ADA urges CMS to account for dental data in Medicaid IT standards
Association calls for use of existing dental standards, continued engagement with standards developers
The ADA is urging the Centers for Medicare & Medicaid Services to ensure dental data and technology are incorporated into new standards being developed for state Medicaid systems.
In comments on CMS’ Medicaid Enterprise Systems IT Standards initiative, the ADA supported the agency’s goal of establishing standards to improve interoperability and health information exchange while emphasizing that the framework should account for the distinct ways dental information is captured and administered.
“We support CMS's goal of establishing clear, outcome-driven standards that improve interoperability, reduce data silos, and enable more efficient exchange of health information,” the ADA wrote.
According to the letter, dental information systems contain clinical and administrative data elements that differ from those used in medical systems. The ADA said CMS should build on existing dental standards rather than adapt medical standards in areas where dental-specific standards already exist.
The Association also asked CMS to engage the ADA as the initiative moves forward. The ADA is an American National Standards Institute-accredited standards developer and maintains standards for dental terminology, data content and information exchange, according to the letter. Those include the Code on Dental Procedures and Nomenclature, or CDT Code; SNODENT clinical terminology; and several dental interoperability and administrative data-content standards.
The ANSI/ADA Standard No. 1111, Oral Data Set Interoperability Network, or ODIN, specifies how to extract, process, format and transmit a patient's essential demographic, dental/medical encounter, and clinical data from one dental information system to another dental or medical system. Consideration of the framework defined by ODIN would let a Medicaid patient's dental records follow them across the safety net's scattered providers, giving dentists and physicians a fuller, reconciled picture that supports whole-person care, faster referrals and prior authorizations, fewer duplicate X-rays and stronger privacy protections. The ADA also works with Health Level Seven International on dental content for exchange using Fast Healthcare Interoperability Resources, or FHIR.
As CMS establishes expectations for data exchange, system integration and technical architecture, the ADA recommended that the agency recognize dental-specific data requirements from the beginning, use existing standards rather than create duplicative requirements, and include the ADA and other standards development organizations in technical workgroups, standards mapping, implementation guidance and testing.
“A standards-based Medicaid technology ecosystem can improve interoperability and administrative efficiency, but its success will depend in part on ensuring that the standards accurately represent the different sectors of health care that Medicaid programs administer,” the ADA wrote.
The Association said CMS should also recognize differences between dental and medical technology infrastructure. According to the letter, dental practice management systems have largely developed outside the federal health IT certification program, and many dental practices use systems that are not certified by the Office of the National Coordinator for Health Information Technology. As a result, dental systems may not support FHIR application programming interfaces and other interoperability standards to the same extent as certified medical electronic health records.
The ADA said harmonization efforts should extend beyond FHIR to the standards used to transmit and describe Medicaid dental information, including X12 837D dental claims and encounters and CDT procedure coding. The Association recommended that CMS treat Medicaid dental as a specific harmonization use case and account for differences in the technological readiness of dental providers.
The letter also addressed the exchange of dental information across Medicaid and other health systems. The ADA recommended that CMS make dental services provided through the Early and Periodic Screening, Diagnostic and Treatment benefit a priority use case for cross-agency interoperability. According to the ADA, dental information can be fragmented across Medicaid dental systems, managed care or dental benefit manager encounter streams and public health or school-based programs.
The Association also said dental terminology should be incorporated into connections between Medicaid systems and medical, public health and health information exchange infrastructure so that oral health information can be represented and linked across systems.
On standards governance, the ADA recommended separating the schedule for updating a standard from deadlines requiring states or vendors to comply with each new version. The Association also called for each Medicaid Enterprise Systems standard to have a designated organization responsible for maintaining it and a published schedule for updates.
The ADA cautioned CMS against developing standards around majority-use cases that may not account for dental, pediatric or noncertified technology endpoints. It also identified potential problems including standardizing transactions without the terminology used within them, insufficient investment in standards maintenance and imposing requirements before all participants in an exchange have the technology needed to meet them.
For reporting and analytics, the ADA urged CMS to rely on already existing information systems rather than introduce additional reporting requirements.
“CMS should prioritize analytics that reuse existing transactional and administrative data over those that require states, vendors, or providers to generate parallel reporting,” the Association wrote.
The ADA concluded by offering to continue working with CMS and state Medicaid agencies on dental data and interoperability, including through future technical discussions, workgroups and testing.
