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Letters to the Editor

PECOS

I am glad to see that the ADA is interested in dental specialists, the group of the ADA that may be affected most by PECOS and Centers for Medicare & Medicaid Services changes. During my past 22 years as a paying member of the ADA, it has done little to address the concerns of ADA-recognized specialties.

Although I am required to be a member as a specialist through the tripartite requirements, the ADA does little to intervene in the politics or the maintenance of the ADA-recognized specialties. A classic example of the ADA's complacency on many issues that affect specialists can be cited in the fact that the July 12 ADA News that cites a requirement that has been implemented since July 6, 2010, and has been tossed around HHS and Congress for more than a year ("ADA: PECOS Enrollment Rule 'Unnecessarily Burdensome'"). Now, the ADA sees that this information is suitable for printing?

Just like everything else that affects specialists, the ADA—along with our PAC fund—feels that maybe the specialty organizations should handle this and other issues. So why should I as a specialist be required to be a member of the ADA when we are always placed on the back burner when it comes to everything that only concerns specialists?

When I as an oral and maxillofacial surgeon signed up with PECOS, I had to be categorized as an allopathic/osteopathic physician in order to be paid for doing complex oral and maxillofacial procedures. Where was the ADA to defend dentists and our specialties when these categories were implemented?

Where is the ADA ensuring proper residency training guidelines keeping the specialist programs teaching the proper scope of practice, policing of false advertising of newly declared specialties, calibrating the quality of training at specialty programs and monitoring the scams of past residencies, i.e. orthodontics? Where is the ADA and its involvement on legislative state issues? Their poor precedents eventually affect us all.

My last point is that the ADA is too late with this article; over the past several weeks I'm sure that thousands of patients have been referred to specialists and they will not be reimbursed by CMS because they were not referred by a properly-registered provider. Has the ADA ever pondered where they would be without dental specialists or their payment of dues to this organization?

Steven A. Saxe, D.M.D.
Las Vegas

Editor's note: The ADA Council on Dental Benefit Programs and Council on Government Affairs respond: Enforcement of the requirement for Medicare enrollment of ordering/referring providers cited in the article has been delayed due in no small part to the efforts of the ADA in working with CMS and in close collaboration with the American Academy of Oral and Maxillofacial Pathology. The burden and complexity of the enrollment process were driving forces behind these efforts.

Importantly, the ADA regularly coordinates many of its federal legislative and regulatory efforts with the dental specialty groups within the "Organized Dentistry Coalition," including the response to this Medicare PECOS issue.

In addition, the ADA recently worked with the American Association of Oral and Maxillofacial Surgeons to challenge the American Medical Association's Scope of Practice Data Series on Oral and Maxillofacial Surgeons that misrepresented the scope and depth of OMS residency training and the ability of OMS specialists to serve the public.