Earlier this year, the Centers for Medicare and Medicaid Services released proposed rules (or proposed regulation) related to access to care in Medicaid and CHIP programs, as well as access, finance, and quality concerns related to managed care in Medicaid and CHIP programs. AAPD was pleased to have the opportunity to comment. 

AAPD supported much of the proposed regulation from the Centers for Medicare & Medicaid Services (CMS) in Ensuring Access to Medicaid Services on transparency, accountability, and streamlined data collection, while urging active provider and beneficiary engagement in State Medicaid programs and suggesting dental-appropriate sources for rates analyses. Specifically, AAPD urged CMS to: 

  • Involve dental providers – and providers of other covered services in Medicaid programs – in state Medicaid advisory committees  
  • Develop benchmarks for dental service payment rate analysis using reputable sources such as FAIR Health 
  • Ensure the experiences of children are represented (via proxy with parents or caregivers) in beneficiary committees 
  • Promote the transparency and accessibility of both provider and beneficiary resources for Medicaid programs online 
  • Remain steadfast in meeting the evolving needs of people with disabilities 
  • Include oral health measures for people with disabilities in Home and Community Based Services programs 

The CMS Medicaid and CHIP Managed Care Access, Finance, and Quality proposed rule covered topics such as state directed payments, health measures, and appointment wait time standards to be upheld by managed care entities. Key comments from AAPD related to:

  • Using state-directed payments as a mechanism to increase dentist participation in Medicaid programs 
  • Encouraging the administration of “secret shopper” and other surveys to better understand beneficiary experience across different health services, including dentistry  
  • Establishing appointment wait time standards that managed care entities must uphold to promote access to care 
  • Instituting a medical loss ratio requirement for managed care entities 

The letters to CMS on Medicaid access and Medicaid managed care are available online at AAPD.org. For additional information, please contact RPC@aapd.org.