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ADA asks CMS to remove Part D requirement

November 14, 2017

By Jennifer Garvin

Washington — The ADA is asking the Centers for Medicare and Medicaid to re-examine the Medicare Part D enrollment requirement for dentists who do not submit claims for reimbursement to Medicare because it believes CMS currently has access to the information needed to maintain program integrity through the National Practitioner Identification Standard, as verified by a recent report published by the Office of Inspector General for the U.S. Department of Health and Human Services.

CMS published a final rule in May 2014 stating that prescribers must be enrolled in or opted-out of Medicare Part B prior in order for their written prescriptions to be covered under Part D. One of the key reasons CMS has said it included dentists and other health care professionals in the final rule was to maintain program integrity.

The Inspector General's October report found that of the 1.5 billion records that Part D plan sponsors submitted for covered drugs in 2016, only 147 records contained invalid prescriber identifiers, which accounted for 0.005 percent of the 1.4 million unique prescriber identifiers, the ADA noted in a Nov. 13 letter to Eric D. Hargan, acting HHS secretary, and Seema Verma, CMS administrator.
 
"These 147 records accounted for only $19,122 in Part D payments," wrote ADA President Joseph P. Crowley and Executive Director Kathleen T. O'Loughlin. "Moreover, the Inspector General's report indicates CMS has subsequently changed the edit criteria that would virtually eliminate even these payments."

Drs. Crowley and O'Loughlin stressed that requiring enrollment for the purpose of verifying prescriber eligibility "not only increases the burden on dentists who only prescribe medications but also on CMS and Medicare contractors."

They also noted that the implementation of this rule has proved difficult "as evidenced by the delays in enforcement."  

The Association has advocated for the removal of the Part D mandate since it was introduced by CMS in 2014.

On Nov. 1, the Association announced its support for the Protecting Seniors Access to Proper Care Act of 2017, legislation that supports removing the mandate for dentists — and other providers who are low prescribers and do not participate in Medicare — requiring they be enrolled in or opted-out of Medicare Part B in order for their written prescriptions to be covered under Medicare Part D.

In a letter from ADA President Joseph P. Crowley and Executive Director Kathleen T. O'Loughlin to the House Ways and Means Committee, the Association noted that if the mandate is not removed, "many seniors will not have access to the dental care they pay for in their Medicare Advantage plan from the dentists of their choice or the prescription coverage they are promised when they enroll in Part D."

For information on all of the ADA's advocacy efforts, visit ADA.org/advocacy.