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Millions of Beneficiaries Could Benefit from Dental Payment Clarifications

February 12, 2026

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Findings from a recent analysis by Harvard School of Dental Medicine and Brigham and Women’s Hospital support that approximately 1.31 million beneficiaries in traditional Medicare annually are eligible for payment of dental services that are “inextricably linked” to a covered medical treatment. Being able to access such covered dental care could prevent medical complications and improve outcomes. Lisa Simon and Nicholas Daley, “Access To Dental Care Among People Newly Eligible For A Medicare Dental Benefit,” Health Affairs 45, no. 1 (2026): 92-96.

The researchers examined Medicare Current Beneficiary Survey data from 2017-22 to estimate how many individuals were eligible to receive Medicare-covered dental services in conjunction with eight medical treatments: cardiac valve surgery or valvuloplasty, organ transplant (including stem cell and bone marrow transplants), head and neck cancer treatment, starting or receiving dialysis for end-stage renal disease, and chemotherapy, CAR-T cell therapy, and high-dose antiresorptive therapies for cancer. Medicare regulation allows that payment under Part A and Part B may be made for dental services that are “inextricably linked to, and substantially related and integral to the clinical success of”  these particular treatments. See 42 C.F.R. § 411.15(i).

Although the findings do not account for the roughly half of all beneficiaries enrolled in Medicare Advantage (MA) plans, it can be extrapolated that a comparable number of MA enrollees annually are likewise eligible for dental benefits under the payment rule. MA plans are legally required to cover all medically necessary services covered by traditional Medicare (Part A and Part B).

Medicare beneficiaries currently face barriers in utilizing this benefit to access dental care. One barrier is lack of awareness about the benefit among dental and medical providers, and their patients. Another barrier is the low number of dental providers who are presently enrolled in Medicare and can claim reimbursement for furnishing this care. Medicare’s website offers information to facilitate understanding about Medicare dental coverage, and how dentists can enroll in Medicare and bill for covered services.

The Center for Medicare Advocacy actively participates in the Consortium for Medically Necessary Oral Health Coverage, consisting of 250 leading dental, medical, public health and patient advocacy organizations. The Consortium played a leading role in advocating for Medicare’s dental payment clarification, emphasizing the teeming evidence that unresolved dental issues can complicate and jeopardize treatment of major health conditions. This week, the Consortium submitted formal nominations to CMS recommending three circumstances in which dental services should be recognized for Medicare payment. It presented clinical evidence supporting how appropriate dental care is “inextricably linked” to the successful management and treatment of diabetic retinopathy and diabetic nephropathy. It likewise urged CMS to consider payment for necessary dental care before and during scheduled in-hospital procedures for Medicare patients deemed to be at high risk for hospital-acquired pneumonia. Such patients would include people with structural lung diseases and multiorgan failure. The agency’s consideration of these and other clinical nominations will be reflected in future rulemaking addressing the CY 2027 Medicare Physician Fee Schedule.

February 12, 2026 – W. Kwok

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