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ADA, coalition urge CMS to allow dentists to administer vaccines

Groups also seek to protect adult Medicaid dental benefits

By Jennifer Garvin

Washington — The ADA and other dental organizations are urging the Centers for Medicare and Medicaid Services to expand the scope of practice for dentists, particularly public health dentists, to administer vaccines in order to aid in the prevention and control of COVID-19.

This request was included in two Jan. 4 letters to CMS in response to the agency’s Interim Final Rule, Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency. The organizations also asked CMS to rescind a proposal that allows states to eliminate optional Medicaid benefits coverage as they believe it could negatively impact both beneficiaries and their dental providers as well as potentially overwhelm hospital emergency departments.

In the interim final rule, CMS invited groups to submit ideas on how to expand the nation’s capacity to immunize the public against COVID-19.

The dental groups urged the U.S. Department of Health and Human Services to expand authorization for dentists to order and administer these vaccines under the Public Readiness and Emergency Preparedness Act. They noted that expanding the scope of practice, “particularly during times of health crisis, is not unprecedented,” as several states chose to allow dentists to administer the H1N1 vaccine in 2009 and said, “certainly, the COVID-19 pandemic justifies continuing this precedent.”

The groups also reminded CMS that dentists are essential health care providers who have the knowledge and skills to administer vaccines safely and who are already approved to administer vaccines in Illinois, Minnesota and Oregon.

“A temporary liability shield at the federal level would extend that authority nationwide during this public health emergency,” the dental groups wrote. “Dentists can help increase the nation’s medical surge capacity when medical personnel are overwhelmed as they are trained health care providers who can administer critical vaccines to prevent life or health-threatening conditions — and protect the life and health of patients and staff at the point of care.”

The Families First Coronavirus Response Act, signed into law in March 2020, included an option for states to receive enhanced Federal Medical Assistance Percentage funds. In exchange, the states must agree to comply with maintenance of effort protections to help ensure beneficiaries are able to obtain and remain covered during the pandemic and receive essential care. The law also included a requirement to preserve the enrollee’s existing benefits, both their enrollment in Medicaid overall and the services for which they have been eligible.

The dental groups are worried that a new interpretation of the law’s guidance could allow states to cut dental benefits.

“Past experience shows us that when optional dental benefits are cut during times of fiscal uncertainty in states, the result is an increase in overall associated costs,” they wrote.

The groups noted that cuts to optional dental benefits in Massachusetts in 2002 and 2003 and in California in 2009 resulted in both a decline in provider reimbursements and an increase in costs because oral health needs went untreated and patients then turned to emergency departments for dental problems.

“We urge a return to previous guidance that kept in place states’ benefits packages if accepting an increase in Medicaid funding as this will cost states less over time than making cuts to essential care during a public health emergency,” they said.

The ADA also signed on to a Jan. 4 letter with the Partnership for Medicaid on this issue. In that letter, the groups urged HHS and CMS to rescind parts of the interim final rule it believes will be detrimental to Medicaid beneficiaries, including the option for states to make cuts to adult dental care. In that letter, the coalition — which includes the ADA — asked CMS to do more to enhance states’ capacity to provide meaningful access to care through Medicaid, both during and beyond the COVID-19 public health emergency.

For more information about the Partnership for Medicaid, visit the website.

For more information about the ADA’s advocacy efforts during COVID-19, visit ADA.org/COVID19Advocacy.