Testimony and Comments

NADP continuously works to educate legislators and regulators regarding the importance of the dental benefits industry in relation to improving overall oral health. Below are comment letters and clarifications that NADP has sought from legislators and regulators in chronological order. The listing does not accurately reflect NADP’s main concerns, as many issues are not included on this page, such as Health Care Reform, or are dealt with through separate discussions and e-mails.

View: by date | by topic

2018

12/18/18 Senate Letter and House Letter to CMS
7/31/18 NADP Letter to the Kentucky Department for Medicaid Services Regarding changes to the Medicaid Alternative Benefit Plan
7/17/18 Joint Letter to Congress Regarding the Health Insurance Tax and impact to Medicare Advantage beneficiaries
5/21/18 NADP Testimony to Ohio House Insurance Committee opposing proposed non-covered services legislation
4/27/18 NADP Comments to the New Hampshire Insurance Department on a proposed network adequacy regulation
4/5/18 NADP Comments to the Colorado Division of Insurance on a proposed regulation on utilization review and internal claims appeals
4/5/18 NADP Statement on the Opioid Crisis and Role of Dental Plans
4/2/18 NADP Testimony to Rhode Island Senate Committee on Health and Human Services on a bill pertaining to non-covered services
2/2/18 NADP Letter to the Governor of New York regarding his proposed “Windfall Profit Tax” on insurers
1/9/18 NADP Comments to the Connecticut Department of Insurance on proposed network adequacy regulations
1/5/18 NADP Letter to CMS Regarding Proposed 2019 Policy and Technical Changes to the Medicare Advantage Program

2017

11/27/17 NADP Comments to HHS: Response to Proposed Notice of Benefit and Payment Parameters for 2019
11/23/17 NADP Analysis Shows Adults with Medicaid Preventive Dental Benefits Have Lower Medical Costs for Chronic Conditions
10/30/17 Community Statement on Medicare Coverage for Medically Necessary Oral and Dental Health Therapies
10/27/17 NADP Letter to Senators Alexander and Murray Supporting draft legislation to stabilize the individual insurance market
9/25/17 NADP Letter to Senators McConnell and Schumer Regarding healthcare legislation proposed by Senators Graham and Cassidy
8/25/17 NADP Letter to Ways and Means Health Subcommittee Providing feedback for the Medicare Red Tape Relief Project
8/10/17 NADP Letter to Senators Alexander and Murray Regarding policy approaches to stabilize the individual insurance market
7/12/17 NADP Comments to CMS Responding to Request for Information on Improving Healthcare Choice
6/12/17 Joint Letter to Congress Supporting CHIP
4/24/17 NADP Letter to CMS Responding to Medicare Advantage Request for Information
3/27/17 NADP Letter to Maine Joint Standing Committee on Insurance and Financial Services Opposing LD 900 on non-covered services and balance billing
3/9/17 CCIIO Guidance for Marketplace Issuers Regarding Stand-alone Dental Plan Intent to Offer in FFM States
3/7/17 NADP Comments to CMS Regarding Proposed Rule on Market Stabilization
3/6/17 NADP Letters to Administration regarding Tax Policy: HHS; Treasury; OMB
2/14/17 NADP Letters to Department of Labor and Office of Management and Budget Regarding 2016 Proposed Revision of Annual Information Reports
2/3/17 Joint Letter to Maryland Insurance Administration Regarding network access standards
1/31/17 NADP Letter to Administration and Congress Regarding the Affordable Care Act and the possible development of policy alternatives and modifications
1/30/17 Joint Letter to CMS Regarding the Medicare Advantage benchmark cap
1/19/17 NADP Comments to Washington Senate Health Care Committee Supporting SB 5158 regarding Dental Service Organizations

