June 2015


NADP Cited for Dental Exemption in OH Network Rules

Late last week, Erika Cybulskis with Delta of OH provided a memo and updated draft OH rule on provider networks, which show the Ohio Department of Insurance (DOI) has revised the definition of “health benefit plan” to eliminate the inclusion of dental plans.

ODI describes reasons for this change in the ODI memo, citing NADP and carrier input:

Redefining health benefit plan
Proposed rule 3901-8-16 was initially drafted to include dental care within the definition of “health benefit plan,” which meant that dental plans would be required to comply with the provisions of the rule. Both the National Association of Dental Plans and various dental carriers maintained that the requirements imposed by this rule were overly burdensome given the size and operation of dental networks, as they differ in scope from that of a major medical plan and the related provider networks. After review, the Department needs to further consider the appropriate regulation for dental insurers based on their differing size and operation. Therefore, the Department is revising the definition of “health benefit plan” to eliminate the inclusion of dental plans.

As described in NADP comments on the prior version, the draft rules would require administrative and technical system changes the resulting costs of which would necessitate dental premium increases without added benefits to the consumer.

This is an incredibly positive development and we appreciate the work of the Government Relations Workgroup (GRW) and Ohio members in developing comments and communicating to the ODI on these critical issues.

Following the submission to the Common Sense Initiative (CSI), CSI will issue their business analysis review of the rule to ODI. The outcome of the review will determine whether additional clarifications are necessary or whether ODI can move forward with the JCARR process.

We will continue to discuss these regulations and OH activities within the GRW and provide updates in the Dental Interact (DI) Government Relations Open Forum.



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