ADA urges HHS to reduce dental regulations that burden providers

The ADA submitted formal recommendations to the Department of Health and Human Services, or HHS, in response to its request for information on reducing regulatory burdens in health care. In a July 14 letter to Secretary Robert F. Kennedy Jr., the ADA outlined nine reforms aimed at streamlining federal rules affecting dental providers and improving access to oral health care. 

ADA President Brett Kessler, D.D.S., and Interim Executive Director Elizabeth Shapiro, D.D.S., J.D., expressed support for the agency’s deregulatory initiative, emphasizing the need to eliminate duplicative processes, promote uniformity and lower compliance costs. One of the ADA’s key recommendations calls on the Centers for Medicare & Medicaid Services to simplify administrative requirements for dental providers who participate in Medicare Advantage plans. 

“We offer the following recommendations, each of which meets one or more of the criteria outlined in [Executive Order] 14219 for identifying and modifying regulations that impose undue burdens, lack clear statutory authority or unnecessarily hinder private sector innovation and efficiency,” Drs. Kessler and Shapiro wrote.  

Dentists often face inconsistent and redundant credentialing processes across Medicare Advantage plans, the letter stated. The ADA urged CMS to encourage centralized or reciprocal credentialing systems and standardize the use of the ADA dental claim form. The Association criticized prior authorization rules in Medicare Advantage dental benefits as “complex” and “unpredictable,” advocating for uniform and transparent standards, as well as an exemption for preventive services. 

The letter also raised concerns about overlapping credentialing for dentists in Medicaid managed care organizations, recommending that low-risk providers be screened by managed care organizations rather than separately by state Medicaid agencies. 

Several proposals addressed administrative compliance challenges for small practices. The ADA recommended modifying Section 1557 coordination and language access mandates by raising the employee threshold for compliance or allowing alternative options for small providers. It also urged HHS to revise good faith estimate requirements under the No Surprises Act to allow use of standard dental treatment plans.  

“Dental offices already practice price transparency and should not be required to implement duplicative federal templates. Streamlining the [good faith estimate] requirement will allow small dental practices to continue serving patients without diverting resources to unnecessary paperwork,” Drs. Kessler and Shapiro wrote.  

Other reform proposals included finalizing Health Insurance Portability and Accountability Act electronic attachment standards; clarifying or exempting dental providers from certain No Surprises Act rules; and updating definitions under information blocking regulations to include dental software vendors. 

“We appreciate HHS’ commitment to meaningful regulatory reform that protects public health while eliminating unnecessary administrative burdens,” the letter concluded. “These recommended changes will not compromise patient care but will enhance provider participation, reduce overhead, and allow dentists to focus on delivering needed services in communities nationwide.”