Speaking up for transparency and affordability

By: Colin Reusch

In the past couple of weeks, the Children’s Dental Health Project (CDHP) has submitted comments to the Centers for Medicare and Medicaid Services (CMS), emphasizing the need for policies that improve access, transparency and affordability of dental care and coverage. (See our comments at the end of this post.) One set of comments was co-signed by 16 other partners who care about children's health and well-being.

The first proposal by CMS’ Center for Medicare and Medicaid Innovation (CMMI) sought public feedback regarding new priorities it is considering to promote patient-centered care and contain costs. CMS also invited public comment on changes outlined in the Notice of Benefit and Payment Parameters for 2019, regarding benefits, affordability, provider networks, consumer-focused resources and information, as well as states’ roles in the health insurance marketplaces.

CDHP took both of these comment opportunities to stress that children’s and families’ oral health is integral to their overall health. Our nation must invest in efforts that improve quality, affordability and access to related coverage and services.

While signaling subtle shifts in its priorities, CMMI put forward a number of approaches related to improving healthcare quality, outcomes and reducing costs, from exploring new payment and health care delivery models to chronic disease prevention efforts. In each category, CDHP recommended avenues to integrate and meaningfully track dental health to improve our nation’s oral health. After reviewing CMMI’s proposed new direction, CDHP urged the agency to pay continued attention to improving oral health for both children and adults.

Children’s oral health is too important to undermine the availability of comprehensive coverage options.

CDHP expressed our concerns on several of CMS’ proposals in its potential new rule, given how they might limit access to dental coverage and care. We also invited organizational colleagues in the children’s health community to join our comments. Among our recommendations focused on informing consumers and ensuring access to comprehensive coverage, CDHP and 16 coalition partners urged CMS to:

  • Preserve the standardized option requirement in state exchanges and at HealthCare.gov, and ensure it includes children’s dental services. Eliminating the standardized option (or “Simple Choice” plan) requirement would leave consumers unable to make apples-to-apples comparisons when shopping for coverage. Further, our recommendation of including pediatric dental services in the plan options proposed for 2019 and beyond would give children the best chance at getting the full range of dental coverage they need.
  • Abandon proposed changes to states’ Essential Health Benefit (EHB) benchmark plans that could reduce children’s comprehensive oral health coverage. Under the proposed rule, states could change their EHB benchmark plans in a way that could lead to insurance options with pediatric oral health benefits that are too narrow. Our concern is not theoretical: the EHB benchmark plan in Utah, adopted from the state’s employee health plan, excludes some key services that may be necessary to treat and manage tooth decay. The proposed changes increase the risk of such limited dental coverage being adopted. Children’s oral health is too important to undermine the availability of comprehensive coverage options.
  • Maintain actuarial value (AV) standards for stand-alone dental plans in the marketplace to better ensure consumers understand their coverage options. Our coalition believes AV standards are a critical consumer protection. The proposed rule could leave marketplace shoppers without the information they need to easily understand and accurately compare the value of their dental insurance options.

CDHP also addressed some proposed changes to provider network standards. We are concerned the rule’s change in network adequacy regulation and oversight would enable states to “rubber stamp” plans with unreasonably limited access to oral health providers. Ensuring access to a range of dental providers and specialists is critical for families, especially those in rural areas. And insufficient access to dental care can exacerbate oral health challenges and health disparities.

Download CDHP’s comments below:

  • CDHP and partner comments to Center for Medicare and Medicaid Services Administrator Seema Verma on the Notice of Benefit and Payment Parameters for 2019
  • CDHP comments to Center for Medicare and Medicaid Innovation Deputy Director Amy Bassano on the RFI on its New Direction

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Did you know?

44% }
of U.S. children will have at least one cavity by kindergarten.
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