Organized Dentistry Coalition urges CMS to not prohibit adult dental coverage

The Organized Dentistry Coalition, led by the ADA, is urging the Centers for Medicare & Medicaid Services to not prohibit adult dental coverage as an essential health benefit in the proposed 2027 Notice of Benefit and Payment Parameters under the Affordable Care Act.

The proposal ODC commented on would effectively undo a significant regulatory change finalized in the 2025 Payment Notice. In that rule, CMS removed a longstanding prohibition that prevented states from including routine adult dental services in their essential health benefit-benchmark plans. That action followed extensive stakeholder input, including comments from the ADA, and allowed states to add routine adult dental benefits as an essential health benefit beginning with plan year 2027.

In a comment letter submitted to CMS, the coalition raised concerns about several provisions affecting oral health coverage, access to care and plan accountability. Chief among them is a proposal to reinstate a prohibition on including non-pediatric dental services as an essential health benefit. The coalition said both pediatric and adult dental services should be recognized as an essential health benefit and available through Marketplace plans and stand-alone dental plans.

“The ODC strongly opposes reinstating the prohibition on non-pediatric dental services as an essential health benefit,” the letter said.

The coalition said the initial exclusion of adult dental benefits reflected commercial market conditions rather than a permanent decision, and that insurance markets have since matured. It pointed to the growing number of states offering adult dental benefits in Medicaid programs and the increasing presence of Marketplace and Medicare Advantage plans that already integrate adult dental coverage in medical plans, stating that these trends demonstrate the feasibility of broader inclusion.

The letter also challenges CMS’ rationale that reinstating the prohibition aligns with legislative intent, stating that Congress provided authority to update essential health benefit standards over time to reflect evolving medical evidence, market practices and consumer needs. The coalition added that continuing to exclude adult dental services would increase fragmentation in coverage and go against evolving markets and adult dental coverage in states.

In addition, the Organized Dentistry Coalition opposed a proposal to reduce the required percentage of essential community providers in Qualified Health Plans and stand-alone dental plans from 35% to 20%. Essential community providers serve low-income and underserved populations, and the coalition expressed concern that lowering the threshold could further restrict access, particularly as many safety-net providers already face capacity constraints.

“The fundamental purpose of [essential community providers] standards is access for patients,” the coalition wrote.

The Organized Dentistry Coalition also objected to potential changes to medical loss ratio requirements that could allow greater state flexibility, warning that weakening standards could limit incentives for plans to increase access to care and reduce protections for beneficiaries. Instead, it called for extending similar reporting requirements to stand-alone dental plans, including standardized dental loss ratio reporting and consumer rebates when plans fail to meet benchmarks.

The coalition said it looks forward to continued engagement with CMS as the rulemaking process moves forward. The other signatories included the American Academy of Oral & Maxillofacial Pathology; American Academy of Orofacial Pain; American Academy of Pediatric Dentistry; American Academy of Periodontology; American Association for Dental, Oral, and Craniofacial Research; American Association of Endodontists; American Association of Oral and Maxillofacial Surgeons; American Association of Orthodontists; American Association of Public Health Dentistry; American Society of Dentist Anesthesiologists; American Student Dental Association; National Dental Association; and National Network for Oral Health Access.