After a strong advocacy campaign spearheaded by AAPD with the ADA, AAOMS and the disability community, the Centers for Medicare and Medicaid Services (CMS) has agreed to establish a new dental billing and payment arrangement to improve access for hospital dental operating room cases requiring care under general anesthesia. Click here for an advanced copy of the CMS final regulation released on October 31, 2022, addressing this issue (see pages 326-335). Publication is scheduled for November 23, 2022.

CMS has agreed to establish a new HCPCS G code and to assign that code to the Medicare Ambulatory Payment Classification (APC) 5871 (Dental Procedures) with a Medicare facility payment rate of approximately $2000. 

The new code is HCPCS code G0330, to describe facility services for dental rehabilitation procedure(s) furnished to patients who require monitored anesthesia (e.g., general, intravenous sedation (monitored anesthesia care)) and use of an operating room. CMS is also allowing additional comment on the APC assignment for the new G code through an addendum to this section of the final rule; we will plan to comment on the addendum.

This decision follows many comments CMS received from AAPD state chapters and members, and comments organized as part of the AAPD-ADA-AAOMS advocacy campaign from the disability community and the Ambulatory Surgery Center Association (ASCA). It also comes following active engagement from Capitol Hill on this issue through AAPD efforts, as Representatives Terri Sewell (D-Ala. 7th) and Drew Ferguson (R-Ga. 3rd) led a congressional comment letter with other members of Congress to CMS, requesting action to address dental OR access no later than this year. Click here for more details on these comments.

This final rule follows the proposed rule issued over the summer, where CMS had proposed a change in the facility fee for dental services, but had not yet proposed the establishment of a code that recognizes dental rehabilitative services. The AAPD and its partners have long advocated for a specific dental billing code and appropriate reimbursement that recognizes the dental services provided in an OR setting. AAPD-ADA-AAOMS meetings with and comments to the agency on the proposed rule recommended that the CMS continue to consider a new code as a viable option. The AAPD believes that a comprehensive fix to address hospital OR access for dental surgeries includes allowing ambulatory surgery centers (ASCs) to provide these services. The AAPD-ADA-AAOMS continue to advocate for allowing dental services to be billed as a covered procedure by ASCs. CMS also responds to this request in the final rule, agreeing to consider the request in future rulemaking. The code adjustment finalized in this rule actually takes a significant step forward at making ASC billing a reality, as the new code can be eligible to be included on the ASC-covered procedures list. AAPD-ADA-AAOMS will continue to pursue this effort in our ongoing discussions with CMS and Congress.

The final regulation, which will be formally published in the Federal Register later this month, goes into effect Jan. 1, 2023. AAPD will issue additional information and guidance upon further analysis of the rule. For any questions on this issue please contact Chief Operating Officer and General Counsel C. Scott Litch at 773-938-4759 or slitch@aapd.org.