In early October 2011, the AAPD joined ADA and other members of the Organized Dental Coalition to comment on proposed regulations of CMS (Centers for Medicare and Medicaid Services) concerning the development of state health insurance exchanges as required under the Affordable Care Act (ACA). The main points raised in the ODC letter were:
- There should be the same consumer protections for stand-alone dental plans and medical insurance plans.
- Stand-alone dental insurance plans should be subject to the same certification requirements as medical insurance plans, except in instances where a criterion is clearly not applicable
- State health insurance exchanges should strive to maximize the dental insurance plan choices available to consumers.
- There should be an "apples-to-apples" comparison of dental insurance plans so that consumers can easily understand their choices based on price, quality and other factors.
- Officials should seek input from state dental societies in the early development of the exchanges, to help assure consumer-friendly web sites for dental patients and their families.
- Access to dental health care for special needs individuals with disabilities should be specifically addressed in the insurance exchange design and implementation.
- Individuals serving as consumer navigators in the exchanges should have a full understanding of the dental coverage options, because the dental delivery system is very different from the medical system.