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ADA weighs in on HHS strategic plan

October 18, 2017

By Jennifer Garvin

Washington — As the U.S. Department of Health and Human Services develops its strategic plan for fiscal years 2018-22, the ADA is offering recommendations on how the agency can best enhance the oral health and well-being of Americans.

Community Dental Health Coordinators. Reducing dental emergency room visits. Medicaid reform. Increased federal support for programs that focus on oral health. These issues were the focus of comments filed Oct. 17 by ADA President Gary L. Roberts and Executive Director Kathleen T. O’Loughlin.

For HHS’ goal to “reform, strengthen and modernize the nation’s health care system” in regards to promoting “the use of high-quality, lower-cost health care providers, such as community health workers, dental therapists and community organizations,” Drs. Roberts and O’Loughlin recommended that HHS include the Community Dental Health Coordinators in that list of providers as opposed to the “one size fits all” approach of dental therapists.

They noted that the CDHC program trains individuals to “directly address the underlying social determinants of health” and cited 2016 ADA’s Health Policy Institute research that underlined the need for more policy interventions targeting patient behavior. 

Drs. Roberts and O’Loughlin told HHS that the ADA is opposed to dental therapists for the following reasons:

  • Dental therapists have not proved sustainable without significant ongoing supplemental government or outside organizational spending.
  • There are no studies comparing any improvements in oral health among targeted populations to the potential outcomes had the same resources been directed to providing these patients with care from dentists.
  • There are no cost savings to private or public sector payers or to patients, noting Medicaid reimbursement rates are the same for a given procedure regardless of who provides the service.
  • The additional training and potential licensing of dental therapists adds additional costs to the health care system.
  • Adding dental therapists to a state’s provider mix does not necessarily result in more services for underserved and rural populations, as many therapists locate in urban areas.
Drs. Roberts and O’Loughlin noted that there are many more dentists coming into the profession but access issues remain due to the distribution of dentists. They urged HHS to provide more incentives such as additional National Health Service Corps loan repayments programs, tax credits for serving in underserved areas and improving the Medicaid program to enhance access.

“The ADA opposes allowing non-dentists (including dental therapists) to perform surgical dental procedures, such as ‘simple” extractions’, restorations and pulpotomies as there can be unanticipated complications in any of these procedures,” they said.

Drs. Roberts and O’Loughlin reminded HHS that many patients who lack access to oral health care also suffer from other health problems such as diabetes, obesity, tobacco use or excessive alcohol consumption that can complicate their dental care.

“As doctors of oral health, dentists are uniquely qualified to identify these comorbidities and properly calibrate treatment plans,” they said. “For all of these reasons, the ADA believes there is no need to promote a new provider who performs some, but not all, of the functions of a licensed dentist. The emphasis should be on directly addressing the many barriers to accessing dental care with a shift away from a model of ‘drilling, filling and extracting’ to one of disease prevention.”

The ADA also requested that HHS include reducing the number of emergency room visits in its goals, reminding the agency that ER visits for non-traumatic dental problems cost more than providing regular care by oral health professionals and do not treat the underlying problem. To back this up, they shared that the U.S. spent nearly $3 billion on ER dental visits from 2008 through 2010, according to a 2014 study in the Journal of the American Dental Association.

Drs. Roberts and O’Loughlin explained that both CDHCs and reduced ER visits for dental pain are part of the ADA’s Action for Dental Health program, a nationwide, community-based movement aimed at ending the dental health crisis facing America today.

The causes of dental disease are varied and complex, but we know that for each of us – and for the nation as a whole – it’s never too late to get on top of our dental health,” Drs. Roberts and O’Loughlin wrote. “ADH aims to prevent dental disease before it starts and reduce the proportion of adults and children with untreated dental disease. Our goal is to help all Americans attain their best oral health.”

They also recommended that HHS continue to ensure access to affordable dental coverage for underserved children and adults as an “extremely important component in reducing disparities in access to health care.”

“The good news is that today more children have dental coverage than ever before in the United States,” Drs. Roberts and O’Loughlin said, noting that HPI research found that between 2000 and 2012, the number of children without dental coverage decreased from 21.7 percent to 13.1 percent. They also cited HPI research that found Medicaid expansion has allowed more than 5 million adults to gain dental coverage and also improved access to dental care for young adults.

They also told HHS that there is “a good deal that should be done at the federal level” to provide states guidance on reducing administrative barriers to providing care to Medicaid beneficiaries, noting Medicaid reform is another prong of Action for Dental Health.

Drs. Roberts and O’Loughlin complimented HHS on its continued efforts to emphasize the importance of oral health during pregnancy and recommended that these efforts be explicitly mentioned in this new strategic plan, such that all pregnant women receive instruction on oral hygiene care for themselves and their children.

Regarding HHS’ goal to “reduce provider shortages in underserved and rural communities,” the ADA reminded the agency that for decades, the Association has supported increased funding for the National Health Service Corps, the oral health division in the Indian Health Service, the oral health division of the Centers for Disease Control and Prevention and Title VII General and Pediatric Residencies and the Dental Health Improvement Act within the Health Resources and Services Administration.