ADA responds to CMS request for information on access to care in Medicaid

Association asks agency to prepare for mandated adult dental benefits

The ADA has many suggestions for how the Centers for Medicare & Medicaid Services can support states in improving access to dental care for Medicaid beneficiaries, the Association said in an April 6 response to the agency's request for information .

In the response, the ADA applauded CMS for its proactive approach to developing and implementing a comprehensive access strategy in Medicaid and the Children's Health Insurance Program.

The Association urged the agency to prepare for a potential Congressionally-mandated adult dental benefit in Medicaid by defining what constitutes a minimum set of dental services for adults in the Medicaid program, using the Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit as a model.

The ADA also asked CMS to establish a new viable facility billing code (HCPCS Level II) for dental rehabilitation surgery in Medicare, as this would increase access to dental care in operating room settings for Medicaid populations with significant needs, such as children with early childhood caries and adults with disabilities with extensive dental needs.

Other highlights from the request include asking CMS to:

• Work with states to establish benchmarks for quality measures, initially using historical trends in the privately insured population in the state.
• Provide guidance to states on opportunities to use care coordinators such as community dental health coordinators to connect beneficiaries to dental care.
• Work with the Health Resources and Services Administration to deploy a revised health professional shortage area algorithm similar to the one used by the ADA Health Policy Institute.
• Support oral health coverage for pregnant and postpartum people enrolled in Medicaid and CHIP.
• Provide guidance to states on incentivizing interprofessional referrals to promote whole person care.
• Consider setting targets for state agencies' Medicaid provider networks to progress toward reflecting their state's racial and ethnic profile in an effort to diversify the health professional workforce.
• Support payment parity for services delivered via teledentistry.
• Develop subject matter expertise within the agency that can assist state agencies with their discussions and negotiations with state licensing and professional boards to promote licensure portability.
• Incentivize dental providers, plans, contractors and state agencies to report diagnosis using standardized coding systems - such as the International Classification of Disease code - on claims.
• Require states to conduct a regular - such as annual or tri-annual - assessment of their fee policies and make this data publicly accessible.
• Phase out the discriminatory practice of paying different rates for the same services for different populations or eligibility groups. Payment rates for all CMS programs should be on par with other CMS programs (e.g. Medicaid and CHIP) and should be benchmarked to state-level private insurance rates (using FAIR Health data, ideally).
• Issue guidance to states on innovative payment models and pilot projects. Some of these innovations include paying for risk assessment and implementing performance-based supplemental payments in managed care plans.
• Require states to use private insurance reimbursement rates - specifically, the 50th percentile of dentist charges in the state as tabulated by FAIR Health - as an appropriate benchmark for fees.

The ADA also shared the ADA-developed Medicaid managed care contracting toolkit,
Medicaid: Considerations When Working with States to Develop an Effective RFP/Dental Contract .

To read the ADA's request for information response in full, visit ADA.org .

Follow all the ADA's advocacy efforts at ADA.org/Advocacy .