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Federal Advocacy

NADP works to advance the dental benefits industry and improve oral care for all. One of the primary ways we achieve this is by advocating on behalf of dental plans at the top levels of government as policies are conceived, debated, and implemented. NADP lobbies Congress and executive agencies, and by offering information and tools that empower dental carriers to share their perspective and expertise directly with policymakers.

Current Issue Briefs  

  • FMAP Increase Fact Sheet
    • NADP supports an overall and dental specific Federal Medical Assistance Percentage (FMAP) increase in the next COVID-19 relief package to preserve Medicaid adult dental benefits.
  • Stabilize Dental Coverage in Marketplace  
    • Decouple medical and dental enrollment on insurance Marketplaces and stop unintended coverage terminations.
  • DOC Access Issue Brief
    • The “Dental and Optometric Care Access Act” (DOC Access Act) eliminates basic consumer protections and would mean higher costs for consumers with dental benefits. Protect dental plans’ ability to negotiate discounts for patients.
  • APCD Issue Brief
    • Many states have established all-payer claims databases (APCDs); policymakers should encourage standardization of APCD reporting
  • McCarran Ferguson Issue Brief
    • Repeal of the McCarran-Ferguson exemption creates no value for patients and consumers. The repeal is opposed by state regulators because it will create conflicting federal and state oversight requirements and lead to costly litigation.


NADP Values in Considering a Dental Benefit for Medicare

NADP Values in Considering a dental benefit for Medicare

Comment Letters

NADP continuously works to educate legislators and regulators regarding the importance of the dental benefits industry in relation to improving overall oral health.

2020 Rule Comments and Activity

  • Medicaid Fiscal Accountability Rule

On January 31, NADP filed comments with the Centers for Medicare and Medicaid Services (CMS) regarding the Medicaid Fiscal Accountability Rule (MFAR). NADP opposed the proposed expansion of the definition of permissible classes of health care items and services for the purpose of imposing Medicaid-related taxes.

  • 2021 Exchange Notice of Benefit and Payment Parameters

On March 2, NADP commented on the annual notice of benefit and payment parameters for the ACA exchanges. NADP provided insight from members on the state of value based dental care, including that fee for service remains the primary reimbursement method for the industry.

  • Interoperability Rules

In May 2019, NADP commented in opposition to the inclusion of dental plans in the rule's requirements, citing cost concerns for plans, the likely lack of dental data utilization by patients, and privacy issues.

  • 1557 Tagline Repeal

On June 12, the HHS Office of Civil Rights finalized "Nondiscrimination in Health and Health Education Programs or Activities: Delegation of Authority" (RIN 0945-AA11) which permanently repeals tagline requirements under section 1557 of the Affordable Care Act, effective August 18, 2020. In August 2019, NADP filed comments supporting the repeal of 1557 tagline requirements

  • Direct Primary Care

On August 7, NADP filed a comment with the Internal Revenue Service (IRS) on the proposed rule regarding “Certain Medical Care Agreements” (RIN 1545-BP31) that would expand the definition of “medical care” under section 213(d) of the IRS Code, to include health sharing ministries and direct primary care arrangements.

  • Price Transparency Rule

In October the Trump Administration announced the publication of the final rule on "Transparency in Coverage" (CMS-9915). Plan and issuers that offer limited scope dental or vision benefits along with their major medical coverage are not required to disclose the information, embedded dental benefits could be required to report as part of the final rule in the future.

  • Final Rule on Medicaid Managed Care

On November 9, the Centers for Medicare and Medicaid Services (CMS) released the final rule "Medicaid Program; Medicaid and Children's Health Insurance Program (CHIP) Managed Care" (CMS 2408-F). In January 2019, NADP filed comments voicing support for changes in tagline requirements, grievance/appeals support, and asking for a carve-out for dental benefits in the existing MMC medical loss ratio reporting requirements.

  • SUNSET Rule

In December, NADP submitted comments on the proposed rule "Securing Updated and Necessary Statutory Evaluations Timely” (SUNSET). The comments focus on the uncertainty the rule creates in the regulatory environment and the detrimental effects of the potential elimination of regulations without proper review.

  • Interim Final Rule on COVID-19

As part of NADP’s continued advocacy to preserve adult dental benefits in Medicaid, comments were filed in opposition to portions of the November 6 interim final rule on COVID-19 (CMS-9912-IFC), which reversed policies established in April by CMS requiring states to maintain dental benefits for Medicaid enrollees in order to receive enhanced FMAP dollars under the FFCRA.

Members-Only Comment Letter Archive

Health Care Reform

NADP is pleased to share important considerations and offer our expertise about dental benefits as the Administration and Congress consider health care reform policies and priorities. We look forward to working with stakeholders to ensure consumer choice and access to dental care in a way that is consistent with NADP’s principles—principles that value oral health and the role of the dental benefits industry in improving access to affordable, quality dental care.

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