The Kentucky Oral Health Coalition (KOHC) – which is comprised of over 450 members and oral health stakeholders that engage with the Coalition from every region of the Commonwealth. Membership includes dentists, dental hygienists, health professionals, family resource center coordinators, universities, managed care companies, business corporations, government entities, teachers, parents, educators, social workers, public health departments, community health advocates and many others — applauds Centers for Medicare and Medicaid Services (CMS) on the inclusion of “medically necessary” dental coverage in the 2023 Medicare Physician Fee Schedule proposed rule.

We are excited to see recognition of the need for dental coverage for our elder adults and people with disabilities, and this first step being taken to make more meaningful medically necessary coverage a reality. With millions of older adults and people with disabilities unable to afford the dental care they need to stay healthy, adding oral health coverage to Medicare is critical. Moreover, Medicare’s lack of dental coverage exacerbates underlying racial, geographic, and disability-related health and wealth disparities. Improved coverage for medically necessary dental care would mitigate some of these disparities by ensuring that Medicare enrollees who need dental treatment as part of their covered medical care can get the full scope of care they need to get healthy.

We also support CMS’ proposal to clarify and codify the existing examples of “medically necessary” dental coverage and recognizing, as additional specific examples, dental examinations and necessary treatment performed as part of a comprehensive workup prior to organ transplant surgery, cardiac valve replacement or valvuloplasty procedures. We encourage CMS to apply “medically necessary” authority in as broad a range of clinical scenarios as possible.

Kentucky consistently ranks as one of the least healthy states in the country compared with national average rates. In 2016, Kentucky had the highest burden of respiratory issues, cancer, obesity, and heart disease, including the highest rate of new cases of lung and bronchus cancers in the nation. The proposed rule from CMS could ensure “medically necessary” dental care includes a more complete scope of oral health services for people undergoing transplants, cardiovascular care, cancer therapies and other critical medical treatments. Lack of access to medically necessary dental treatment can worsen other health conditions, resulting in increased costs to Medicare for treating illnesses. Poor oral health has been linked to other health conditions, including diabetes, stroke, heart disease, kidney disease, and cancer.

Additionally, we believe that coverage—and thus care–should not be unnecessarily limited by the care setting. Therefore, we agree with CMS’ proposal to implement this Medicare coverage and payment in either an inpatient or outpatient setting as it is clinically appropriate.

Ensuring medically necessary Medicare dental benefits will allow beneficiaries to access the oral health care they need to meet their overall health needs. We strongly support CMS’s inclusion of “medically necessary” Medicare dental coverage in the 2023 Medicare Physician Fee Schedule proposed rule and look forward to continued efforts from CMS to advance health equity.

 

If you would like to submit individual comments on this proposed rule, CMS is accepting public comments through September 6th at 5pm ET.