CMS Issues Letter on Implementation of CHIP (Children’s Health Insurance Program) Dental Benefit

On October 7, 2009, the Centers for Medicare and Medicaid Services (CMS) issued a letter to states concerning implementation of required dental coverage under the Children’s Health Insurance Program Reauthorization of 2009 (CHIPRA). CHIPRA requires that, effective October 1, 2009, "child health assistance provided to a targeted low-income child shall include coverage of dental services necessary to prevent disease and promote oral health, restore oral structures to health and function, and treat emergency conditions." The CMS letter discusses the requirements for services and a dental benefits package, including the supplemental "wrap-around" option for children who have health insurance but are uninsured or underinsured with respect to dental. The underlying legislative provisions were strongly advocated by the AAPD and a broad coalition of organizations including the ADA and the Children’s Dental Health Project.


The AAPD has worked closely with CMS on these implementation issues, including an August 2009 meeting with Cindy Mann, the new CMS director of the Center for Medicaid and State Operations. The AAPD is delighted that CMS directs states to adopt a dental periodicity schedule, as this has been a Medicaid regulatory priority of the AAPD for several years. In fact, CMS states that "we encourage States to rely on nationally recognized standards, including Medicaid dental periodicity guidelines used for children under EPSDT or the guidelines from the American Academy of Pediatric Dentistry (AAPD)." A link to the AAPD guidelines is provided in the letter, and a check off-box to indicate adoption of such a dental periodicity schedule is included in the State Plan Amendment template attached to the CMS letter.


The AAPD is also specifically referenced in the Code of Federal Regulations sec. 457.520 which describes the well-baby and well-child care services for which cost sharing (copayments, deductibles, coinsurance, etc.) cannot be imposed:


"(5) Routine preventive and diagnostic dental services (such as oral examinations, prophylaxis and topical fluoride applications, sealants, and x-rays) as described in the most recent guidelines issued by the American Academy of Pediatric Dentistry (AAPD)."


Click here to view the CMS letter.


For further information contact AAPD Dental Benefits Manager Mary Essling at


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