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ADA asks CMS to postpone Medicare Part D enforcement date

September 27, 2016

By Jennifer Garvin

Washington — The Association filed comments Sept. 23 to the Centers for Medicare & Medicaid Services, urging regulators to postpone the enforcement date of the Medicare Part D prescriber enrollment rule.

Beginning Feb. 1, dentists who write prescriptions for Part D drugs must be enrolled in "an approved status or have a valid opt-out affidavit on file with Medicare in order for their prescriptions to be covered under Medicare Part D," according to CMS.

The ADA is "on record as opposing the application of such requirements to dentists, in part because, since Medicare covers very few dental items and services, many (perhaps most) dentists have little incentive to enroll in Medicare other than in connection with CMS program integrity initiatives in the proposed rule," wrote ADA President Carol Gomez Summerhays and Executive Director Kathleen T. O'Loughlin in a letter to Andy Slavitt, CMS acting administrator.

While applauding CMS' goal to prevent fraud, waste and abuse, the ADA told CMS that "proceeding with the current date would cause disruption to the effective treatment of our patients who are Medicare beneficiaries."

The ADA also said since CMS "already has access to the information needed to maintain program integrity through the dentists' National Practitioner Identification numbers and adverse event reporting maintained through the National Practitioner Data Bank," it shouldn't require dentists to go through the Part D enrollment process.

"Alternatively, if dentists are required to enroll, CMS must correct the categories to allow that to happen. Dentists cannot be held to compliance if they cannot enroll," concluded Drs. Summerhays and O'Loughlin.

The ADA continues to support H.R. 4062, bipartisan legislation introduced in 2015 that calls for removing the mandate that Part D prescribing health care providers be enrolled in Medicare in order for pharmacists to be reimbursed. Visit for more information.