February 02, 2012 17:46 ET

NADP Calls for Equitable Treatment of Americans With Dental Policies

NADP Files Comments on HHS Bulletin on Essential Benefits Under ACA

DALLAS, TX--(Marketwire - Feb 2, 2012) - In response to Health and Human Services' Dec. 16 Bulletin on essential benefits, the National Association of Dental Plans (NADP) filed comments earlier this week highlighting the need for equitable treatment of Americans with dental policies both inside and outside health Exchanges (starting in 2014). The comments urged HHS to allow consumers to keep the dental policies and dentists they have now and encouraged flexibility for the states to choose from a variety of dental policies currently in the marketplace.

"The practical and political stakes could not be higher; 43.7 million employees and dependents have dental policies today through 1.65 million small businesses that are now vulnerable to disruption when the Exchanges become effective in 2014," commented Evelyn F. Ireland, NADP's Executive Director. "And for consumers that are getting dental coverage for the first time, the dental specific benchmark options provided in the Bulletin may not be affordable."

The HHS Bulletin allows the states to adopt their own essential health benefits by using benchmarks identified by HHS. Under this approach, a state can chose a medical benchmark that includes the state's mandated benefits and have those mandates included as part of federally subsidized coverage. While the Bulletin includes specific dental benchmarks for states to use when "pediatric oral services" are missing from the selected medical benchmark, the proposed dental specific benchmarks are not typical for the dental market. If "pediatric oral services" is to include services that are typically covered under a dental policy, NADP suggested that HHS both clarify the trigger for adding benefits from a dental specific benchmark and allow states to use the dental policies parallel to the four main health benchmarks as a way of keeping coverage affordable.

NADP's comments include these seven recommendations:

1. Align inside and outside exchange rules to provide for equitable treatment for consumers in all markets.
2. Consumers with dental coverage should not be required to purchase duplicative coverage.
3. Set the age range for "pediatric" at the federal level.
4. Clarify when a state must supplement its medical benchmark with a dental specific benchmark to meet the "pediatric oral services" of the EHB.
5. Provide flexibility to the states to fill in "missing pediatric oral services" by using the dental plan offered in any of the categories of medical plan benchmarks.
6. Allow states to utilize plan benefits and cost sharing typical in dental plans.
7. HHS should affirmatively state if "medically necessary" orthodontia is part of the EHB and covered under a medical benchmark.

NADP filed the comments as part of its ongoing "Keep Our Coverage" campaign which urges HHS to clarify that separate dental policies of Americans insured by small businesses can meet the requirements of the Essential Health Benefits Package for children's pediatric oral coverage. contains more information about the possible impacts of the Affordable Care Act on dental benefits outside the Exchange as well as links to NADP's Exchange white paper, "Offering Dental Benefits in Health Exchanges: A Roadmap for Federal and State Policymakers."

About NADP
National Association of Dental Plans (NADP), a Texas nonprofit corporation with headquarters in Dallas, Texas, is the "representative and recognized resource of the dental benefits industry." NADP is the only national trade organization that includes the full spectrum of dental benefits companies operating in the United States. NADP's members provide Dental HMO, Dental PPO, Dental Indemnity and Discount Dental products to 141 million Americans, more than 80 percent of all Americans with dental benefits.

Contact Information

    Evelyn Ireland
    NADP Executive Director
    (972) 458-6998, x101
    Email Contact