ADA asks Secretary Price to exempt dentists from Part D requirement
February 28, 2017
— The ADA is asking Health and Human Services Secretary Tom Price to re-examine the Affordable Care Act's requirement that dentists and other providers who write prescriptions to Medicare beneficiaries with Part D coverage must be enrolled in or opted-out of Medicare Part B prior to Jan. 1, 2019, in order for the prescription to be covered by the beneficiaries' Part D plans.
In a Feb. 27 letter
to Secretary Price, ADA President Gary Roberts and Executive Director Kathleen T. O'Loughlin praised HHS for its efforts in preventing "fraud, waste and abuse in Medicare," but urged the secretary to exclude dentists from the Part D provision, noting that the requirement "places an unnecessary burden on dentists and their Medicare eligible patients."
"As taxpayers, dentists are also concerned about criminals masquerading as health care professionals or suppliers, submitting false or fraudulent billings to Medicare," wrote Drs. Roberts and O'Loughlin. "However, the ADA is not aware of, nor has the Centers for Medicare & Medicaid Services demonstrated, high-billing levels associated with prescriptions written by dentists for Medicare eligible patients. Therefore, there appears to be little need for this requirement as it applies to dentists yet the administrative burden would be significant."
Drs. Roberts and O'Loughlin also pointed out that 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, any enforcement action affecting health care professionals that allegedly violate ethical prescribing practice "should remain within the state boards of pharmacy and the respective professional state licensing boards."
CMS published a final rule in May 2014 and an interim final rule in May 2015 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. Previously CMS said that enforcement of this requirement would begin on Feb. 1, but last October
said it also "recognizes the need to minimize the impact on the beneficiary population and ensure beneficiaries have access to the care they need."
For information on all of the ADA's advocacy efforts, visit ADA.org/advocacy