The American Dental Association and the American Academy of Pediatric Dentistry filed comments to CMS in response to its proposed benefit and payment parameters for 2024.
CMS' proposal includes rules to streamline options on the ACA marketplace and add more provider network requirements.
The two dental organizations responded to four areas of the proposal affecting dentistry:
1. Under the proposal, issuers of Stand-Alone Dental Plans would be required to use the age on effective date as the sole method to calculate an enrollee’s age for rating and eligibility purposes. In their Jan. 30 letter, the two groups supported the proposed rule, noting that while most issuers already follow this approach, setting a standard for all issuers could reduce confusion.
2. Stand-Alone Dental Plan issuers would also be required to submit guaranteed rates under the proposal. The ADA and AAPD said requiring only the submission of guaranteed rates would lead to accurate advance premium tax credits of the pediatric dental essential health benefit portion of premiums.
3. CMS proposed requiring all plans, including SADPs, to comply with network adequacy rules, a move the ADA and AAPD said would enhance consumer choice and care accessibility.
4. Qualified health plans would also be required to follow fair marketing practices, including supplying correct information and not including misleading content. The two dental groups said the new rule would prevent potentially deceptive marketing of SADPs, adding that a standard marketing format should be implemented for such plans.