On June 25, NADP received a letter from Director of the Center for Consumer Information & Insurance Oversight (CCIIO) Randy Pate, in response to NADP’s joint letter to
the Health and Human Services Secretary Alex Azar, which urged the U.S.
Department of Health and Human Services (HHS) to “provide the option of
purchasing dental coverage independent of medical coverage on the
federal health insurance Marketplace.” The letter from NADP presented a
new perspective on the independent purchase of dental plans on
exchanges, bringing to the foreground the needs of kidney and transplant
patients, who require dental treatment before and after surgery.

The response
letter from CCIIO represents a significant departure from prior
communications between the Agency and stakeholders. CCIIO appears to
have reversed course with respect to their stance that there are no
statutory barriers to independent purchase of dental on the federal
marketplace. In 2019, CCIIO communicated with Congressional staff that
the Affordable Care Act ensures that stand-alone dental plans may be
offered on Exchanges as a separate health insurance product. CCIIO also
recognized the benefits of independent purchase, as evidenced by
activity that is already happening in several state-based marketplaces.
The Agency expressed that the primary barrier to independent purchase
was simply a technical issue with, which the Centers for
Medicare and Medicaid Services (CMS) was actively working to resolve.

NADP will be
reaching out to Congressional supporters to explore next steps and will
continue to advocate for independent purchase of dental benefits on the
federal health insurance Marketplace, which provides consumers with an
additional option beyond the existing private individual market through
which to obtain dental coverage. NADP’s kidney and transplant partners
have expressed their willingness to continue to advocate on this issue.

Please contact Director of Government and Regulatory Affairs Teresa Cagnolatti with any questions about this issue.

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