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ADA urges Congress to modernize MACRA to better integrate oral health 

Outlines priorities on interoperability, Medicare Advantage, quality measures 

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The ADA is urging congressional health care leaders to prioritize dental interoperability, administrative simplification and evidence-based quality measurement as part of ongoing efforts to modernize the Medicare Access and CHIP Reauthorization Act, or MACRA. 

In a Jan. 16 letter, the ADA outlined key legislative reforms it says are necessary to ensure Center for Medicare and Medicaid Innovation models can improve oral health control costs and successfully scale. 

A central theme of the ADA’s recommendations is the lack of interoperability between medical and dental electronic health records. The Association said this gap creates administrative burdens and added costs for dental practices that serve Medicare Advantage beneficiaries, while also limiting the development of integrated medical-dental care models. 

Currently, many dental electronic health record systems are exempt from the Office of the National Coordinator for Health Information Technology certification requirements, and there are few incentives for dental vendors to invest in interoperability. The ADA warned that, without federal action, dentistry will remain excluded from interoperability advancements driven by MACRA. The Association called for targeted technical assistance and financial incentives to support dental data exchange using established standards such as HL7 Clinical Document Architecture and Fast Healthcare Interoperability Resources. 

“Without this support, dental [electronic health record] vendors and participating entities have little incentive to invest in interoperability capabilities necessary to support innovative, integrated care models,” the letter said.  

The ADA also highlighted inefficiencies in Medicare Advantage dental administration. Many plans rely on manual processes such as web portals, phone calls or faxes for eligibility verification, benefit confirmation and referrals. These challenges are compounded by variation in supplemental dental benefits, even within the same geographic area, the letter noted. 

Citing the 2024 CAQH Index, the ADA said dental practices could save up to $580 million annually if standardized electronic eligibility and benefit verification were implemented by Medicare Advantage plans. To address this, the Association urged Congress to require Medicare Advantage plans to automate dental administrative transactions, similarly to what has been implemented for medical and pharmacy services.  

The letter also addressed potential reforms to the merit-based incentive payment system. While most dentists do not qualify for this system, those who do typically treat dually eligible Medicare and Medicaid beneficiaries. The ADA said existing oral health measures in this system are insufficiently refined and not well aligned with evidence-based dental practice. 

If the merit-based incentive payment system is reformed or replaced, the ADA recommended a clinician-led quality program that relies on clinically relevant, evidence-based measures.  

“For oral health care, the ADA requests that any quality measures used in a reformed program be those developed and tested by the Dental Quality Alliance,” the ADA said. “[It] is the only comprehensive, multi-stakeholder organization dedicated to developing dental quality measures using a consensus-based methodology.” 

The ADA concluded by offering to serve as a resource to lawmakers as bipartisan MACRA modernization efforts continue, emphasizing the importance of integrating oral health into broader health care policy to improve outcomes and contain costs. 


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