ADA weighs in on CMS' proposed dental payment rules

The American Dental Association formally submitted comments to CMS on the proposed physician fee schedule for 2025.

Here are six notes on the organization's comments to CMS proposals, according to a Sept. 12 news release:

  • The organization supports the CMS proposal to cover payment for dental services for individuals who are undergoing dialysis.
  • Responding to CMS' request for feedback on providing dental care to individuals with diabetes, the ADA found no evidence that dental services are directly linked to clinical success of a Medicare-covered procedure in the treatment of diabetes. 
  • The ADA requested clarification on whether a dental claim must be submitted with administrative modifiers to coordinate with a state's Medicaid program, even when the Medicaid provider knows a dually eligible patient will be ineligible for dental benefits under the medically necessary payment rules. 
  • The ADA requested that administrative claim modifiers KX and GY be waived until Jan. 1, 2026 to allow for more sufficient testing. 
  • The ADA suggested that CMS consider delaying the requirement for ICD-10 codes in dental Medicare claims until Jan. 1, 2026, to ease the transition to ICD-10 codes for the dental community. 
  • The organization also offered to share market data with CMS to help with fee guidance for dental services. 

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