ADA responds to CMS request for information on establishing national directory

Directory would serve as 'centralized data hub' for health care providers, others

The ADA is willing to work with the Centers for Medicare & Medicaid Services to establish a national provider directory that includes dentists, the Association said in response to the agency's request for information.

In comments sent Dec. 6 to CMS Administrator Chiquita Brooks-LaSure, ADA President George R. Shepley, D.D.S., and Raymond A. Cohlmia, D.D.S., said the ADA believes in the timely and accurate updating of provider directories because they have the potential to reduce confusion for beneficiaries and can help them access dental care.

The ADA said it stands ready to work with CMS on developing a national provider directory and offered suggestions on the best way to do this for dentistry. The comments focused on interactions with current CMS data systems and impacts to business practices, as well as a phased approach to implementation.

The Association noted that the statutory definition of physician under the Social Security Act is clear in including doctors of dental surgery or dental medicine as physicians, which reinforces the ADA's belief that dentists should be included in a national directory of providers.

The ADA also noted that it "strongly supports" the efforts of the U.S. Department of Health and Human Services to integrate Fast Healthcare Interoperability Resources-based application programming interfaces into a national directory of health care providers and services. The ADA also said it supports HHS efforts to integrate these resources in order to make directory information more accessible but noted that dental practice management and record systems have limited adoption of Fast Healthcare Interoperability Resources. The ADA said that it supports incentives and significant investment in dental-specific Fast Healthcare Interoperability Resource-based pilots and technology to move the dental industry towards Fast Healthcare Interoperability Resource-based application programming interfaces that could be used to make the directory data interoperable.

The ADA encouraged CMS to work with organizations and states where dentists are already included in provider directories to both avoid duplication and implement best practices for a potential CMS national directory. The ADA encouraged the agency to work with states to understand their experience of regulating insurance network directories for accuracy, particularly those states that require insurance companies to maintain provider directories.

Regarding implementation, the ADA urged CMS to minimize the burden on small dental practices by providing them with financial incentives to share data with the directory and update that data as needed. The ADA also noted that it is "critical that dentists not be penalized for errors in the directory that are beyond their control or the fault of another party" and encouraged CMS to consider a collaborative review process. The Association also recommended that CMS continue to work closely with CAQH, a nonprofit alliance of health plans and trade associations that specializes in health care technology solutions with nearly two decades of experience.

In response to what issues CMS should anticipate throughout a national provider's development life cycle, the ADA said maintaining reliable data in the directory is the biggest hurdle to development and implementation.

Read the comments in full at .

For more information on all of the ADA's advocacy efforts, visit .

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