ADA responds to CMS request regarding re-inclusion of dental services as a specific supplemental benefit

Association encourages CMS to go further in collecting and publishing state-by-state assessment of medical loss ratio data

The ADA supports the Centers for Medicare & Medicaid Services’ re-inclusion of dental services as a specific supplemental benefit under Medicare Advantage Organizations reporting requirements, according to a May 10 letter from ADA leadership to CMS.

The letter, signed by ADA President George R. Shepley, D.D.S., and ADA Executive Director Raymond A. Cohlmia, D.D.S., is a response to a notice of information collection request from CMS.

“Half of Medicare beneficiaries are now enrolled in Medicare Advantage, and it continues to grow in the number of enrollees each year,” wrote Drs. Shepley and Cohlmia. “However, despite this growth, we still do not know a lot about the supplemental benefits offered to these beneficiaries, especially the dental benefits.”

The ADA also encouraged CMS to go further in collecting and publishing in a timely manner a state-by-state assessment of medical loss ratio data with the percentage of allocated Medicare Advantage funding that is being spent on dental services and asks that CMS monitor the specific dental loss ratio.

“Because Medicare Advantage is a critical access point for dental care to millions of enrollees, tracking the correct data is just as important to ensure Medicare Advantage enrollees are getting the dental care they need going forward,” wrote Drs. Shepley and Cohlmia.

The letter also emphasized the following:

• CMS should analyze data on supplemental benefits in the Medicare Advantage program, including who is enrolled by ages, race and ethnicity, education and income, what is covered, and what benefits are being utilized.
• CMS should collect and analyze data on supplemental benefits for lower-income enrollees.
• CMS should standardize the summaries of benefits offered by plans and also seek reporting from Medicare Advantage Organizations regarding what is covered versus noncovered, which should at least be at the level of the CDT category and not just “includes dental coverage” or arbitrary classifications such as “basic,” “routine” or “major.”

In addition, the ADA recommended that CMS require Medicare Advantage plan administrators to report the following metrics pertaining to beneficiary enrollment and utilization of dental services and other aspects of quality of care supported by Medicare Advantage plans:

• Total number of beneficiaries (age, race and ethnicity, income, education).
• Number of beneficiaries with a dental claim in a plan year (age, race and ethnicity, income, education) as a measure of access.
• Cost sharing (average benefit paid per user [among enrollees who had a dental visit], average benefit paid per beneficiary [among all enrollees], coinsurance, annual maximums, total average out of pocket spending).
• Applicable measures for the older adult population from the Dental Quality Alliance.

Follow ADA advocacy efforts at ADA.org/advocacy.