To provide value to NADP member companies offering dental benefits via government programs such as the health insurance marketplaces, Medicare, Medicaid or the Children’s Health Insurance Program (CHIP), the NADP Government Funded Program WorkGroup (GFP WG) volunteers continue to monitor key legislative and regulatory issues. Recent highlights from Dental Interact include:

NADP Victory! Health Plan Identifier Requirements Ended
NADP members scored an important victory regarding the recent repeal of Standard Unique Health Plan Identifiers (HPID). The repeal was announced by the Centers for Medicare and Medicaid Services (CMS) in its Oct. 28  final rule.

At several opportunities, NADP commented in support of repealing HPID requirements, including most recently in a February letter to CMS. On page 3 of the final regulation, CMS acknowledges public comment very similar to what NADP submitted as being helpful in confirming HPID repeal:

“Commenters explained that, at this point, the HPID would have been an impediment to the effective use of the HIPAA transactions. One large provider group wrote that, while the HPID had been intended to solve routing issues identified at the time HIPAA was enacted in 1996, in today’s environment, using the Payer IDs, providers no longer experienced routing issues. This group further noted that expending resources on implementing the HPID would be wasteful and would hurt the industry, including providers, vendors, clearinghouses, and payers.”

The CMS final rule rescinds the HPID and the implementation specifications and requirements for its use. The rule also outlines the CMS plans to deactivate the identifiers on behalf of the entities that had obtained them.


Dental in Medicare
Congressional action on H.R. 3 and several Medicare-related bills (including H.R. 4650 to include dental in Medicare) has been delayed and may not reach the House floor until December. According to senior House aides, a vote will not be scheduled until the Congressional Budget Office (CBO) completes its analysis of the prescription drug provisions in H.R. 3 and the costs of adding dental, vision and hearing benefits to the Medicare program. If the CBO reports lower than anticipated drug savings and/or higher than anticipated costs for new benefits in Medicare, modifications to the package may be made prior to a vote by the full House. More information about the provisions of H.R. 4650 is available online here.


GFP WG Reviewing Hospital and Insurer Price Disclosure Rules

GFP WG is currently reviewing the Insurer Price Disclosure rule (CMS- 9915 -P), released by the Trump Administration last week. NADP and GFP WG previously reviewed the Hospital Price Transparency rule (CMS-1717-F2) and found it to have minimal impact on dental benefits. Both rules are part of a continuing plan from the administration based on Executive Order 13877, “Promoting Healthcare Choice and Competition Across the United States,” which directed the U.S. Department of Health and Human Services (HHS), the Department of Labor, and the Internal Revenue Service to develop wide ranging price transparency rules in healthcare.

The President recently remarked on both rules, emphasizing the publication of prices to consumers via the Internet. He did not mention dental benefits. You can find the CMS press release on this insurer rule here.

If you have any questions about either rule, contact Government Relations Analyst Owen Urech.


NADP Monitoring Interoperability Rules Under OMB Review

The Office of Management and Budget (OMB) is currently reviewing interoperability rule CMS-9115-F for publication, along with information blocking rule RIN 0955-AA01. Earlier this year, NADP commented on the CMS rule, citing concerns about requiring development and use of APIs and recommending an exemption for dental benefits delivered through Medicare, Medicaid, CHIP, and Medicare Advantage as was provided for standalone dental plans on federal marketplaces.


More background on NADP comments and the proposed regulation is available online here. A news article online here includes additional background. We will continue to monitor these rules as they go through the review process at OMB


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