2016

12/13/16 NADP Comments to Department of Labor responding to a proposal to increase reporting requirements under Form 5500
11/14/16 NADP Comments to New York Department of Financial Services: Regarding Proposed Cybersecurity Requirements 23 NYCRR 500
10/14/16 Joint letter to Congress Supporting CHIP
10/6/16 NADP Comments to HHS: Response to Proposed Notice of Benefit and Payment Parameters for 2018
9/6/16 NADP Comments to Department of the Treasury: Supporting Proposed Changes to the Calculation of ACA Premium Tax Credits
7/14/16 NADP Comments to NM Office of Superintendent of Insurance: Requesting exemption from medical credentialing forms
6/29/16 NADP Letter to the Massachusetts Health Connector regarding the Offer of Dental Benefits and Exchange-Certification
6/22/16 NADP Comments to the Texas Sunset Commission: Regarding Dental Support Organizations and the Staff Report on the State Board of Dental Examiners
5/27/16 NADP Comments to Georgia Office of Insurance and Safety Fire Commissioner Regarding implementation of SB 302 on provider directories
5/17/16 U.S. Senators Letter to Department of the Treasury: Requesting the Cost of Stand-alone Dental Benefits be Included in the Calculation of ACA Premium Tax Credits
5/10/16 NADP Comments on U.S. H.R. 3323: Opposing the “DOC Access Act” related to extreme contractual issue
4/22/16 NADP Comments to South Carolina Department of Consumer Affairs: Regarding Discount Medical Plan Organization Proposed Regulation
4/11/16 NADP Comments to Ohio Senate Insurance Committee: Opposing non-covered services legislation HB 95
3/11/16 NADP Comments to California Department of Managed Health Care Regarding a checklist for implementation of SB 137 on provider directories
1/28/16 NADP Comments to Washington Senate Health Care Committee: Opposing SB 6318 regarding Dental Service Organizations
1/17/16 NADP Comments to CMS responding to CMS’ Draft 2017 Letter to Issuers
1/11/16 NADP Comments to Massachusetts Jt Committee on Financial Services: Opposition to MA HB 951

2015

12/21/15 NADP Comments to HHS: Response to Proposed Notice of Benefit and Payment Parameters for 2017
11/24/15 NADP Letter to WA Office of the Insurance Commissioner: Regarding draft rules on adjusting rate and form filing procedures and implementation of SB 5023
11/16/15 CMS Letter to NADP: Correction to the Dental Icon via Static Verbiage on Healthcare.gov
11/9/15 NADP Comments to the CA Department of Insurance: Responding to Proposed Provider Network Regulations
11/9/15 NADP Comments to HHS: Regarding Nondiscrimination in Health Programs and Activities Proposed Rule
10/22/15 NADP DDPA AHIP Letter to CCIIO: Urging Correction of the Dental Icon on the FFMs
10/13/15 NADP Comments to CCIIO: Regarding Proposed Transparency in Coverage Requirements
9/30/15 NADP Comments to CCIIO: Regarding Proposed Essential Health Benefit Benchmarks for Plan Year 2017
8/4/15 NADP Comments to CMS: Regarding Essential Community Provider Data Collection To Support PY 2017 QHP Certification
7/27/15 NADP 2nd Comments to CMS: Regarding Submission of Machine-Readable Data (see 5.29.15 for 1st comments)
7/27/15 NADP Comments to the Centers for Medicare & Medicaid Services: Responding to Proposed Rules regarding Medicaid and Children's Health Insurance Program (CHIP) Programs
7/24/15 NADP Comments to CMS regarding the Health Plan Identifier
7/21/15 NADP Comments to the U.S. Department of Labor: Requesting exemption of dental plans within the proposed Fiduciary Rule
6/29/15 NADP Comments to CMS: Advocating Dental Transparency Within New Consumer OOP Calculator
5/29/15 NADP Comments to CMS: Regarding Submission of Machine-Readable Provider Network Data
5/18/15 NADP Press Release: New analysis and Infographic shows choice of dental policies key to protect kid’s dental costs
5/18/15 NADP Comments to OH Department of Insurance: Responding to Draft Rules regarding Provider Network Disclosures
5/15/15 NADP Letter to Massachusetts Exchange: Regarding Carrier Request for Responses and Quality Improvement Strategy
5/15/15 NADP Comments to IRS: Regarding Excise Tax on High Cost Employer-Sponsored Health Coverage
5/14/15 NADP Press Release Urging Limit on TX Dental Board’s Rulemaking on Dental Support Organizations and Patient Access
4/8/15 NADP Comments to TX Senate Health & Human Services Committee: Supporting SB 960 regarding dental office support services
4/8/15 NADP Comments to TX House Committee on Public Health: Supporting HB 2330 regarding dental office support services
4/3/15 NADP Comments to OH House Health and Aging Committee: Opposing non-covered services legislation HB 95
3/17/15 NADP Comments to Maryland Education, Health and Environmental Affairs Committee: Supporting SB 887 regarding dental office support services
3/17/15 NADP Joins Dental Coalition Letter supporting CHIP
3/2/15 NADP Comments to HHS / IRS / DOL: Response to Summary of Benefits and Coverage (SBC) Proposed Rule
2/9/15 NADP Comments to Nebraska Banking, Commerce and Insurance Committee: Opposing LB 553 regarding non-covered services and proposing an amendment
2/3/15 NADP Comments to Washington House Health Care & Wellness Committee: Supporting HB 1514 regarding dental office support services
1/12/15 NADP Comments to CMS: Response to CCIIO 2016 Draft Letter to Issuers in the Federally-Facilitated Marketplaces

