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ADA, AGD, AAPD urge CMS not to change process for documenting fee-for-service Medicaid

September 17, 2019

By Jennifer Garvin

Washington — The ADA, Academy of General Dentistry and American Academy of Pediatric Denistry are urging the Centers for Medicare and Medicaid Services to not rescind the requirement for states to submit Medicaid access monitoring review plans because they believe changing the requirements will have a negative impact on access to oral health care.

The three dental organizations are also asking CMS to not change the requirements for how states undergo reducing or restructuring their Medicaid payment rates.

“Over 23 million Medicaid enrollees receive dental services via fee-for-service and an additional 5.3 million Medicaid enrollees receive them via combined fee-for-service/managed care,” wrote ADA President Chad P. Gehani, AGD President Neil Gajjar and AAPD President Kevin Donly in a Sept. 13 letter to CMS. “These include pregnant women, children, the elderly, the disabled and patients with a chronic and/or complex health condition. It is critical that these beneficiaries have access to quality services received in a timely manner. Delays in accessing needed treatments and services can lead to poor outcomes and unnecessary costs to the health care system. Federal oversight is needed to ensure that the Medicaid program is serving our nation’s most vulnerable.”

The organizations said that while they appreciate CMS’ efforts to find a balance between “maintaining access to care and providing states with flexibility,” they are concerned that the proposal to rescind the November 2015 Medicaid access rule could impede access to oral health care. That rule required states to develop and submit an access monitoring review plan — also called an AMRP — which enables CMS to measure access to care and reimbursement rates.

For example, they pointed out that a letter from CMS to Minnesota noted that state’s 2017 AMRP reported only 38.4% of children enrolled in Medicaid fee-for-service had a dental visit in 2014 and its Medicaid dental reimbursement rates were low compared to other benchmarks.

The three dental organizations also recommended CMS use an ADA-developed checklist to review state AMRPs and ensure that the states have plans in place to ensure access to care for fee-for-service beneficiaries.

“It is important that state dental associations and other stakeholders undertake this review,” Drs. Gehani, Gajjar and Donly wrote. “Although we have found the AMRPs to vary in quality, completely rescinding this rule is not in the best interest of Medicaid beneficiaries covered under the fee-for-service programs. In fact, we believe standardization of AMRPs and template-based reporting could reduce the burden for states while at the same time preserving the mechanism to seek accountability for these programs.”

The groups encouraged CMS to adopt an approach to standardize and submit the ADA’s checklist as a foundational tool for such standardization for the dental benefit within Medicaid fee-for-service programs.

Within the proposed rule, CMS also noted that it is developing a methodology for reporting Medicaid access data in lieu of AMRPs.

The ADA, AGD and AAPD urged CMS to first come up with criteria for improving the AMRPs before loosening the monitoring requirements.

“Any methodology used in place of an AMRP must be built on sound data and analyses, must be reported by states to CMS on an annual basis, and must be in place before the AMRP requirement is rescinded,” they wrote.

The ADA, AGD and AAPD also said they would like the opportunity to participate in CMS’ review process for monitoring state Medicaid programs and requested more access to the information necessary to do this, noting that CMS' Transformed Medicaid Statistical Information System, or T-MSIS, is currently not widely available to non-governmental entities.

The three organizations believe it is critical that CMS monitors rate reductions and maintain a process for beneficiaries and providers to provide input on the implications of rate reductions on access to care.  On average, Medicaid fee-for-service reimbursement was 49.4% of fees charged by dentists for children and 37.2% for adults in 2016.

"This shortfall in reimbursement threatens access to care, and that will only grow under the proposed rule’s removal of the requirements for states to follow prior to submitting a state plan amendment that reduces or restructures Medicaid payment rates,” the letter concluded.