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The New Health Insurance Exchanges Need a Dental Check-Up

Nov 29, 2011

By Evelyn Ireland
Executive Director, National Association of Dental Plans (NADP)

As Washington continues to implement insurance provisions in the Affordable Care Act (ACA), tens of millions of American families and small businesses are intently watching to see if regulators will provide equitable access to dental coverage inside and outside the new state Health Exchanges.

The practical and political stakes couldn’t be higher; 43.7 million employees and dependents through 1.65 million small businesses have “stand-alone” dental health policies that are now vulnerable to disruption when the Exchanges become effective in 2014.

In order to deliver on the often touted promise made by President Obama that Americans can keep their current coverage and doctors, regulatory clarity is desperately needed to protect consumer access to the dental plans they enjoy. Today 97% of all dental policies are separate from medical coverage.

Specifically, the U.S. Health and Human Services Department (HHS) must clarify that the dental policies consumers now have will be accepted to meet the Essential Health Benefit requirements for children by the Exchanges and in the small group and individual market outside the Exchanges. They also need to make clear that health insurance plans can offer medical coverage without dental both inside and outside the Exchanges.

Without these important clarifications, there will be a massive and unnecessary disruption in the dental benefits marketplace for both consumers and dentists. In 2014 medical plans are mandated to add children’s dental services to policies sold in the small group and individual market. This will duplicate coverage these consumers already have.

If HHS doesn’t act soon, 22.9 million children, that have coverage under their parent’s existing dental policies through small employers, will be required to obtain their dental coverage through a medical carrier, who may or may not provide access to the family’s current dentist. The National Association of Dental Plans estimates about half of their parents—11 million Americans--may drop dental coverage when their children are removed from their dental polices.

Any degradation of dental coverage will likely have a negative impact on overall health, as there is a strong linkage between oral health and medical conditions like diabetes and cardiovascular diseases. This is unacceptable; the health of Americans should not be compromised because ACA contains unclear statutory language.

Therefore, the dental benefits industry has provided regulators with a thoroughly researched policy paper that provides a roadmap for offering stand-alone dental policies inside and outside the Exchanges. The commonsense policy recommendations seek to ensure that consumers can continue to choose from a wide variety of affordable policies in terms of price, benefits, services and quality.

Our children certainly should not be made to suffer because of bureaucratic uncertainty that can be easily remedied. The bottom line is HHS has the authority to issue updated Exchange rules to ensure fair competition between all health and dental plans for pediatric benefits. Americans should expect that regulators will meet this responsibility, avoid causing a confusing and painful disruption of dental benefits service and fill the gaps in the ACA’s statutory language in a timely manner.
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