ADA comments on HHS draft strategic plan

Washington - The ADA is asking the U.S. Department of Health and Human Services to prioritize several dental issues as the agency works to finalize its five-year strategic plan.

In a Nov. 5 letter to the HHS Office of the Assistant Secretary for Planning and Evaluation, ADA President Cesar R. Sabates, D.D.S., and former Executive Director Kathleen T. O'Loughlin, D.M.D., offered comments on the sections of the plan the Association believes will most impact dentistry and the oral health of the public.

Regarding the strategic plan's objective of expanding equitable access to "comprehensive, community-based, innovative, and culturally competent health care services" and supporting community-based services to meet the diverse health care needs of underserved populations, the ADA commented on how best to expand access to oral health care, including diagnostic, preventive and restorative services.

"Despite many oral health advancements over the last half century, oral health disparities and inequities continue," Drs. Sabates and O'Loughlin wrote. "The Surgeon General's 2000 report, 'Oral Health in America,' identified systemic disparities and inequities in social determinants of oral health that disproportionately prevent those in vulnerable communities from accessing the resources needed to achieve and maintain their oral health, and in turn, their overall health. Failing to successfully address the social determinants as an underlying contributor to oral health disparities will certainly continue what the [report] defined as the silent epidemic of dental disease leading to devastating consequences for individuals and communities."

The ADA comments also shared the policy it adopted in 2021 defining oral health equity as optimal oral health for all people.

"The ADA is committed to promoting equity in oral health care by continuing research and data collection, advocating to positively impact the social determinants of oral health, reinforcing the integral role of oral health in overall health, supporting cultural competency and diversity in dental treatment, advancing disease prevention education, and supporting efforts to improve equitable access to oral health care," Drs. Sabates and O'Loughlin stated.

To address "socioeconomic and racial/ethnic disparities, the ADA supports the inclusion of adequately funded adult dental services in state Medicaid programs and believes that dentalcare should be a required benefit of Medicaid programs."

Regarding HHS' plan to drive the integration of behavioral health into the health care system, the ADA said it applauds the agency for recognizing the need to expand access to treatment for substance use disorders and to improve care through better integrated health care services particularly given "the scourge of opioid-related addictions, overdoses, and deaths that have been ravaging" families and communities.

"The ADA encourages HHS to continue supporting programs that would help dentists manage acute pain with minimal use of opioid pain relievers, screen patients for risky substance abuse behaviors, and briefly counsel and refer those patients for appropriate treatment," Drs. Sabates and O'Loughlin wrote. The ADA said this includes continued support for the Providers' Clinical Support System for Opioid Therapies and encouraged HHS to work closely with the Drug Enforcement Administration to help bolster state prescription drug monitoring programs.

The ADA comments also said it supports HHS' plan to bolster the health workforce and address barriers to strengthening the health workforce.

"The ADA greatly appreciates HHS' efforts to bolster the dental workforce," Drs. Sabates and O'Loughlin said. "In order to ensure that patients can get access to dental care, there must be an adequate number of dentists, dental hygienists and other dental team members."

The ADA comments noted that COVID-19 has exacerbated the shortages of these professionals and shared the American Dental Association Health Policy Institute's August findings that 90% of dentist owners reported that it is extremely or very challenging to recruit dental hygienists, and 63% said that it is extremely or very challenging to recruit dentists compared with before the pandemic. HPI also said 85% of dentist owners are finding it extremely or very challenging to fill dental assistant positions. It is critical that HHS find ways to fill the shortages of these positions because the vacancies are limiting dental practices' abilities to see more patients, the Association said, and encouraged HHS to support the use of Community Dental Health Coordinators, or CDHCs, to link patients to available, but underutilized, sources of dental care.

Regarding HHS' desire to improve capabilities to prepare and recover from emergencies, disasters, and threats across the nation and globe, Drs. Sabates and O'Loughlin said the ADA welcomes the opportunity to work with its federal partners and noted that in January, the CDC affirmed that dentists are essential health care personnel and dental care is an essential health care service.

For the objective on promoting healthy behaviors to reduce occurrence and disparities in preventable injury, illness and death, Drs. Sabates and O'Loughlin told HHS that dental caries "remains the most common preventable chronic disease of children" and said "education is critical," as are evidence-based population health measures such as community water fluoridation.

Lastly, the comments discussed the economic impact of dental practices on the community, as well as the economic impact of good oral health on individuals.

Read the letter in full at

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