On March 9 CMS
released the final rule “Medicare and Medicaid Programs; Patient
Protection and Affordable Care Act; Interoperability and Patient Access
for Medicare Advantage Organization and Medicaid Managed Care Plans,
State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities,
Issuers of Qualified Health Plans on the Federally-facilitated
Exchanges, and Health Care Providers” (CMS 9115-F). This rule requires
that Medicaid, CHIP, and Medicare Advantage dental plans create
standardized application programming interfaces (API) for patients to
access, encounter, and clinical data as well as a provider directory.
Stand-alone dental plans on federally facilitated exchanges (FFEs) would
not be required to meet these requirements.

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. This argument
was in line with the Administration’s own reasoning for exempting
Standalone Dental Plans (SADP)s on federally facilitated exchanges
(FFEs) from the rule.

The Administration responded to NADP’s comment letter in the final rule by saying:

appreciate the commenter’s request for additional information. We note
that MA claims data, encounter data, and clinical data related to
supplemental benefits, including dental services, are subject to the API
requirement, even if issuers only offering SADPs on FFEs are not
subject to the requirement. (p.172)”

disappointed that CMS has decided not to exempt dental plans in Medicare
Advantage, CHIP, or Medicaid, and will continue to monitor the
implementation of the final rule and engage with the administration on
managing impacts. The Patient Access API must be implemented by all
effected plans by January 1, 2021.

For more information on the rule and NADP’s comments please contact Owen Urech.


CMS Press Release

CMS Fact Sheet

CMS 9115-F Full Text

NADP Comment Letter on the Proposed Rule

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