Essential Health Benefits: AAPD and ADA Comment on Proposed Federal Regulations

Pediatric oral health is defined under the Patient Protection and Affordable Care Act (ACA) as an essential health benefit.  Health insurers in the individual and small group markets, inside or outside of state health insurance exchanges, must offer qualified health plans that cover ten categories of essential health benefits.   It is estimated that 3 million children will gain dental benefits through the health insurance exchanges by 2018.  Federal guidance issued in 2011 indicated states can use the Federal Employees Dental and Vision Plan or the state CHIP plan as a benchmark for a stand-alone pediatric oral health plan, since currently most dental insurance is offered separately from medical insurance plans. On November 20, 2012, the U.S. Department of Health and Human Services released proposed regulations on Essential Health Benefits, Actuarial Value, and Accreditation Standards: Ensuring Meaningful, Affordable Coverage. The proposed regulations repeat much of the same material from earlier federal guidance.  Joint regulatory comments were filed on December 19, 2012 by the American Academy of Pediatric Dentistry (AAPD) and the American Dental Association (ADA).  Click here for a copy of the comment letter.  For further information contact COO and General Counsel C. Scott Litch at


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