looser, such as for anyone worried about diabetes or for seniors who want to lose weight. A person who does not meet the criteria is not eligible for the Medicare benefit, and an ad that suggests otherwise misleads the people it reaches.

Once per lifetime, and what the Medicare.gov page says

The regulation treats the benefit as once in a lifetime. Under 410.79(c)(1)(i)(B), a person must not have previously received the set of MDPP services in their lifetime, and 424.205(c)(11)(i) requires suppliers to tell people about the once-per-lifetime nature of the services before the first session.

On the check date, the Medicare.gov coverage page showed a different message in the field that says how frequently a person can use the benefit: there is no limit to the number of times you can participate. We did not find a rule change that would explain the difference. Our suggestion is to follow the regulation in your own materials, say once per lifetime, and if you have a reason to think the benefit has changed, confirm it with CMS in writing before you advertise anything else. Telling a person they can repeat the program, and then finding their claim denied, is the kind of surprise that ends in a complaint.

Cost wording

The Medicare.gov page says: You pay nothing if you qualify. The CMS 2026 social media toolkit, written for partners to share, uses at no cost to you and, in one post, describes it as a free program for people who may qualify. So a cost line is supported by the government’s own materials, as long as the condition stays attached.

Keep three things next to any cost line. First, the qualification: no cost if you qualify, followed by the criteria or a link to them. Second, Medicare Advantage: the Medicare.gov page says a person in a Medicare Advantage plan may have to go to an in-network provider, so tell those readers to check with their plan. Third, the cap: the CMS page says Medicare pays for up to 22 sessions, so if you offer extra sessions or add-on services, say clearly whether those cost anything before the person signs up.

If your organization also runs a cash-pay lifestyle program for people who are not eligible for Medicare’s benefit, keep it on a separate page with its own price and its own name. Mixing the two invites the reader to assume the paid program is the covered one.

Formats: in person, distance learning and online

Under 410.79, sessions can be delivered in person, by distance learning, where a coach teaches live and participants join by phone or video from another location, or online. The online format is defined as sessions delivered entirely through the internet, at the participant’s own pace, without a live coach teaching the content. The regulation sets an online delivery period from January 1, 2026 to December 31, 2029, and the CMS page says the CY 2026 Physician Fee Schedule final rule added this coverage and clarified that suppliers do not need to keep in-person delivery sites to deliver the program online during that period.

Online delivery comes with conditions that shape how you describe it. Under 410.79(f), live coach interaction must be offered to each participant during weeks when they engage with content. Emails and texts count only when the participant can respond and get support from the live coach. Chat bots and AI forums do not count as live coach interaction, and suppliers may not use AI or machine learning to replace it. Coaches must track engagement and use proactive outreach to encourage session completion and weight reporting.

So if you market an online version, do not present an automated assistant as the coach, and do not promise round the clock coaching if what you offer is a person who answers within the week. Say which format the person is signing up for, since 410.79(f) does not allow a supplier to bill online sessions alongside in-person or virtual sessions for the same person during the online delivery period. A participant picks one track.

What you must tell people before the first session

Section 424.205(c)(11) requires the supplier, before the first core session, to disclose detailed information about the set of services to each person it wishes to serve. The disclosure must include the eligibility requirements, including the once-per-lifetime nature of the services, the minimum coverage requirements in 410.79(c)(2), and the supplier standards in 424.205(c).

Build this disclosure into your intake, not into the fine print of an ad. A one-page summary in plain language, handed out or sent before the first session and kept in the record, does the job and doubles as the best answer to the questions people ask on the phone. Section 424.205(c)(12) also requires suppliers to answer questions and respond to complaints within a reasonable timeframe and to keep a complaint resolution protocol, so the contact details on your page should reach someone who can answer.

Engagement incentives: allowed, but not advertised

Suppliers may give participants in-kind items or services to keep them engaged, under 42 CFR 424.210. The conditions are specific. The item or service must be furnished directly by the supplier or its agent, be reasonably connected to the curriculum, and advance one of the program’s clinical goals, which the rule lists as attendance, weight loss, long-term dietary change and adherence to long-term health behavior changes. It must not be tied to other services or to a particular provider, supplier or coach, and its cost must not be shifted to the participant or to another federal health care program.

