AAPD and ADA Comment to Federal Government on Federally-Facilitated Exchanges Guidance
On August 3, 2012 the AAPD and ADA submitted comments in response to May 16, 2012 guidance issued by the Center for Consumer Information and Insurance Oversight (CCIIO) regarding federally-facilitated exchanges (FFE). This guidance relates to options for states that choose not to operate health insurance exchanges, thereby triggering the requirements of the Affordable Care Act (ACA) that the federal government operate exchanges in such states. This letter is part of our ongoing dialogue with CCIIO and the HHS Office of Health Reform to promote effective pediatric oral health benefits within health insurance exchanges. Among the comments in the letter:
"Ensuring that the pediatric dental/oral health benefit is comprehensive and meets the law’s intention of providing children adequate access to oral health services is extremely important to the ADA and AAPD. Dental providers want to ensure that the benchmarks set for health plans offered within the exchange provide an appropriate level of preventive and restorative benefits needed to maintain a child’s oral health, and when they do not, that supplemental coverage is available. Patients must have access to supplemental coverage if a benchmark’s coverage is limited."
"We believe the standard [for network adequacy] should require QHPs [qualified health plans] to include general and pediatric dentists as well as those dentists with expertise treating children who may have complex needs, including but not limited to children with physical or cognitive limitations."
" . . . we believe the FFE should closely review plan service areas to ensure the target population is able to access dental services as intended."
"The ADA and APPD recommend that CMS require any designated accrediting entity to use specific clinical quality measures developed by the Dental Quality Alliance (DQA), a voluntary consensus organization requested by the Centers for Medicare and Medicaid Services, with broad representation that is currently engaged in developing quality measures for accrediting dental plans."
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