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ADA, VDA advocate RAC audit, opt out policy with CMS administrator

January 13, 2015

By Craig Palmer

DC meeting: CMS Administrator Marilyn Tavenner (center) hosts policy meeting with Dr. Terry Dickinson, VDA executive director, and Dr. Kathleen O’Loughlin, ADA executive director.
— The ADA and Virginia Dental Association executive directors thanked Centers for Medicare & Medicaid Services Administrator Marilyn Tavenner for hosting a Jan. 8 discussion of Medicaid and Medicare policy issues important to the profession.

"Thank you again for convening your staff and taking the time to meet with us in person," Drs. Kathleen T. O'Loughlin, ADA executive director, and Terry Dickinson, VDA executive director, said in a follow-up letter to Ms. Tavenner. "Over the next few weeks, ADA staff will follow up to ensure that meetings have been scheduled with the appropriate CMS staff. We sincerely appreciate your understanding of the importance of oral health and providing dental services to individuals enrolled in government insurance programs."

Continued discussions with CMS staff will focus on "ways that we can collaborate on resources," program integrity and Recovery Audit Contractor audits, and the Action for Dental Health Medicaid initiative "to increase the number of Medicaid beneficiaries receiving dental visits and to increase the number of dentists participating in state Medicaid programs."

"As our previous communications to you and your staff have indicated, our members remain very concerned about the new Medicare enrollment requirements for prescribers of Part D covered drugs," the ADA-VDA letter said.

"We had a positive teleconference [with CMS staff] on Jan. 5, reiterating our concerns and the need for further assistance from CMS to educate both our member dentists and the Medicare contractors that are managing the enrollment process. While we still believe a dentist's National Practitioner Identifier or National Practitioner Data Bank registration provide sufficient information, we understand the process is underway."

The CMS published a final rule in 2014 that requires dentists who prescribe Part D covered drugs to be enrolled in Medicare or opt out for those prescriptions to be covered under Part D. The ADA actively opposes this provision as it applies to dentists and is seeking an exemption for the dental profession. Although the enrollment deadline is June 1, the CMS recently delayed the enforcement date to Dec. 1.

ADA and CMS staff will have "further discussion" on proposed adjustments to the enrollment form to include the ADA-recognized specialties and general dentistry and further education for dentists and Medicare contractors on the enrollment process, the letter said.

The ADA-VDA executives also told the CMS administrator:

  • "One area that we are focusing on as a result of member feedback is the Medicaid credentialing process. The time associated with becoming a credentialed Medicaid provider is often onerous and time consuming. To address this issue, the ADA plans to launch a credentialing service, open to both public and private dental programs, to simplify and expedite the credentialing process that assures the quality of the network."
  • "We appreciate your acknowledgment that the approach CMS has taken on program integrity may not be universally applicable to both medicine and dentistry."
  • "RAC audits are a significant concern for our members, for both enrolled Medicaid providers and those interested in becoming an enrolled provider. We believe education focused on compliance will be highly beneficial but would appreciate some additional guidance from [CMS officials] on the next steps. CMS has a number of resources available online but we believe further dissemination and tailoring would be good for our members."