2014

12/23/14 NADP Comments to HHS: Response to Benefit and Payment Parameters for 2016 Proposed Rule
12/12/14 NADP Letter to Washington Exchange (WAHBE): The Offering of Family Dental Benefits
10/27/14 NADP Letter to Minnesota Insurance Division Regarding Dental Plan Certification
10/27/14 NADP Comments to Iowa Insurance Division Regarding HB 2463 and Discussion of Dental External Appeals
10/16/14 NADP Press Release Announcing Opposition to Texas Rules Limiting Access for Dental Patients
9/29/14 NADP Comments to TX State Board of Dental Examiners Opposing Proposed Amendments to Texas Code re Management of a Dental Practice
9/12/14 NADP Comments to TX State Board of Dental Examiners Opposing Proposed Amendments to Texas Code re Management of a Dental Practice
9/4/14 NADP Update: State Interpretations of Reasonable Assurance
8/26/14 Joint Stakeholder Letter to HHS: Regarding Direct Access to Dental on Exchanges
8/6/14 NADP Comments to Texas State Board of Dental Examiners Responding to Draft Amendments of Texas Code re Management of a Dental Practice
7/31/14 NADP Update: Selection of Qualified Dental Plans in 2014 Marketplaces
7/28/14 NADP Comments to CMS: Clarifications sought on Exchange renewals related to dental plans
7/17/14 NADP Comments to CMS: CCIIO’s Renewal Notices Impact on Dental Plans
6/9/14 NADP Comments to California State Assembly: Regarding AB 1962 Amendments
6/3/14 NADP Update: State Interpretations of Reasonable Assurance
6/2/14 NADP Comments to Maryland Department of Health and Mental Hygiene Responding to Proposed Regulations regarding Management of a Dental Practice
5/28/14 NADP Letter to Maryland Exchange (MHBE) Recommending MD Utilize a Legal Source Code
5/5/14 Joint Stakeholder Letter to IRS: Calculation of ACA Premium Tax Credits
5/5/14 NADP PDF Map and Interactive Map: Impact of Missing Premium Assistance for Pediatric Dental Benefits in 2014
4/25/14 NADP Letter to Connecticut Exchange (AHCT): Requesting Medical Plan Designs without Dental
4/21/14 NADP Comments to HHS: Response to Proposed Exchange and Insurance Market Standards
4/18/14 NADP Comments to Idaho Department of Insurance: Response to Draft Bulletin on Dental Coverage and Reasonable Assurance
4/17/14 NADP Letter to Connecticut Department of Insurance: Regarding the Approval of Dental and Medical Plan Filings
4/14/14 NADP Memo to Connecticut Exchange (AHCT): Information on Proposed Dental Plan Design
4/7/14 NADP Comments to Washington D.C. Exchange: The Offering of QHP & Dental Policies
3/31/14 NADP Comments and Milliman Memo to California State Assembly: Opposition to AB 1962
3/28/14 NADP Letter to Mississippi Insurance Department: Regarding the Offer of Dental Plans through the SHOP
3/26/14 NADP Comments to Connecticut Exchange: Follow up to 2/26/14 NADP Questions
3/21/14 NADP Letter to New Mexico Superintendent of Insurance: Regarding 2015 Plan Year Form and Rate Filings
2/28/14 NADP Comments to Nevada Division of Insurance - Responding to Issue Brief on Network Adequacy
2/26/14 NADP Questions for Connecticut Exchange: Requesting Insight on Dental Requirement for QHPs & Assessment Fee
2/25/14 NADP Comments to CMS: Response to CCIIO 2015 Letter to Issuers in the FFM
2/24/14 NADP Comments to HHS / IRS: Proposed Rule on Changing HIPAA Excepted Benefit Definition
2/21/14 NADP Comments to Washington Insurance Commissioner Mike Kreidler Responding to Draft of Amendments to WA Code Sections re Network Adequacy
2/20/14 NADP Press release & Fact Sheet: Stand-Alone Dental Enrollment in Marketplaces
2/14/14 Letters from Senators Landrieu, Warner, Begich, Grassley and Congressman Latham: Regarding Proposed changes to the maximum out-of-pocket limit for dental services.
2/3/14 NADP Comments to HHS: Regarding Proposed Rule on 2015 Benefit and Payment Parameters.

