On September 13, 2019 the AAPD, ADA, and AGD (Academy of General Dentistry) wrote the Centers for Medicare and Medicaid Services (CMS) to comment on their proposed rule CMS-2406-P2, entitled Medicaid Program; Methods for Assuring Access to Covered Medicaid Services-Rescission.

The AAPD-ADA-AGD regulatory comment letter noted that Medicaid plays an essential role in our nation’s oral health safety net, as over 23 million Medicaid enrollees receive dental services via Fee-for-Service (FFS) and an additional 5.3 million Medicaid enrollees receive them via combined FFS/managed care. These include pregnant women, children, the elderly, the disabled, and patients with a chronic and/or complex health condition. It is critical that these beneficiaries have access to quality services received in a timely manner. While acknowledging CMS efforts to strike a balance between maintaining access to care and providing states with flexibility, the groups opposed CMS’ proposal to rescind the November 2015 Medicaid access rule. That rule required states to develop and submit an access monitoring review plan (AMRP). These AMRPs provide a means for CMS to measure access to care and reimbursement rates. Further, using a checklist developed by the ADA,[1] state dental associations review the AMRPs and ensure that the states have plans in place to ensure access to care for FFS beneficiaries. It is important that state dental associations and other stakeholders – such as state pediatric dentistry chapters with our Public Policy Advocates network- undertake this review.

Therefore, the comment letter urged CMS to develop a template and standardize AMRPs, and also utilize the ADA’s checklist as a foundational tool for such standardization for the dental benefit within Medicaid FFS programs. Within the rule, CMS notes that it is developing a methodology for reporting Medicaid access data in lieu of AMRPs. The comment letter recommended that CMS should first issue criteria for improving the AMRPs before loosening the monitoring requirements:  “Any methodology used in place of an AMRP must be built on sound data and analyses, must be reported by states to CMS on an annual basis, and must be in place before the AMRP requirement is rescinded.” The ADA, AGD, and AAPD also requested the opportunity to participate in the review process. Ultimately, it was recommended that CMS should monitor rate reductions and maintain a process for beneficiaries and providers to provide input on the implications of rate reductions. While there is a lot of variation between states on Medicaid FFS reimbursement rates, the comment letter noted that on average in 2016, Medicaid FFS reimbursement was 49.4 percent of fees charged by dentists for children and 37.2 percent for adults.[2] This shortfall in reimbursement threatens access to care.

Click here for a copy of the letter.

[1]See American Dental Association Medicaid Toolkit, “Medicaid Fee-for-Service: Access Monitoring Plans Review Checklist,” 

[2] See: Niodita Gupta, Cassandra Yarbrough, Marko Vujicic, Andrew Blatz, Brittany Harrison, American Dental Association Health Policy Institute Research Brief, “Medicaid Fee-for-Service Reimbursement Rates for Child and Adult Care Services for All States, 2016,”