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.