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ADA, AAPD comment on CMS proposed rule

By Jennifer Garvin

Baltimore — The American Dental Association and American Academy of Pediatric Dentistry filed comments Feb. 19 on the Centers for Medicare and Medicaid Services' proposed 2020 notice of benefit and payment parameters for the Affordable Care Act.

In a joint letter to CMS, ADA President Jeffrey M. Cole and AAPD President Joseph B. Castellano told the agency they are concerned about the options given to states for selecting essential health benefit benchmark plans, particularly an option that allows states to select a set of benefits that would become the state’s essential health benefit-benchmark plan. The two organizations said they believe that will give states the opportunity to “weaken the essential health benefits, including the oral health benefit for children.”

The ADA and AAPD instead support “the offering and availability of comprehensive dental services to children under the essential health benefit as required by the ACA.”

The 2020 proposed rule also includes moving the deadline to May 6 for states to submit the documents for their essential health benefit-benchmark plan selection for the 2021 plan year.

“We believe that this does not give states enough time to fully evaluate their choice of an essential health benefit-benchmark plan and its impact on vulnerable populations, especially low-income children,” Drs. Cole and Castellano wrote. “We urge CMS to reconsider this deadline and instead use a July deadline, as was the case for the 2020 plan year.” 

Navigator programs were established under the ACA to help consumers understand available coverage options. The ADA and AAPD said they recognize the need to make these programs flexible so navigators can best serve their communities, but urged CMS to require navigators to provide certain services and have the appropriate training.

“Requiring navigators to provide post-enrollment counseling will be especially helpful to consumers with limited English proficiency, low health literacy, physical disabilities, or limited access to computers and the Internet,” Drs. Cole and Castellano wrote. “To provide this assistance, navigators must first receive training in all areas of the exchanges. The specific training navigators will need to educate and inform consumers about dental plans may be lost if the training requirements are streamlined into four broad categories.”

The rule also proposes changing the way premium assistance is calculated. Previously, the rate was calculated using employer-sponsored insurance premiums. The proposed rule calls for the rate to be based on the premium adjustment percentage on projected private individual and group market health insurance premiums — excluding Medigap and property and casualty insurance expenditure.

“The ADA and AAPD are concerned that this change would increase premiums for exchange plans and decrease enrollment for consumers who receive the premium tax credit,” wrote Drs. Cole and Castellano, noting the rule predicts that enrollment would fall by 100,000 in 2020.

The proposed change in calculating the premium adjustment would also affect the maximum annual limitation on cost sharing. The new limitations will be $8,200 for individual coverage, a $300 increase from 2019, and $16,400 for family coverage, a $600 increase from 2019.

“The ADA and AAPD believe that these increases in cost sharing will further decrease the affordability of exchange plans,” Drs. Cole and Castellano wrote.

Regarding quality standards, the ADA and AAPD encouraged CMS and plan issuers to seek input from the Dental Quality Alliance — a multi-stakeholder coalition known as the DQA — as the Meaningful Measures Initiative is implemented into quality reporting and quality improvement programs. The DQA has developed a comprehensive set of measures and obtained their endorsement from the National Quality Forum that have been tested for validity, reliability, feasibility and usability, and rely on standard data elements in administrative claims data.

The ADA and AAPD thanked CMS for supporting automatic re-enrollment for standalone dental plans for plan years beginning in 2020 and requested that the agency continue automatic re-enrollment for other plans on the exchanges.

“Automatic re-enrollment is critical for ensuring that beneficiaries continue to be enrolled and do not lose coverage due to forgetfulness, lack of knowledge about the deadlines and requirements, or other factors,” Drs. Cole and Castellano wrote. “It also reduces the administrative burden on plans.”

The organizations urged CMS not to defer to states for network adequacy reviews using the “reasonable access” standard and not to use the same standard for essential community providers as the agency did in 2019. They concluded the letter by asking CMS not to eliminate the actuarial value standards for standalone dental plans.