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Dental groups to CMS: Boost children’s dental health efforts

December 18, 2018

By Jennifer Garvin

Baltimore — In response to the Centers for Medicare and Medicaid Services’ guidance on Section 1332 waivers, the ADA, American Academy of Pediatric Dentistry and Children’s Dental Health Project are urging the agency to improve efforts to protect children’s dental health.

In November, CMS announced four 1332 waiver concepts to “spur innovative ideas that can be utilized by individual states to improve their health care markets,” according to an agency fact sheet.

In a Dec. 12 letter to CMS Administrator Seema Verma, the three organizations  expressed support for the concept of providing states with more flexibility but shared their collective concern that the guidance may weaken the Affordable Care Act’s Essential Health Benefits — also known as EHBs. The stakeholders also said they are particularly worried that the guidance will weaken the ACA’s comprehensive oral health benefit for children.

“Under the ACA guardrails in Section 1332, a state’s plan waiver must provide comprehensive health coverage to at least as many residents as would have coverage without the waiver,” wrote ADA President Jeffrey M. Cole, AAPD President Joseph B. Castellano and CDHP Executive Director Meg Booth. “The new guidance, however, does not guarantee that the same number of residents would maintain access. Additionally, the new guidance does not protect the affordability of care provided under the EHB and no longer guarantees coverage to vulnerable populations like low-income and special needs children.”

The three organizations also noted that since the new guidance doesn’t prohibit a state from submitting both a Section 1115 and a Section 1332 waiver, children’s dental health coverage under Medicaid and the Children’s Health Insurance Program could also be threatened because the guardrails in those programs could be weakened under the 1115 waiver.

“In addition, we are concerned about CMS’ recent announcement on waiver concepts that would allow the use of federal and state subsidies for the purchase of coverage that does not meet the EHB requirements,” they wrote. “For example, allowing the use of these subsidies for short term limited duration plans could limit children’s access to dental care because these plans typically do not include dental benefits.” 

This could lead to “a significant reduction in access to dental coverage while also resulting in higher out-of-pocket expenses for those who need care.”

Citing 2018 ADA Health Policy Institute research, the organizations pointed out that thanks to benefits offered by the ACA, Medicaid and CHIP, the dental uninsured rate among children is now at an “all-time low” with 90 percent of U.S. children now covered with some form of dental coverage. They also shared that the gap in dental care use between low-income and high-income children has narrowed, which is critical because “good oral health is an essential part of children’s overall health and dental disease is linked to other conditions.”

The letter concluded with the ADA, AAPD and CDHP reminding CMS that the inclusion of pediatric dental coverage as an EHB was a “victory for children.”

“Dental disease is largely preventable, and consistent access to early interventions and treatment can help children achieve optimum health while minimizing cost throughout the lifespan,” the three organizations wrote.