ADA asks for transparency, payment parity and improved access in comments to CMS on proposed Medicaid rules

The ADA sent comments to the Centers for Medicare and Medicaid Services June 29 on two proposed Medicaid rules, one on fee-for-service and one on managed care.

Both rules propose strengthening provider payment rate transparency, but the ADA President George R. Shepley, D.D.S. and Executive Director Raymond A. Cohlmia, D.D.S. urged the agency to further improve transparency by requiring “more granular data within the dental category, such as utilization numbers, median fees, and service frequency” and to use “commercial data such as federal or state employee dental plan payment rates or FAIR Health data as benchmarks” for comparisons.

The ADA also addressed the need for states to take corrective action in the case of very low provider payment rates, especially when they impact network sufficiency and quality of care, asking CMS Administrator Chiquita Brooks-LaSure to take corrective action in payments to maintain network adequacy and offer incentives to participating providers. The ADA also supported that dentists be allowed to claim a tax credit for the first $10,000 of services and be credited at a rate consistent with the dentists’ full fees for that region or state.

The letters also asked that CMS establish payment parity between Medicaid and CHIP regardless of age, noting that in states that administer Medicaid programs separately from CHIP programs, provider payments are often substantially higher for services rendered to children covered by CHIP compared to those in the Medicaid program. The ADA noted that this practice is discriminatory and perpetuates oral health disparities for lower income families.

The ADA told CMS it supports the agency’s proposals to improve access to dental care, including increasing payment rates to providers, improving outreach and reducing barriers to provider credentialing and contracting, expanding use of telehealth and improving timeliness and accuracy of claim payment and prior authorization, but noted that reducing administrative burdens, especially audits, for dentists will encourage them to enroll and remain providers. “The ADA also supports efforts to ensure that each managed care entity establishes a designated provider advocate position to conduct educational sessions for participating providers and provide ongoing technical and navigational support,” the letters said.

The ADA also supports requiring states to have a more simplified single website with links to specific program and health plan information, explanations of assistance available to users and secret shopper survey results to assist enrollees.

In its comments on the proposed rule on Medicaid and CHIP managed care, the ADA said it supported efforts to increase accountability for dollars directed through state directed payments but noted that there should be exceptions for states that may make SDPs to safety net providers like federally qualified health centers and dental schools, which provide care to disproportionately high numbers of Medicaid beneficiaries. The letter also noted ADA support of the president’s fiscal year 2024 budget that proposes requiring Medicaid managed care plans to meet an 85% minimum medical loss ratio and requiring states to collect remittances if plans fail to meet the minimum MLR but asked for more transparency with the process. The ADA also noted its support for mandatory Medicaid and CHIP Core Set Reporting.

These comments were also sent to CMS by the Organized Dentistry Coalition, a group that includes the ADA, Academy of General Dentistry, American Academy of Oral & Maxillofacial Pathology, American Academy of Oral & Maxillofacial Radiology, American Academy of Pediatric Dentistry, American Academy of Periodontology, American Association of Oral and Maxillofacial Surgeons, American Society of Dentist Anesthesiologists, American Student Dental Association, Association of Dental Support Organizations and National Dental Association.

Follow all of the ADA’s advocacy efforts at

Recommended Content


© 2023 American Dental Association