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The AAPD continues its advocacy campaign to address the challenges pediatric dentists around the country are experiencing in obtaining or maintaining hospital or ambulatory surgery center (ASC) operating room time for dental cases requiring care under general anesthesia. In 2020, the AAPD engaged the consulting services of the Washington, D.C. law firm of Powers Pyles Sutter and Verville PC. The firm identified a major access barrier as the lack of a specific dental facility fee code in CMS HCPCS (Healthcare Common Procedure Coding System). This results in an abysmally low facility fee for dental cases. HCPCS codes are developed by CMS Medicare. Hence, a strategy was developed to seek a specific facility fee code for dental cases and to ensure it will receive an appropriate level of reimbursement.

It was concluded that a HCPCS Level II Category G Code would be the most appropriate coding category, since G codes are not only commonly utilized in the Medicare Hospital Outpatient Prospective Payment System (HOPPS), but also are recognized by Medicaid and other non-Medicare payers as well. Therefore, after several meetings and discussions with CMS, the AAPD along with the American Dental Association (ADA) and the American Association of Oral and Maxillofacial Surgeons (AAOMS) submitted a proposal to CMS on September 21, 2021, with this simplified coding language:

“Covered dental procedure requiring general anesthesia; facility services only.”

We also recommended that CMS place the code into the same payment category as coded dental procedures (APC 5871) to receive a competitive facility fee compared to other types of surgeries, and that the code be included on the ambulatory surgery center covered procedures list to support access in these settings. Click here for a copy of that letter.

On January 20, 2022, the American Academy of Pediatrics wrote CMS in support of the AAPD-ADA-AAOMS code proposal. Click here for a copy of that letter.

On February 17, 2022, the AAPD, ADA, and AAOMS filed written testimony with the Subcommittee on Health of the House Ways and Means Committee summarizing the problem and advocating CMS adoption of our proposal. This was in response to the Subcommittee’s hearing on Bridging Health Equity Gaps for People with Disabilities and Chronic Conditions. Click here for a copy of the testimony.

AAPD members also advocated on this issue during their Congressional visits on March 14-15, 2022.

For further background on this issue, see:

On March 24, 2022, 24 national organizations from the Consortium for Citizens with Disabilities (CCD) Health Task Force wrote CMS in support of the AAPD-ADA-AAOMS facility fee code proposal. Click here for a copy of the letter.

On May 18, 2022, 25 Members of the U.S. House of Representatives wrote CMS in support of efforts to obtain a HCPCS facility fee code for dental cases. This Congressional Dear Colleague Letter was led by Congresswoman Terri Sewell (D-Ala. 7th) and Congressman/dentist Drew Ferguson (R-Ga.3rd). The AAPD applauds their leadership on this critical issue. Click here for a copy of the letter.

For further information, please contact Chief Operating Officer and General Counsel C. Scott Litch at 312-337-2169 ext. 29 or