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Public Statement on Medicare Coverage of
Medically Necessary Oral
and Dental Health Therapies
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July 8,
2022
Beginning
in 2016, a consortium was formed among the undersigned dental and medical
specialists, patient and consumer advocates, and care delivery providers to
support and advocate for Medicare coverage of medically necessary oral and
dental care. Today, the Consortium applauds the Biden Administration and
Congressional champions for taking action that will have a direct and
meaningful impact in the lives of tens of millions of Medicare beneficiaries.
It
is well established that chronic diseases disproportionately impact Medicare
beneficiaries and impose a substantial cost on the federal government. It is
also well established that untreated oral microbial infections are closely
linked to a wide range of costly chronic conditions, including diabetes,
heart disease, dementia, and stroke. In addition, oral diseases have been
documented by researchers and medical specialty societies as precluding,
delaying, and even jeopardizing medical treatments such as organ and stem
cell transplantation, heart valve repair or replacement, cancer
chemotherapies, placement of orthopedic prostheses, and management of
autoimmune diseases.
Despite
these factors, most Medicare beneficiaries have been unable to receive
oral/dental care even when medically necessary for the treatment of
Medicare-covered diseases. Historically, Medicare coverage has extended to
the treatment of all microbial infections except for those relating to the
teeth and periodontium. Believing there is no medical justification for this
exclusion, the Consortium formed to express broad consensus among health care
providers that such care is integral to the medical management of numerous
diseases and medical conditions and that the lack of medically necessary
oral/dental care heightens the risk of costly medical complications,
increasing the financial burden on Medicare, beneficiaries, and taxpayers.
In
recognition of these facts, the Biden Administration has proposed
transformative action to extend Medicare coverage to dental services that are
integral to the delivery of covered medical services. Specifically, the
Physician Fee Schedule for Fiscal Year 2023 issued yesterday by HHS Secretary
Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure proposes to
meaningfully broaden reimbursement for medically necessary dental services.
The proposed rule also opens an exciting opportunity for stakeholders to
provide “comments on other types of clinical scenarios where dental services
may be inextricably linked to, and substantially related and integral to the
clinical success of, other covered medical services” as well as on a process
for public submission of recommendations for identifying the circumstances
when the policy may apply and the payment models that will support it.
“This important announcement marks a new day in the health of Medicare
beneficiaries,” said Dr. Michael Alfano, D.M.D., Ph.D., cofounder of the
Santa Fe Group and the Consortium. “Thanks to the tireless work of literally
hundreds of organizations and thousands of dedicated advocates, Americans will
no longer lack access to medically necessary oral and dental treatment within
the traditional Medicare program.”
Dr.
Cheryl Lee, President of the National Dental Association said, “We support
this policy change as it represents significant progress towards a more
equitable healthcare delivery system. Most importantly, it will expand access
and improve outcomes while also reducing hospitalizations and Medicare
program costs.”
Due
to their conviction that the Medicare program and its beneficiaries should
not be without the vital clinical and fiscal benefits of medically necessary
oral/dental health therapies, more than 230 leading organizations joined as
signatories of the Consortium’s Community Statement to urge Congress and the
Administration to explore options for extending such evidence-based coverage
for all Medicare beneficiaries.
“For
too long Medicare beneficiaries have suffered due to a lack of coverage for
medically necessary dental care crucial to treating other conditions,” said
Center for Medicare Advocacy Executive Director Judith Stein. “Now, thanks to
the determined efforts of this broad group of organizations, and the
recognition of the administration, we look forward to a future of better
health and quality of life, and greater program equity.”
In
light of yesterday’s historic announcement, the Consortium will now turn to
the important process of securing implementation of medically necessary
coverage. Formal comments will be submitted, and community leaders will lend
their expertise as the Administration works to formalize this policy in the
manner best suited to meet the needs of Medicare beneficiaries.
