Public Comments Due by Sep. 6, 2022
The Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule that could allow Medicare payment in more circumstances where dental services are important to the outcome of primary, covered medical treatments. The proposal reflects a growing understanding that “unequal distribution of dental services and prohibitive costs, particularly for older adults who are at the highest risk for poor oral health, can lead to and further complicate the treatment of medical conditions.” CMS seeks public comment on numerous issues concerning the proposal by September 6, 2022.
Under the proposal, CMS would clarify the exception to Medicare’s statutory dental exclusion whereby payment may be made for certain dental services that are “inextricably linked to, and substantially related and integral to, the clinical success of other covered medical services.”
CMS proposes to recognize, as a specific example, dental examinations and necessary treatment to eradicate dental infections prior to organ transplant surgery, cardiac valve replacement or valvuloplasty procedures.
The agency is also requesting public input on other clinical scenarios where dental services may qualify under the exception. CMS seeks comments that provide compelling, systematic, and clinically meaningful evidence to support the inclusion of additional medical situations where Medicare payment would be appropriate.
The agency also requests comment on several related topics and impacted policies in the proposed rule, including issues around utilization, payment, coding, interprofessional coordination, care management and integration, health equity, and potential future payment models.
Interested parties can review the full text of the proposal at: https://www.regulations.gov/document/CMS-2022-0113-1871 (scroll down to Section II.L)
Attached are short and long-version templates, developed with our partners at Families USA and Justice in Aging, that parties may work off of to organize their personalized comments, which can be submitted electronically at the same link.