The ADA is urging lawmakers to adapt proposed health care price transparency requirements to account for the unique structure of dental benefits, emphasizing that patient-specific benefit information provides the clearest picture of patients' out-of-pocket costs. The ADA offered multiple reforms to the legislation to build upon the bill’s transparency objectives by providing additional patient-specific benefit and payment information required to offer accurate and meaningful price transparency patients deserve.  

In a July 1 comment letter to the Senate Health, Education, Labor and Pensions Committee, the ADA expressed support for the bipartisan Patients Deserve Price Tags Act while recommending several changes to better reflect the dental benefit system.  

“The ADA supports meaningful transparency that helps patients understand their expected costs, allows employers and plan sponsors to evaluate the value of coverage, and improves accountability for health plans and third-party administrators,” reads the letter signed by ADA President Richard Rosato, D.M.D. and Executive Director Nader Nadershahi, D.D.S.. “For dental care, transparency is most effective when it is payer-facing, patient-specific, available in real time, and tied to the Code on Dental Procedures and Nomenclature.” 

According to the ADA, dental plans rather than dental practices control many of the factors that determine a patient's financial responsibility, including benefit design, deductibles, annual maximums, frequency limitations and adjudication rules. As a result, the Association said dental offices should provide treatment cost estimates, while dental plans should remain responsible for the accuracy of coverage estimates and payment determinations. 

Beyond price transparency, the ADA also called for greater visibility into insurer claim edits such as downcoding. According to the letter, requiring group health plans to receive unmodified copies of dental claims and payment files would help employers and plan sponsors identify when claims have been altered, downgraded or otherwise repriced after submission. 

The letter also recommends that routine dental imaging be excluded from the bill's imaging price transparency provisions.   According to the letter, publicly posting fee schedules alone would not provide patients with an accurate picture of their likely out-of-pocket costs because dental benefits are heavily influenced by plan provisions such as annual maximums, waiting periods, co-insurance requirements and frequency limits. 

The ADA further cautioned that negotiated-rate disclosures could create unintended consequences for dental practices while doing little to improve patient understanding if they are presented without individualized benefit information. “A transparency framework that combines reimbursement data with real-time benefit determinations would provide patients, providers, employers, and plan sponsors with a more complete and actionable understanding of dental care costs,” Drs. Rosato and Nadershahi wrote. 

The letter recommended developing dental-specific standards for explanations of benefits. According to the ADA, current dental explanations of benefits often rely on proprietary payer codes that make payment decisions difficult for both providers and patients to interpret. The Association urged the Department of Health and Human Services to work with the ADA and standards organizations to establish dental-specific explanation of benefits content and format requirements built around CDT Codes and existing dental transaction standards. 

The ADA is urging lawmakers to improve cost transparency for patients while ensuring new requirements reflect how dental care and benefits actually work. 

“The ADA welcomes the opportunity to work with the Committee on ways to enhance the strongest parts of the Patients Deserve Price Tags Act while avoiding unintended burdens on dental practices and their patients,” the letter concluded. 

For the latest advocacy efforts on insurance reform visit ADA.org/advocacy.