Re: Draft 2017 Letter to Issuers in the Federallyfacilitated Marketplaces

Dear Administrator Slavitt,

The National Association of Dental Plans (NADP) appreciates the opportunity to provide
comments on the Draft 2017 Letter to Issuers in the Federallyfacilitated Marketplaces
(Letter) released on December 23, 2015. Much of what is included in the Letter to Issuers
originated from the December 2, 2015 Notice of Benefit and Payment Parameters (NBPP)
proposed regulation. Our comments on the proposed Notice are attached as they still
remain a critical concern to the dental benefits industry.

Ch.2 Sec.3 Network Adequacy / Federal Default Standards: The mileage and timing
standards as proposed for dental providers is appropriate and a feasible option as a network
adequacy metric for the FFMs. As network adequacy standards are not typically utilized
within the dental benefits industry, NADP requests a year delay with any application of new
measures for Plan Year 2018. In addition, the continued availability for written justification
on rare instances when the CEAC may not be attainable is appreciated. CMS must also be
cognizant when applying new network adequacy metrics to minimize confusion of differing
standards with each state amid the markets for both consumers and issuers.

Recommendation: Dental plans need additional time to assure their network systems can
incorporate these new administrative metrics and geographical access mapping software
can correctly identify and utilize the five listed categories.

Ch.2 Sec.4 Essential Community Providers (ECP): The ECP standards were designed for
medical providers where ECPs are more common than in the dental provider community.
While dental plans continue to work towards increasing networks with ECPs, the medical
ratio of 30 percent remains a difficult target. There are few incentives for dental providers to apply and
be listed as an ECP, and providing deadlines for their participation is unreasonable.


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