ADA, DQA comment on CMS proposed rule on Medicaid, CHIP Core Set

The ADA and Dental Quality Alliance are applauding the Centers for Medicare & Medicaid Services for including three DQA measures into the Core Set of Children's Health Care Quality Measures for Medicaid and the Children's Health Insurance Program.

The measures included are the Oral Evaluation, Dental Services measure; Prevention: Topical Fluoride for Children measure; and Sealant Receipt on Permanent 1st Molars measure.

The ADA and DQA submitted joint comments on Sept. 26 in response to the agency's proposed rule on Mandatory Medicaid and CHIP Core Set Reporting that said requiring reporting of these measures in the core set will lead to "robust age-appropriate" preventive pediatric dental care services.

The ADA and DQA also said they generally support CMS's efforts in exploring the use of the Transformed Medicaid Statistical Information System Analytic Files data set to report on the core set measures but noted that because state data submissions vary, urged CMS to use the DQA dashboard that includes a data quality assessment.

"Given the variability and significant gaps in data quality for some states, we recommend that CMS' technical assistance to states be focused first on improving data quality," wrote ADA President Cesar R. Sabates, D.D.S., and DQA Chair Paul Casamassimo, D.D.S. "Data quality improvement is a prerequisite to reliable quality measure reporting and should be a primary focus of technical assistance efforts. DQA is ready to assist CMS and the states with improving their data quality on oral health measures. DQA is also ready to assist CMS in generating state-level reports using TMSIS data."

In addition to supporting the mandatory reporting of the oral health measures in the Child Core Set, the two organizations also urged CMS to include oral health measures in the Adult Core Set and require that these measures be reported by the states.

"Measuring performance is critical to improving quality of care, hence incorporation of oral health care measures in the Adult Core Set is critical," according to the comments. "Low-income adults suffer a disproportionate share of dental disease and are nearly 40% less likely to have a dental visit in the past 12 months compared with higher income adults."

The comments noted that including oral health services measures in the Adult Core Set would do the following:

• Acknowledge the critical role of oral health in overall health and wellbeing.
• Enable states to assess the extent to which adults are receiving needed dental care.
• Reduce oral health care disparities.
• Highlight the extent to which there are adverse impacts associated with untreated dental disease in adults that impose significant costs in terms of both health outcomes and actual program expenditures.

The comments also encouraged CMS to undertake an "assessment of the barriers and facilitators pertaining to dental data exchange and information systems interoperability" and to work with other federal offices such as the Office of the National Coordinator for Health Information Technology and the Bureau of Primary Health Care to identify a roadmap for dental interoperability and data exchange.

"The ADA has been committed to pursuing coordinated and meaningful measurement through the DQA, which was convened by the ADA at the request of the CMS," the comments concluded. "DQA is the only comprehensive multi-stakeholder organization in dentistry that develops dental quality measures through a consensus-based process. Thirty-eight organizations with oral health experience participate in the DQA along with a public member."

Follow all the ADA's advocacy efforts at ADA.org/Advocacy.