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Dental Associations Urge CMS to Add Codes to ASC-CPL

ASCA supports the effort

BY SAHELY MUKERJI | JULY 2022

For years, ASCA has worked with key dental organizations to add dental surgery procedures to the Centers for Medicare & Medicaid Services’ (CMS) ASC Covered Procedures List (ASC-CPL). These procedures cannot be performed in an ASC because they do not have codes payable under Medicare Part B. This creates a limitation in access to these surgeries for children and adults with special needs and disabilities, resulting in health inequity.

To address the problem, the American Academy of Pediatric Dentistry (AAPD), the American Dental Association (ADA) and the American Association of Oral and Maxillofacial Surgeons (AAOMS) sent a letter to Meena Seshamani, MD, deputy administrator and director of the CMS Center for Medicare, and Daniel Tsai, deputy administrator and director of the CMS Center for Medicaid and CHIP Services, a couple of weeks ago, asking for a meeting.

The letter stated that the “limitations in access have been exacerbated” by the pandemic, primarily affecting high-risk Medicaid and commercially insured patients who require an operating room setting when receiving extensive dental procedures due to their particular medical conditions, according to an ADA press release.

“These critical dental services can be life-changing for children and adults,” says Bill Prentice, chief executive officer of ASCA. “ASCA supports the work these organizations are doing to expand access to this care among these underserved populations, and ASCs stand ready to help.”

The dental groups wrote, “The lack of OR access for needed and covered dental procedures often results in wait times of 6–12 months for these patients, many of whom are children whose daily activities and school performance are often significantly affected in the interim. We attribute most of this access challenge to the lack of a sustainable billing mechanism for hospitals and [ambulatory surgical centers] to report dental surgical services in both Medicare and Medicaid.”

To fix the issue, the groups wrote they believed “the hardship experienced by our patients” could be alleviated by the issuance of a new Healthcare Common Procedure Coding System codes for dental surgical procedures performed under general anesthesia and payment for the new code at a rate that reflects the costs involved, based on Medicare data, according to the ADA release.

The groups also said that “even more significantly, Medicaid programs often either adopt Medicare payment rates or utilize them as a benchmark, and both Medicaid and commercial payers generally utilize Medicare’s [ambulatory surgery centers] list to determine which procedures are eligible for coverage. The lack of appropriate payment and the absence of these procedures on the ambulatory surgery center list, therefore, has a significant ripple effect on OR access for Medicaid patients.”

Other stakeholders, such as the Consortium for Constituents with Disabilities Health Task Force and the American Academy of Pediatrics (AAP), and members of Congress also have asked CMS to address the issue, according to the ADA release. AAP sent its own letter to CMS Administrator Brooks-LaSure at the end of May to emphasize the urgency of the dental access problem and its consequences on health equity.