ADA Meets with CMS Administrator on Medicare Part D Opt-Out, Medicaid
January 13, 2015
ADA President Dr. Kathleen O'Loughlin and Washington Office staff met with CMS Administrator Marilyn Tavenner last week to discuss issues important to the dental community, including the Medicare Part D opt-out provision, Medicaid reform and RAC audits. They were joined by Dr. Terry Dickinson, executive director of the Virginia Dental Association.
The issues discussed included the final rule published early last year that requires dentists who prescribe Part D covered drugs to be enrolled in Medicare or opt out. The ADA is concerned about the rule because it would deny payment for a Medicare beneficiary’s medication if the prescribing provider had not either enrolled or opted out of the program. The ADA has actively opposed this new Medicare provision as it applies to dentists and is currently seeking an exemption for the dental profession. CMS delayed the enforcement date; although the enrollment deadline remains June 1, 2015, the agency will not enforce the rule until Dec. 1.
During the meeting Ms. Tavenner acknowledged that the approach CMS has taken on program integrity may not be universally applicable to both medicine and dentistry; this is what the ADA has said repeatedly in objecting to the opt-out provision as applied to dentists. Ms. Tavenner asked the ADA representatives to stay in touch with her staff as the process moves forward.
Also discussed was the ADA’s Medicaid reform initiative, the objectives of which are to increase both the number of Medicaid beneficiaries receiving dental visits and the number of dentists participating in state Medicaid programs. The ADA would like to continue working with CMS and the state governments to help improve dental Medicaid. ADA staff cited the Association's Action for Dental Health initiative, which has identified 10 states in which the dental associations are addressing barriers to participation.
Finally, the ADA raised the issue of RAC audits, a significant concern for its members, explaining that dentists would like additional guidance on how to avoid triggering the audits, which are intended to recover improper payments. Ms. Tavenner was open to continued discussions on this issue as well, asking that ADA staff follow up with representatives in her office.
It is critical for the ADA and CMS to work together, especially as the Association moves forward with its ADH Medicaid initiative. For its part, CMS is seeing good results with its Oral Health Initiative program and, as Ms. Tavenner said, collaboration with the dental community is a big part of the reason for that success.
Drs. O'Loughlin and Dickinson sent a letter to Ms. Tavenner yesterday, thanking her for taking the time to meet with them.