The American Academy of Pediatric Dentistry (AAPD), American Dental Association (ADA), and the American Association of Oral and Maxillofacial Surgeons (AAOMS) have been working together in a concerted advocacy campaign to address the challenges pediatric dentists and other dentists around the country are experiencing in obtaining or maintaining hospital or ambulatory surgical center (ASC) operating room time for dental cases requiring care under general anesthesia.

On July 21, 2023, the Centers for Medicare and Medicaid Services (CMS) released the CY 2024 Proposed Rule on Hospital Outpatient and Ambulatory Surgical Center Payments Under Medicare.[1] This proposal is of critical importance to boosting facility fees for dental operating room cases in such settings. The good news for patient access that HCPCS code G0330 (new dental rehabilitation facility fee code approved by CMS under HOPPS for CY 2023) is proposed to be included on the covered procedures list for ASCs. This was a specific request from AAPD-ADA-AAOMS, with crucial support from Members of Congress and patient disability advocacy groups.

The proposed rule is extremely complex, as there is a list of specific CDT codes that must be included when billing for G0330, and other CDT codes that can be billed separately to generate a facility fee.  If finalized without change, the Ambulatory Payment Classification (APC) rate – i.e. facility fee- for G0330 would drop from $1,722.43 in 2023 for HOPD to $938.69 in 2024. Under the proposed rule, the national average ASC payment for G0330 in ASCs would be $495.52 (this is typically roughly 1/2 of the hospital rate). However, depending on what CDT codes are reported in addition to those linked to G0330, the actual total facility fee for a dental case might be significantly higher. These rates are reviewed and adjusted annually based on claims data.

AAPD-ADA-AAOMS submitted a detailed regulatory comment letter. Click here for a copy. These comments were also supported by the Ambulatory Surgery Center Association, as well as 13 Members of the Consortium for Constituents with Disabilities (CCD) Health Task Force (HTC):

Access Ready Inc
American Association on Health and Disability
American Medical Rehabilitation Providers Association
Autistic Women & Nonbinary Network (AWN)
Brain Injury Association of America
Center for Medicare Advocacy
Epilepsy Foundation
Family Voices
Justice in Aging
Lakeshore Foundation
National Down Syndrome Congress
The Arc of the United States

Click here for a copy of the CCD HTF letter. The AAPD is also a member of CCD.

The final rule will likely be released in November. The AAPD will educate and inform its members about the nuances and implications for billing/coding hospital OR and ASC dental cases after the final rule takes effect on January 1, 2024.

For any questions, please contact Chief Operating Officer and General Counsel C. Scott Litch at 773-938-4759 or