Maintain transparency, access in Medicare Advantage dental benefits, ADA urges CMS 

The ADA is urging the Centers for Medicare & Medicaid Services to maintain strong oversight of Medicare Advantage supplemental dental benefits, warning that proposed changes for contract year 2027 could weaken transparency, and accountability from insurers as well as beneficiaries’ access to care. 

In comments submitted Jan. 26 on CMS’ proposed rule on policy and technical changes to the Medicare Advantage program, the ADA expressed concern about proposals that would loosen certain reporting requirements and more readily grant network adequacy exceptions. The Association emphasized that supplemental dental benefits play a significant role in beneficiary enrollment decisions and must be subject to meaningful oversight. 

“The ADA supports policies that advance access to high-quality, affordable dental care and promote transparency in healthcare delivery. This proposed rule addresses critical areas impacting Medicare Advantage beneficiaries and their oral health,” the comments said.  

While the ADA has expressed support for efforts to reduce unnecessary administrative burden, it cautioned against changes that could compromise program integrity or allow fraud within the system. The ADA said weak reporting requirements, particularly those tied to network adequacy and medical loss ratio reporting for supplemental dental benefits, could prevent beneficiaries from receiving the coverage they were promised when selecting a plan. 

The Association noted that more than half of Medicare Advantage enrollees choose their plan based on advertised dental benefits. Without clear reporting and accountability, the comments said, plans may lack sufficient incentives to ensure that adequate provider networks are in place and that premium dollars are directed toward patient care. 

The ADA also raised concerns about the prevalence of “ghost networks” within Medicare Advantage, in which providers listed as in-network are not realistically available to see patients. Research cited by the Association suggests that a substantial share of advertised in-network providers may not be accepting new patients.   

The ADA opposed any reduction in reporting requirements for Medicare Advantage plan sponsors or broader network adequacy exceptions for supplemental dental benefits. The Association said current network adequacy standards already lack clear minimum thresholds tied to meaningful access, such as appointment availability, geographic distribution and inclusion of dental specialists.  

“Allowing broader exceptions would further weaken networks at the very time seniors need strong guarantees and reliability with their supplemental dental coverage,” the ADA said.  

The ADA also opposed CMS’ proposal to rescind requirements for plans to send mid-year notifications informing beneficiaries about unused supplemental benefits. Many Medicare Advantage enrollees are unaware of what benefits remain available during the plan year, the Association noted, leading to forgone care due to lack of information rather than lack of coverage. Standardized reminders would help beneficiaries better understand and use their dental benefits. 

In addition, the ADA urged CMS to address administrative barriers that interfere with patient care. The Association called on CMS to prohibit Medicare Advantage plans from requiring dentists to sign Waivers of Liability in order to assist patients with appeals of denied dental claims, stating that such requirements discourage provider involvement and disrupt the dentist-patient relationship. 

“The ADA appreciates the opportunity to provide feedback and commends CMS for its commitment to improving Medicare Advantage for both patients and providers,” the ADA said.