ADA comments on proposed Notice of Benefit and Payment Parameters for 2026

New Affordable Care Act Regulations include no significant changes to dental insurance market

The ADA is asking the Centers for Medicare & Medicaid Services to allow higher advance premium tax credits for silver-level plans to be applied toward adult and pediatric dental care when included in silver-level qualified health plans as part of the Affordable Care Act. 

The request was part of comments the ADA submitted on the proposed Notice of Benefit and Payment Parameters for 2026. While there are no significant changes to the dental market in the proposed regulations, the ADA took this as an opportunity to reaffirm its policies and positions that may be relevant to the rule.  

These annual proposed regulations of the Affordable Care Act would apply to commercial insurance offered in the individual, small-group or large-group marketplace exchanges beginning in 2026.  

The silver level qualified health plans are unique on the exchange because reductions of cost-sharing are considered for their actuarial value with consumers at or below 250% of the federal poverty level. The Association also advocated that CMS should permit any leftover advance premium tax credits for silver-level plans to be directed adult dental care toward stand-alone dental plan premiums.  

“Doing so would allow low-income consumers to use [advance premium tax credits] for necessary dental care, which aligns with CMS’ acknowledgment that oral health significantly impacts overall health and quality of life,” according to the ADA’s comments, which were addressed to Chiquita Brooks-LaSure, administrator of CMS’ Department of Health and Human Services.  

The ADA also commented on essential community providers, supporting CMS’ efforts to review qualified health plans offered on federally funded marketplaces to ensure these plans include a sufficient number of essential community providers. The Association requested that the agency extend the review process to stand-alone dental plans, which are also subject to the essential community providers requirement under the Affordable Care Act.  

In the letter, the Association expressed support for CMS’ proposed limitations and made several suggestions regarding the proposed revisions to the medical loss ratio.  

Because the proposed regulations to medical loss ratio primarily relate to risk adjustment as part of the medical loss ratio calculation, the ADA noted, there is little applicability for dental services in the proposal. However, the organization urged CMS to revisit the definition of “health plan” in the statute regarding medical loss ratio in the Affordable Care Act to include stand-alone dental plans.  

“This interpretation would help ensure that consumers’ premium dollars are appropriately directed toward care as was the intent of the Affordable Care Act,” reads the letter.