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ADA, industry ask HHS to re-examine Medicare Part C, Medicare Advantage requirement

April 11, 2017

By Jennifer Garvin

Washington — The ADA, along with the National Association of Dental Plans and Delta Dental Plans Association, is asking the U.S. Department of Health and Human Services to remove the enrollment requirement for dentists and other health care professionals who participate in Medicare Part C or Medicare Advantage plans.

In a joint April 11 letter to Tom Price, M.D., HHS secretary, the three organizations urged him to re-examine the final rule requiring participating dentists to enroll in Medicare Part C or Medicare Advantage plans using the Centers for Medicaid and Medicare Form 855i Medicare Enrollment Application for Physicians and Non-Physician Practitioners because they believe the final rule "places an unnecessary burden on dentists" who do not regularly submit claims to Medicare. The groups also said they believe that enforcement of the rule, set for Jan. 1, 2019, could lead to large numbers of dentists choosing not to participate in Medicare Advantage plans.

"One of the stated purposes of this requirement is to 'ensure that Medicare enrollees receive items or services from providers and suppliers that are fully compliant with the requirements for Medicare enrollment,' " wrote Dr. Gary L. Roberts, president, and Dr. Kathleen T. O'Loughlin, executive director, ADA; Theresa McConeghey, chair, and Evelyn Ireland, executive director, National Association of Dental Plans; and Steven R. Olson, president and chief executive officer, Delta Dental Plans Association, in the letter.
The groups applauded HHS and the U.S. Department of Justice's commitment to preventing fraud, waste and abuse, but said they believe providers can still be compliant without fully enrolling in Medicare.

"We are equally committed to ensuring that our members who participate in Medicare Advantage plans comply with all Medicare requirements," they wrote. "However, the enrollment process used by the Medicare Advantage system already protects Medicare beneficiaries.

The three groups also pointed out that Medicare Advantage plans already include language stating that a dentist participating in Medicare Advantage may not do the following:

  • Discriminate against a Medicare enrollee by refusing services because of Medicare enrollment or status.
  • Discriminate against a Medicare enrollee based on his/her health condition.
  • Keep a Medicare enrollee's records for a period of 10 years.
"The industry believes that serious, negative consequences will result from full implementation of the final regulation, including large numbers of dentists choosing not to participate in Medicare Advantage plans and less access to care for Medicare beneficiaries," the letter concluded.

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