ADA, AAPD file joint comments on CMS proposed rule

Washington — The ADA and American Academy of Pediatric Dentistry submitted joint comments to the Centers for Medicare & Medicaid on updates to the proposed 2022 notice of benefit and payment parameters for the Affordable Care Act.

In a July 28 letter to CMS Administrator Chiquita Brooks-LaSure, the two organizations commented on these three sections of the proposed rule:

  • State exchange direct enrollment options: The ADA and AAPD said they are relieved the current proposed rule repeals the exchange direct enrollment option because they believe it would’ve harmed consumers.
  • Extending the annual open enrollment period: The two organizations said they support CMS extending the annual open enrollment period and implementing a 75-day period of enrollment beginning with the 2022 plan year. They also said allowing consumers additional time to review options, including stand-alone dental plans “will further grow this benefit and further reduce the number of uninsured Americans.”
  • Proposed low-income special enrollment period to expand access to marketplace coverage: The ADA and AAPD support a plan to further expand access to marketplace coverage by creating a new special enrollment period for consumers who are eligible for advance premium tax credits and whose household income is under 150% of the federal poverty level. This new, year-round special enrollment period for low income consumers “could reduce the number of uninsured who are healthier and younger.” The ADA and AAPD added that they “remain concerned” over the future end point of COVID-19, which would end maintenance of effort requirements in the Medicaid program and “could trigger a mass disenrollment” of those who maintained their Medicaid coverage since the onset of the pandemic. “We favor a permanent mechanism to smoothly transition those persons from the Medicaid program into an ACA SEP for low-income persons” they said.

For more information on the ADA’s advocacy efforts, visit

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