NADP Urges Delay in the Planned Implementation of CDT 2.0
By Mike Adelberg, NADP Executive Director
March 22, 2023
As I settle into my position as the NADP Executive Director, I am pleased that more and more member plans feel comfortable approaching me with their concerns. And, over the last two weeks, I’ve had at least a half dozen conversations about proposed changes to Current Dental Terminology (CDT) Codes, the HIPAA-compliant system for dental claims.
An ambitious proposal, Enhanced CDT (sometimes called CDT 2.0), has been made to significantly change dental codes by adding modifiers to codes for materials and modalities. Comments are currently being accepted on the proposal until the end of March. In this month’s blog, I’m happy to summarize what I am hearing from NADP members about this proposal and offer some thoughts on how to move forward in a positive way.
Before diving into dental plan concerns with the proposal, I want to state that NADP and its members respect the good intentions of those who are championing this proposal. We share a common goal: improving dental claims data so that they can better identify high-quality oral care. NADP and its members are willing partners on this journey.
With that being said, NADP and its members have significant concerns with the proposal to add modifiers to CDT codes in this manner, at this time. Here’s why:
Value of Modifiers Is Undetermined: While collecting information on the modality and materials used in dental procedures adds a new level of granularity to the claim dataset, the ultimate value of this granularity is not yet demonstrated. And the potential value of this added granularity is likely to be undermined by inconsistent dentist use of these modifiers.
Provider Adoption of Modifiers: Training and encouraging the nation’s dentists on these modifiers is a Herculean task; any adoption of modifiers must be coupled with a significant provider adoption strategy. That strategy is not currently evident. Getting dentists and DSOs trained up and supportive of the modifiers is not an add-on task after adoption—it is central to adoption.
System Expenses: Two NADP members offered me informal cost estimates for building modifiers into existing claims processing systems. The estimates range from $5-10M. If we assume that roughly 100 dental plans will have system rebuilds, the total cost of system changes could easily exceed a half-billion dollars. That’s a lot of new ADMINISTRATIVE cost at a time when stakeholders are advocating for Dental Loss Ratios that penalize plans for administrative costs.
Patient/Member Confusion: Establishing modifiers raises a number of unanswered questions with respect to patients/plan members. How will modifiers be reported on Explanation of Benefit statements? These documents are already too complex for some consumers; modifiers tied to modalities and materials will only make EOBs more complex.
De-Emphasis on Diagnoses: NADP and its members support leveraging the good work of SNODENT and using dental diagnostic codes to drive dental practice toward outcome measures and condition-specific benefits. Furthering the adoption of diagnostic codes by building them into CDT 2.0 would be more impactful than establishing novel modifiers. We propose re-upping efforts to spur the adoption of diagnostic codes and worry that new modifiers will dilute the promotion of diagnostic codes.
Natural Language Processing: Rapidly improving Natural Language Processing software can data-mine notes fields on existing claims to locate information on modalities and materials. Dentists, particularly small practices, might prefer adding detail to existing notes fields versus investing in new CDT 2.0-compliant software.
NADP and its members remain willing partners in measuring and improving dental care. But with respect to adopting the CDT 2.0 proposal, a pause is needed. NADP is happy to discuss cost-benefit analyses and collaboratively look at the pros and cons of the proposal. We also look forward to reviewing the feedback from other stakeholders with respect to the Enhanced CDT proposal.
Let’s find a way forward, together.