The marketing rule is in 424.210(b)(6): the availability of the item or service must not be advertised or promoted as an engagement incentive, except that a participant may be told about it at the time they could reasonably benefit from it during the engagement incentive period. In practice, no ad, flyer, landing page or social post should mention a gift, a scale, a pedometer, a gift card or any other incentive as a reason to join. Tell participants about an item when it becomes useful to them inside the program, not before.

Technology items have caps under 424.210(c): items involving technology may not exceed $1,000 in retail value in total for one participant, and technology items over $100 in retail value remain the supplier’s property and must be retrieved at the end of the engagement incentive period, with retrieval attempts documented. Under 424.210(e), any incentive over $25 in retail value must be documented when it is furnished.

Outside those conditions, the general federal rules apply. The civil monetary penalty provision at 42 U.S.C. 1320a-7a(a)(5) covers offering remuneration to a Medicare beneficiary that the offeror knows or should know is likely to influence the choice of a particular provider or supplier, and the anti-kickback statute at 42 U.S.C. 1320a-7b(b) covers paying anyone to induce referrals. The safe harbor at 42 CFR 1001.952(ii) for CMS-sponsored model patient incentives applies only where CMS has determined it is available for that model, so check that with counsel before relying on it.

Referrals from clinicians and from other suppliers

Eligibility depends on a recent blood test result, which puts primary care practices and other clinicians in a natural position to suggest the program. Reaching them with a clear one-page description, the eligibility criteria and a way to send a patient your way is fair outreach. Paying them per referral, giving them free services, or offering anything of value tied to the number of people they send is where 42 U.S.C. 1320a-7b(b) comes in. Our patient and physician referrals guide covers that in more detail.

Section 424.205(c)(9) adds a rule of its own: the supplier, and anyone performing functions for it, must not unduly coerce a participant’s decision to change or not to change to a different supplier, including through pressure, intimidation or bribery. If a person is already in another supplier’s program, your outreach should not try to pull them over with offers or pressure.

Who you can turn away, and why your ads should not hint at it

Under 424.205(c)(8), a supplier must not deny a participant access to services during the services period, including on the basis of weight, health status or achievement of performance goals. The only permitted reasons are that the person no longer meets eligibility, the supplier lacks its own publicly posted capacity, or the person significantly disrupts sessions or becomes abusive. Declines for capacity or disruption must be recorded.

That rule should shape your copy. Language like for motivated people who are ready to lose weight, or we accept participants we think will succeed, suggests a screening the rule does not allow. Write for everyone who meets the eligibility criteria. If capacity is limited, post the limit publicly, which the rule itself refers to, and say how people join a waiting list.

Privacy and outreach messages

Section 424.205(g)(4) requires suppliers to handle participant information, including personally identifiable information and protected health information, as would be required under HIPAA, other applicable federal and state privacy laws and CMS standards. That applies to community organizations as well as practices. Your eligibility screening form, your intake calls and your reminder messages all carry health information, so they belong in tools set up for it.

For a covered entity inviting its own patients, 45 CFR 164.501 excludes from the definition of marketing a communication that describes a health-related service the covered entity provides, and communications for treatment or care coordination, unless the covered entity receives financial remuneration from a third party for making it. A supplier that is paid by an outside party to promote the program is in a different position: under 45 CFR 164.508(a)(3), marketing that involves financial remuneration to the covered entity needs the individual’s authorization, and the authorization has to say so.

Reminder calls and texts fall under the Telephone Consumer Protection Act rules at 47 CFR 64.1200, which set consent requirements for autodialed and prerecorded calls and texts to wireless numbers and restrict telemarketing. Get consent for texts at intake, keep the messages short and free of clinical detail, and honor opt-outs. Our text message reminders guide covers the mechanics.

Claims about weight loss and preventing diabetes

The CMS page says the program has demonstrated effectiveness in delaying or preventing the onset of type 2 diabetes among people with prediabetes, and CMS’s own social posts say the program can help people prevent type 2 diabetes. Those are statements about the program, made by CMS. They are not a promise about any one person, and they are not evidence of your own results.

Under 15 U.S.C. 45 and 52 and the FTC’s policy statements, advertising claims must not mislead and objective claims need a reasonable basis before they run. For a supplier, that rules out lines like you will not get diabetes, weight loss you can count on, or lose 5 percent in 6 months. The 5 percent figure is the required minimum weight loss the regulation uses for performance payments, a measure of what Medicare pays for, not a result to promise. Results statements about your own cohorts need records behind them, the right comparison, and the context a reader needs to understand them.