The
signatories of the Consortium’s Community Statement are listed below:
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AARP
ABLE NH (Advocates Building Lasting Equality in NH)
ACA Consumer Advocacy
Acuity Specialists
Adenoid Cystic Carcinoma Research Foundation
AIDS Foundation of Chicago
Alliance for Retired Americans
Allies for Independence
ALS Association
American Academy of Nursing
American Academy of Periodontology
American Association for Community Dental Programs
American Association for Dental, Oral, and Craniofacial Research
American Association of Clinical Endocrinologists
American Association of Colleges of Nursing
American Association of Diabetes Educators
American Association of Hip and Knee Surgeons
American Association of Kidney Patients
American Association of Oral and Maxillofacial Surgeons
American Association of Nurse Practitioners
American Association of Public Health Dentistry
American Association on Health and Disability
American Autoimmune Related Diseases Association
American College of Cardiology
American College of Emergency Physicians
American College of Gastroenterology
American College of Physicians
American College of Rheumatology
American Dental Assistants Association
American Dental Education Association
American Dental Hygienists’ Association
American Diabetes Association
American Geriatrics Society
American Head and Neck Society
American Heart Association
American Institute of Dental Public Health
American Kidney Fund
American Liver Foundation
American Medical Association
American Muslim Health Professionals (AMHP)
American Nephrology Nurses’ Association
American Network of Oral Health Coalitions
American Nurses Association
American Parkinson Disease Association
American Psychiatric Association
American Psychiatric Nurses Association
American Public Health Association
American Society for Radiation Oncology
American Society of Clinical Oncology
American Society of Nephrology
American Society of Transplant Surgeons
American Society of Transplantation
American Thoracic Society
Arcora Foundation
Arizona Oral Health Coalition
Arthritis Foundation
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association of Community Cancer Centers
Association of Oncology Social Work
Association of State and Territorial Dental Directors
Autistic Self Advocacy Network
Be a Hero
Brain Injury Association of America
California Dental Association
California Medical Association
CareQuest Institute for Oral Health
Carlson Foley Enterprises
Catholic Health Association of the United States
Center for Advocacy for the Rights and Interests of the Elderly (CARIE)
Center for Elder Law & Justice
Center for Health Law and Policy Innovation
Center for Medicare Advocacy
Center for Popular Democracy
Champaign County Health Care Consumers
Children’s Dental Health Project
Coalition for Oral Health for the Aging
Coalition of Texans with Disabilities
Colgate Palmolive Company
Colorado Consumer Health Initiative
Community Catalyst
Community Dental Health NPO
Connecticut Oral Health Initiative
Cornerstone Dental Specialties
Crohn’s and Colitis Foundation of America
Culpeper Wellness Foundation
Davis Phinney Foundation for Parkinson's
Delaware Dental Hygienists' Association
Dental Lifeline Network
Dental Trade Alliance
Dentsply Sirona
Dialysis Patient Citizens
Dientes Community Dental Care
Disability Rights Education and Defense Fund
Eating Disorders Coalition
Elderly Housing Development & Operations Corporation
Epilepsy Foundation
EXCELth, Inc.
Families USA
504HealthNet
Florida Health Justice Project
Georgia AIDS Coalition
Georgians for a Healthy Future
Gerontological Advanced Practice Nurses Association
GlaxoSmithKline Consumer Healthcare
GLMA: Health Professionals Advancing LGBTQ Equality
Hartford Institute for Geriatric Nursing
Hawai‘i Oral Health Coalition
Hawaiʻi Children's Action Network Speaks!
Head and Neck Cancer Alliance
Health Care For All (MA)
Health Care Is a Human Right WA
Health Care Voices
Healthy Living and Learning Center
Heartland Alliance
Henry Schein Cares Foundation
HIV Medicine Association
Hispanic Dental Association
International Pemphigus and Pemphigoid Foundation
Island Liaison, Inc.
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John A. Hartford Foundation
Jon C Burr Foundation
Justice in Aging
Kentucky Oral Health Coalition
Klamath Basin Oral Health Coalition
Lakeshore Foundation
Leukemia and Lymphoma Society
Louisiana Primary Care Association
Lupus and Allied Diseases Association, Inc.
