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ADA: Exempt dentists from proposed Medicare Part A, B rule

April 26, 2016

By Jennifer Garvin

Baltimore — The Association is urging the Centers for Medicare & Medicaid Services to exempt dentists from the proposed rule that would require health care providers who order, certify, refer or prescribe any Part A or Part B service to be enrolled in Medicare or opt out.

The Medicare, Medicaid and Children's Health Insurance Programs; Program Integrity Enhancements to the Provider Enrollment Process rule was designed to protect CMS from fraud and abuse. However, because Medicare covers very few dental items and services, the Association is concerned that the proposed rule, "will impose an unreasonable burden with negligible corresponding benefit to CMS, and asks CMS to exempt dentists from the scope of the proposed rule," wrote ADA President Carol Gomez Summerhays and Executive Kathleen T. O'Loughlin in April 25 comments to CMS.

"ADA applauds CMS's goal to prevent fraud, waste and abuse," they continued. "As taxpayers, dentists are also concerned about dishonest individuals and entities who attempt to circumvent Medicare requirements through name and identity changes as well as through elaborate inter-provider relationships."

Historically, dentists have faced unique burdens when attempting to enroll in Medicare.

These enrollment difficulties — which include confusing provider enrollment forms — "could compromise patient safety and quality of care if Medicare beneficiaries are unable to obtain needed items and services due to a dentist's unenrolled status," wrote Drs. Summerhays and O'Loughlin. "Additionally, financial hardships can result if beneficiaries, providers and suppliers are unable to obtain reimbursement where their claims are rejected because the ordering, referring or prescribing dentist was not properly enrolled or formally opted-out."

The ADA is also concerned that requiring dentists to obtain national provider identifiers will put them at increased risk of fraud.

"The ADA supports CMS's goal of eliminating such abusive practices, and urges CMS to implement procedures to protect practitioners from any unreasonable compliance burden that may also result in NPI misuse by criminals," wrote Drs. Summerhays and O'Loughlin.

The proposed rule also requires providers and suppliers to disclose certain direct and indirect affiliations, which the Association believes will "burden honest providers" with paperwork. There is also concern that a recordkeeping requirement will make it difficult for some dentists to comply simply because they do not have control over the relevant documents.

"ADA urges CMS to place the burden for any recordkeeping compliance solely on the individual or entity who controls such records," wrote Drs. Summerhays and O'Loughlin.

Finally, the ADA expressed concern that the "true cost" of the rule cannot be justified. CMS has estimated that doctors will average 10 hours obtaining and furnishing the information necessary to enroll.

"Today's dentists, who are increasingly mobile and who work in increasingly complex practice environments, will likely need more than ten hours to research and gather the necessary information," they wrote.

For ADA resources on Medicare, visit the Center for Professional Success at and search for Medicare. There is also an FAQ and video.