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ADA asks CMS to consult Dental Quality Alliance on dental measures

October 08, 2019

By Jennifer Garvin

Washington — The ADA encourages the Centers for Medicare and Medicaid Services to simplify the complex Merit-Based Incentive Payment System program, and would like the agency to remain sensitive to the needs of rural and small dental practices who treat pediatric patients.

That was one of the Association’s recommendations in comments filed Sept. 25 in response to CMS’ proposed changes to transform the Merit-Based Incentive Payment System — a physician payment program based on quality reporting known as MIPS.

In the letter, ADA President Chad P. Gehani and Executive Director Kathleen T. O’Loughlin focused on two dental measures that are included as part of the Dentistry Set in MIPS: measure 378, which is children who have had dental decay or cavities; and measure 379, which is primary caries prevention as offered by primary care medical providers, including dentists.

Measure 378 is not risk-adjusted and there are questions regarding the validity of the data sets, Drs. Gehani and O’Loughlin pointed out. The ADA also expressed concerns that measure 379 does not reflect current clinical guidelines and noted that both measures have not been “widely adopted” despite being in the MIPS program for several years.

The ADA “strongly urged” CMS to consider working with the Dental Quality Alliance — or DQA for short — which was convened by the ADA at the request of CMS. The Dental Quality Alliance currently has 38 members and is the “only comprehensive multi-stakeholder organization in dentistry that develops dental quality measures through a consensus-based process.”

This will ensure that these measures are appropriately specified to properly reflect current evidence-based clinical guidelines, be more meaningful and encourage greater adoption among providers treating pediatric patients eligible for Medicare coverage, Drs. Gehani and O’Loughlin wrote.

The ADA also noted the agency’s efforts to “align and harmonize measures reviewed by a consensus-based entity such as the National Quality Forum Measure Applications Partnership and said, “given that the DQA is itself a consensus based multi-stakeholder body for quality measure development formed at the request of CMS,” the agency should consider the DQA to be the primary consensus-based entity for review of any oral health measures.

Read the letter in full in the advocacy section on the ADA website.