ADA, AAPD file joint comments with CMS on Affordable Care Act

The American Dental Association and American Academy of Pediatric Dentistry filed comments Dec. 30, 2020, on the Centers for Medicare and Medicaid Services’ proposed 2022 notice of benefit and payment parameters for the Affordable Care Act.

In a joint letter to CMS , ADA President Daniel J. Klemmedson, D.D.S., M.D., and AAPD President Jessica A. Lee, D.D.S, M.P.H., Ph.D., said they appreciated the agency’s efforts to enhance the role of the states in Affordable Care Act programs by providing them with additional flexibilities, reducing unnecessary regulatory burdens on stakeholders, empowering consumers and improving affordability.

The two organizations commented on the following provisions that affect oral health care:

State Exchange Direct Enrollment Options
CMS is proposing “significant changes” to’s website portal functionality by allowing separate webpages from the traditional page to be utilized by states more easily. The changes would allow direct enrollment entities to create access points for coverage selection and states could request that CMS allow these to replace without a section 1332 waiver process. The two organizations are concerned this could lead to unintended consequences for consumers and noted that the Georgia waiver request to stop using as its portal required revisions before approval. “This more informal approval process proposed could ultimately lead to consumer confusion and less utilization of the marketplace as a result if they are unaware of new procedures for selecting coverage,” the ADA and AAPD wrote.

Separate Webpage Requirement
In response to the CMS proposal that direct enrollment entities use three separate webpages to distinguish between qualified health plans, non-qualified health plans and excepted benefits, the ADA and AAPD said that “Our overarching concern is that direct enrollment entities creating separate webpages from will be unknown to most consumers and they may not recognize new webpages if not properly advertised.”

Premium Adjustment Percentage
The ADA and AAPD said they are concerned about CMS’ proposal to change the way premium assistance is calculated because they believe it will continue to increase premiums for exchange plans and decrease enrollment for consumers who receive the premium tax credit. They also said they believe this decrease in enrollment may be even larger for stand-alone dental plans “because if lower income consumers have to pay more for medical plans they will have less funds to pay for dental and may have to go without dental coverage.”

Maximum Annual Out-of-Pocket Limit On Cost-Sharing
The proposed change in calculating the premium adjustment will also affect the maximum annual limitation on cost sharing. The new limitations will be $9,100 for self-only coverage, a $550 increase from 2020; and $18,200 for other than self-only coverage, an $1,100 increase from 2020. The ADA and AAPD believe that these increases in cost sharing will further increase the cost for consumers.

Quality Rating System
The ADA and AAPD continue to encourage CMS and plan issuers to seek input from the Dental Quality Alliance as the Meaningful Measures Initiative is implemented into quality reporting and quality improvement programs. The DQA was established at the request of CMS, and as a multi-stakeholder coalition is well-positioned to collaborate, coordinate and lead efforts on quality measures. For more information about the Dental Quality Alliance, visit for more information.

Follow all of the ADA’s advocacy efforts at .

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