NADP provided comments
this Monday to CMS, restating our recommendation for Exchange certified
dental plans offering policies off the Exchange, be exempt from
machine—readable requirements. The newly proposed requirements will
allow third party vendors to compare the provider directories of
carriers offering policies on the Federally-facilitated Exchanges.
During the last round of comments, CMS stated that Standalone Dental
Plans (SADP) would need to comply with the requirement regardless of
whether they are offering policies on or off Exchanges; however, NADP
recently met with CCIIO staff and got some positive feedback on the
potential for a change in policy on this point.

This is the second round of comments provided by NADP. In the first edition of comments,
NADP also advocated for delay of the requirements on dental carriers
and concern related to oversight of the directory’s data information.
Additional draft regulations are expected throughout the next several

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