ADA responds to CMS request for information on Medicare Advantage plans

Association urges agency to work with oral health stakeholders to improve transparency

The ADA has suggestions for how the Centers for Medicare & Medicaid Services can improve Medicare Advantage plans and their dental benefits, the Association said in an Aug. 31 response to the agency's request for information.

Medicare Advantage plans, sometimes called Medicare Part C, are a type of health plan offered by Medicare-approved private companies that must follow rules set by Medicare.

In the comments, the ADA addressed the following areas on how CMS can improve the plans: expanding access, collection and reporting of health equity data, medical loss ratio, and engaging partners.

Regarding how Medicare Advantage plans use rebate dollars to advance health equity and address the social determinants of oral health, the ADA said it believes CMS should collect and analyze data on supplemental benefits for lower income enrollees.

"The ADA believes that it is critical that CMS analyze data on supplemental benefits in the MA program, including who is enrolled by ages and income, what is covered and what benefits are being utilized," wrote ADA President Cesar R. Sabates, D.D.S., and Executive Director Raymond A. Cohlmia, D.D.S. "These are important data points for determining how to best advance oral health equity for MA beneficiaries."

Regarding how well MA plans do at marketing efforts to inform beneficiaries, the ADA said it is aware that enrollment in MA plans is expanding, including those Part C plans where beneficiaries have access to a dental benefit, but noted the range of services covered with these plans differ with some plans covering only preventive dental services and others offering a more comprehensive benefit.

The ADA noted that it does not have data to quantify how many enrollees are getting the different types of dental benefits, and urged CMS to collect that data.

"We believe that standardization in the benefits offered as part of a Part C plan would be beneficial for consumers," Drs. Sabates and Cohlmia wrote. "Beneficiaries need and deserve more transparency regarding dental benefits and plan design for their MA plan, including services covered, frequency limitations, and more."

Regarding the role of telehealth and MA plans, the ADA said teledentistry has the capability of expanding the reach of a dental home to provide needed dental care to populations experiencing distance barriers. The ADA response also noted that these encounters typically involve a dental hygienist who is on site with the patient, expanding the reach of dental professionals and increasing access to care.

"Having teledentistry-capable dental teams can reduce wait times for initial visits, expedite treatment planning and treatment delivery, and triage cases based on the needs of the population being served," Drs. Sabates and Cohlmia wrote. "The care provided is equivalent to in-person care, and as such, insurer reimbursement of services must be made at the same rate that it would be for the services when provided in-person."

CMS also asked responders to weigh in on what factors MA plans should consider when determining whether to make changes to their networks. The ADA said that the availability of a robust provider network is crucial to the success of any health plan.

"Plans must work not only for beneficiaries, but also for providers in order to build and sustain an adequate network," Drs. Sabates and Cohlmia wrote. "Building such a network includes establishing reasonable and appropriate fees for providers. This helps ensure beneficiaries have access to needed care."

The ADA recommended that CMS require MA plans to report on the following metrics representing various aspects of dental providers' experiences with and participation in the plans:

- Provider participation
- Network adequacy
- Credentialing
- Claims administration
- Provider satisfaction

The ADA also asked CMS to institute a dental loss ratio reporting requirement for the dental component of any MA plan.

The ADA response concluded by urging CMS to work with the ADA Dental Quality Alliance in the identification and endorsement of standardized tools for measuring beneficiary experience and oral health-related quality of life, such as the Consumer Assessment of Healthcare Providers and Systems Dental Plan Survey and the Oral Health Impact Profile.

"These tools could be incorporated into the Medicare Current Beneficiary Survey and/or required for MA plans to administer to their beneficiaries and report back to CMS," wrote Drs. Sabates and Cohlmia, who added that more information is needed from CMS regarding the beneficiary populations enrolled in traditional Medicare plans, MA plans and supplemental plans.

"To assess differences between the beneficiaries served by these plan types and evaluate whether care is being offered and delivered equitably to these different beneficiary populations, sociodemographic data - such as income, race and ethnicity, education, and more - needs to be available to CMS, plan administrators, researchers, and the public," they wrote.

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