Safer wording stays with what the program is: a year of sessions on eating, activity and problem solving, with a trained coach, designed to help people with prediabetes lower their risk. If you quote CMS, attribute the line to CMS and use its words, including or delay. Testimonials from participants are subject to the same rules; our weight loss guide linked above covers before and after claims.

Illustration: two program pages

Illustration: A community organization launches a program page with the headline Free diabetes program, lose weight and get a free fitness tracker. The page says anyone over 65 can join and that participants who reach their goals get a gift card. Each of those lines runs into a rule: the incentive offers break 424.210(b)(6), the eligibility is wider than 410.79, the cost line drops the condition, and the weight loss line is a promise.

Illustration: The same organization rewrites the page. The headline says a 12 month program for people with Medicare who have prediabetes. The page lists the eligibility criteria and links to Medicare.gov, says no cost if you qualify and that Medicare Advantage members should check with their plan, states the recognition level held, explains the in-person and online options and that a live coach responds to participants, notes the once per lifetime rule, and gives a phone number answered by staff. Incentives are not mentioned; coaches tell participants about items when they become useful inside the program.

Checklist

The program is described as 16 weekly sessions and 6 monthly sessions over 12 months, in the regulation’s terms.
The recognition level is stated as preliminary, full or full plus, with no certified or endorsed wording.
The eligibility criteria from 410.79(c)(1) appear in full, with a link to the Medicare.gov page.
The once per lifetime rule is stated, and the pre-session disclosure under 424.205(c)(11) is part of intake.
Cost lines keep the condition: no cost if you qualify, Medicare Advantage members check with their plan, extra services priced separately.
The format is named, and online materials do not present AI as the coach.
No ad, flyer, page or post mentions an engagement incentive.
Technology incentives stay within the 424.210(c) caps, and incentives over $25 are documented.
No payment or anything of value goes to referral sources per referral, and no pressure is used on people in another supplier’s program.
Copy does not hint at screening by weight, health status or likely success.
Screening forms and reminders run in tools set up for health information, with text consent at intake.
No promise of preventing diabetes or of a set amount of weight loss; CMS lines are quoted and attributed.

Screening that finds prediabetes is the step before referral; our guide to prediabetes and diabetes screening outreach covers the USPSTF recommendation and the Medicare screening benefit.

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and health businesses. For a diabetes prevention program supplier, that means a website page that carries the eligibility criteria, cost wording and recognition level the way the rules state them, outreach that leaves incentives out, and inquiry flows that send eligibility questions to staff who can check them. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. We do not sell lead lists and we do not pay for referrals. For the wider rules, see our healthcare marketing rules hub.

Who is eligible for the Medicare Diabetes Prevention Program?

Under 42 CFR 410.79(c)(1), a person enrolled in Part B with a body mass index of at least 25 (23 if they self-identify as Asian), a qualifying A1c, fasting glucose or 2-hour glucose result within the past 12 months, no previous diabetes diagnosis other than gestational diabetes, and no end-stage renal disease.

Can we say the program is free?

The Medicare.gov page says you pay nothing if you qualify, and the CMS partner toolkit uses no cost wording. Keep the condition attached, and tell Medicare Advantage members to check with their plan.

Can we advertise a gift or a free device for joining?

No. Under 42 CFR 424.210(b)(6), the availability of an engagement incentive must not be advertised or promoted. A participant may be told about an item when they could reasonably benefit from it during the program.

Can a person take the program more than once?

The regulation describes a once-per-lifetime benefit and requires suppliers to disclose that. The Medicare.gov page showed a no limit message on our check date, so confirm with CMS in writing before advertising anything other than once per lifetime.

Can an online program use an AI coach?

Not as the coach. Under 42 CFR 410.79(f), chat bots and AI forums do not count as live coach interaction, and suppliers may not use AI or machine learning to replace it.

Can we turn away people who are unlikely to lose weight?

No. Under 42 CFR 424.205(c)(8), a supplier may not deny access on the basis of weight, health status or achievement of performance goals. The permitted reasons are loss of eligibility, publicly posted capacity limits and serious disruption or abuse.

Sources

More in Dental, vision, hearing and therapy marketing

Medicare Diabetes Prevention Program marketing: eligibility, cost wording, incentives and what suppliers can say