Lupus Foundation of America
Maryland Dental Action Coalition
Massachusetts ME/CFS and FM Assoc
Medicaid|Medicare|CHIP Services Dental Association
Medicare Rights Center
Mended Hearts
Mental Health America
Metro New York Health Care for All
Michigan Primary Care Association
Minnesota Dental Therapy Association
myNEXUS
National Alliance of State & Territorial AIDS Directors
National Alliance on Mental Illness
National Association of Area Agencies on Aging
National Association of Chronic Disease Directors
National Association of Community Health Centers
National Association of Dental Plans
National Association of Nutrition and Aging Services Programs
National Association of Social Workers
National Association of States United for Aging and Disabilities
National Coalition of Dentists for Health Equity
National Comprehensive Cancer Network
National Committee to Preserve Social Security and Medicare
National Consumer Voice for Quality Long-Term Care
National Consumers League
National Council for Behavioral Health
National Dental Association
National Forum for Heart Disease and Stroke Prevention
National Hispanic Medical Association
National Health Law Program
National Interprofessional Initiative on Oral Health
National Kidney Foundation
National League for Nursing
National Medical Association
National Multiple Sclerosis Society
National Network for Oral Health Access
National Osteoporosis Foundation
National Rural Health Association
National Stroke Association
North American Transplant Coordinators Organization
Northwest Harvest
Nurses for America
Nursing Interventions for Health System Elders
NYU Rory Meyers College of Nursing
Ohio Alliance for Retired Americans Educational Fund
Oklahoma Policy Institute
Oncology Nursing Society
Oral Cancer Foundation
Oral Health Kansas
Oral Health Nursing Education and Practice Program
Oral Health Ohio
Oral Health Progress and Equity Network (OPEN)
Our Mother's Voice
PA Coalition for Oral Health
Pacific Dental Services Foundation
Parkinson’s Foundation
Patient-Centered Primary Care Collaborative
Pennsylvania Health Access Network
PEW Dental Campaign
Piedmont Regional Dental Clinic
PRC
Preventive Cardiovascular Nurses Association
Pride At Work - WA North, Mt. Kulshan Chapter
Procter & Gamble
ProHEALTH Dental
Project Accessible Oral Health
Puget Sound Advocates for Retirement Action (PSARA)
Renal Healthcare Association
Renal Physicians Association
Research!America
Santa Fe Group
School-Based Health Alliance
Scleroderma Foundation
Senior Charity Care Foundation
Senior Mobile Dental
Sepsis Alliance
Sjögren’s Foundation
Smiles To Go, LLC
Social Security Works
Society for Transplant Social Workers
Statewide Poverty Action Network
Support for People with Oral and Head and Neck Cancer
Texas Oral Health Coalition, Inc
Texas Parent to Parent
The AIDS Institute
The Arc of the United States
The Bingham Program
The CornerStone Community Development Center
The Gerontological Society of America
The Michael J. Fox Foundation
The National Forum of ESRD Networks
The Society for Thoracic Surgeons
The TMJ Association
Third Way
Tri-Area Community Health
Trust for America’s Health
United Health Organization
United Network for Organ Sharing
UUFHCT
Virginia Community Healthcare Association
Virginia Health Catalyst
Virginia Organizing
Virginia Rural Health Association
Washington Healthcare Access Alliance
Wayne County Oral Health Organization
Wesley Living Woodland Homes
West Central Initiative
Western Center on Law and Poverty
Winters Elder Day Council
WomenHeart, The National Coalition for Women with Heart Disease
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The Center for Medicare Advocacy (http://www.medicareadvocacy.org) is a
national, non-profit, law organization that works to advance access to
comprehensive Medicare coverage, health equity, and quality health
care for older people and people with disabilities. Founded in 1986, the
Center focuses on the needs of people with longer-term and chronic
conditions. The organization’s work includes legal assistance, advocacy,
education, analysis, policy initiatives, and litigation of importance to
Medicare beneficiaries nationwide. Our systemic advocacy is based on the
experiences of the real people who contact the Center every day.
Headquartered in Connecticut and Washington, DC, the Center also has
attorneys in CA, MA, and NJ.
Center for Medicare Advocacy, Inc. • www.MedicareAdvocacy.org • PO Box 350,
Willimantic, CT 06226 • 1025 CT Ave. NW, Washington, DC 20036
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