CMS updates COVID-19 FAQ

Baltimore — The Centers for Medicare & Medicaid Services announced May 5 the agency has created a new Frequently Asked Questions page to aid state Medicaid and Children’s Health Insurance Program agencies in their response to the COVID-19 pandemic.

The new FAQ addresses a number of topics relevant to dentistry, including questions on teledentistry, expanded information on financing flexibilities, and payment rates and methodologies.

Those topics are summarized here:

What flexibilities are available to provide dental care via telehealth for individuals who are quarantined or self-isolated to limit risk of exposure?

Answer: According to CMS, “no federal approval is needed for state Medicaid programs to reimburse providers for teledentistry services” and “states have broad flexibility to cover teledentistry through Medicaid, including the methods of communication (such as telephonic, video technology commonly available on smart phones and other devices) to use.” The agency added that providing services “such as oral screenings, assessments, problem-focused evaluations, or re-evaluations via teledentistry can help to limit in-person visits, determine when dental procedures can be deferred and avoid unnecessary trips to hospital emergency departments.

Q: During the public health emergency period, can states receive federal funding to provide advanced payments to providers as an interim payment and reconcile the advanced payments with actual processed claims at a later point?

A: According to CMS, “states can submit a state plan amendment to add an interim payment methodology that says, under certain specified conditions, states will make periodic interim payments to the providers.” The interim payment methodology “must describe how states will compute interim payment amounts for providers (e.g., based on the provider’s prior claims payment experience), and subsequently reconcile the interim payments with final payments for which providers are eligible based on billed claims.” The agency said CMS will consider state plan authorities “on an expedited basis” and said states should contact their designated reimbursement contact for technical assistance with the state plan amendment submission process.

Q: Is there flexibility to request/implement temporary rate increases or retainer payments in a 1915(i) state plan amendment similar to those found in Appendix K for 1915(c) Home and Community-Based Services waivers?

A: According to CMS, “states may increase Medicaid payment rates to offset losses to providers during the COVID-19 pandemic, if consistent with all applicable requirements, including section 1902(a)(30)(A) of the Act.” The agency said that federal financial participation “is not available under the Medicaid state plan to pay providers directly for the time when care is not provided to beneficiaries” but noted in March of this year, CMS released a template that states may use to request a section 1115 demonstration to combat the COVID-19 public health emergency. To download the template, visit

Q: In what ways might states use the Medicaid disaster relief state plan amendment template to increase payments to providers during COVID-19?

A: According to CMS, states can use the Medicaid disaster relief state plan amendment template to increase payments to providers during the emergency period. State plan amendment approvals and other COVID-19 related waiver documents may be downloaded on the COVID-19 resources page.

Q: During the public health emergency, some providers are experiencing significant cost increases. Without knowing how much costs will increase right now, how should states approach making adjustments to Medicaid payment rates and methodologies to ensure that Medicaid costs are paid during the public health emergency period?

A: According to CMS, states have the flexibility to “make reasonable adjustments to Medicaid payments to better align Medicaid payments with the increased cost of providing services to Medicaid beneficiaries during [COVID-19] under the Medicaid state plan through base and supplemental payments.” The agency noted that these adjustments could include “an increase in resource utilization to account for the need for more personal protective equipment or other increased safety measures” but said the agency would need to consider a state’s justification for these increases in payment rates during the pandemic.

To see a complete list of all of all COVID-19 Frequently Asked Questions for state Medicaid and Children’s Health Insurance Program agencies, visit the CMS website. To directly access the questions covered in this story, dentists should visit pages 30, 40 and 42 of the full FAQ.

For the latest news on the COVID-19 pandemic, visit