ADA, AAPD file joint comments with CMS

Comments in response to Affordable Care Act’s Notice of Benefit and Payment Parameters

The American Dental Association and American Academy of Pediatric Dentistry filed comments Jan. 30 on the Centers for Medicare and Medicaid Services’ proposed 2024 notice of benefit and payment parameters for the Patient Protection and Affordable Care Act.

In a joint letter to CMS , ADA President George R.Shepley, D.D.S., and AAPD President Amr M. Moursi, D.D.S., Ph.D., said they appreciated the agency’s efforts to “provide quality, affordable coverage to consumers while minimizing administrative burden and advancing health equity.”

The two organizations commented on the following sections:

Uniform Age-Rating and Eligibility Methodology for Stand-Alone Dental Plans

The ADA and AAPD said they support a proposal that would require stand-alone dental plan issuers to “use the age on the effective date as the sole method to calculate an enrollee's age for rating and eligibility purposes” beginning in 2024. They did note it’s apparent that most issuers are already doing this and said that “setting one standard for all brings more certainty and less confusion when comparing plans for consumers regardless of which stand-alone dental plan they may choose.”

Guaranteed Rates for Stand Alone Dental Plans

Regarding allowing stand-alone dental plan issuers to offer either guaranteed or estimated rates, ADA and AAPD suggested using only the submission of guaranteed rates to allow for accurate advance premium tax credits of the pediatric dental essential health benefit portion of premiums. They added that “guaranteed rates add transparency and clarity for consumers.”

Network Adequacy

In response to a CMS proposal to revise network adequacy standards starting in 2024 by requiring all plans, including stand-alone dental plans, to comply with network adequacy requirements, ADA and AAPD said this would “aptly improve consumer choice and access to care.”

Plan Marketing Transparency

In response to CMS’ plan to require fair marketing practices of quality health plans, ADA and AAPD said they believe there should be “a standard marketing format used by plans that is simple (perhaps one-page), captures important cost considerations for consumers (e.g., coinsurance obligations), and provides direction to consumers on how to find participating providers.”

Dental plan marketing has been a significant concern in Medicare Advantage plans in recent years, and this is a proactive approach to preventing similar, potentially deceptive marketing of stand-alone dental plans,” the two organizations wrote.

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