2013

6/4/13 NADP Comments to Ohio House Insurance Committee Opposing non-covered services legislation HB 159

2012

12/13/16 NADP Comments to Massachusetts Governor opposing non-covered services legislation HB 4265
12/13/16 NADP Comments to Ohio House Insurance Committee opposing non-covered services legislation HB 497

2011

11/9/11 NADP Comments to Wisconsin Rep. Peterson & Rep. Weininger opposing non-covered services legislation AB 251
7/28/11 NADP Comments to HHS (Reg) responding to HIPAA Privacy Rule Accounting of Disclosures
5/25/11 NADP Comments to Opposing North Carolina Legislators (Leg) opposing HB 698 / SB 655 regarding Dentist Management Arrangements (DPMs). Senators: Bingham, Blake, Forrester, Pate; Representatives: Barnhart, Brown, Burr, Current, Dollar, Earle, Hollo

2010

11/8/10 NADP Comments to Massachusetts Department of Insurance (Reg) - Responding to proposed regulations of MLR reporting by Dental Plans
10/11/10 NADP Comments to California DMHC (Reg) - Responding to proposed regulations of discount health plans
9/13/10 NADP Comments to HHS (Reg) -Responding to HITECH Privacy and Security Rule Modifications
3/18/10 NADP Comments to New Hampshire Insurance Department (Reg) - Request change of potential MLR on ancillary benefits from proposed changes to INS 4100
3/16/10 NADP Comments to Mississippi Governor Barbour - Opposing non-covered services legislation HB 1167
2/23/10 NADP Comments to Iowa Floor Manager Rep Reasoner - Opposing non-covered services legislation HF 2229
2/22/10 NADP Comments to California DMHC - Responding to proposed regulations of discount health plans
2/18/10 NADP Comments to Alaska Senate Labor & Commerce Com - Opposing non-covered services legislation SB 258
2/17/10 NADP Comments to Mississippi Senate Insurance Com - Opposing non-covered services legislation HB1167
2/10/10 NADP Comments to Alaska House Health & Human Services Com - Opposing non-covered services legislation HB 309
2/10/10 NADP Comments to South Dakota Senate Commerce Com - Opposing non-covered services legislation HB 108
2/3/10 NADP Comments to Kansas Senate Financial Institutions & Insurance Com - Opposing non-covered services legislation SB 389
1/20/10 NADP Comments to Washington House Health Care & Wellness Com - Opposing non-covered services legislation HB 2686

Click here for GR comment letters from 2003-2009

Health Insurance Marketplaces

As state policymakers implement Health Care Reform, NADP provides options, recommendations, and background for best practices on how to include dental policies into health Exchanges.

10/6/16 NADP Comments to HHS: Response to Proposed Notice of Benefit and Payment Parameters for 2018
6/29/16 NADP Letter to the Massachusetts Health Connector regarding the Offer of Dental Benefits and Exchange-Certification
1/17/16 NADP Comments to CMS responding to CMS’ Draft 2017 Letter to Issuers
12/21/15 NADP Comments to HHS: Response to Proposed Notice of Benefit and Payment Parameters for 2017
11/16/15 CMS Letter to NADP: Correction to the Dental Icon via Static Verbiage on Healthcare.gov
10/22/15 NADP DDPA AHIP Letter to CCIIO: Urging Correction of the Dental Icon on the FFMs
10/13/15 NADP Comments to CCIIO: Regarding Proposed Transparency in Coverage Requirements
8/4/15 NADP Comments to CMS: Regarding Essential Community Provider Data Collection To Support PY 2017 QHP Certification
6/29/15 NADP Comments to CMS: Advocating Dental Transparency Within New Consumer OOP Calculator
5/15/15 NADP Letter to Massachusetts Exchange: Regarding Carrier Request for Responses and Quality Improvement Strategy
1/12/15 NADP Comments to CMS: Response to CCIIO 2016 Draft Letter to Issuers in the Federally-Facilitated Marketplaces

Affordable Care Act

The Affordable Care Act (ACA) allows for separate dental policies to provide coverage for ‘pediatric oral services’ as part of the Essential Health Benefits Package (EHBP) to be offered in the small group and individual market.

11/9/15 NADP Comments to HHS: Regarding Nondiscrimination in Health Programs and Activities Proposed Rule
5/18/15 NADP Press Release: New analysis and Infographic shows choice of dental policies key to protect kid’s dental costs

Administrative Efficiency

[Text describing the issue]

4/5/18 NADP Comments to the Colorado Division of Insurance on a proposed regulation on utilization review and internal claims appeals
2/14/17 NADP Letters to Department of Labor and Office of Management and Budget Regarding 2016 Proposed Revision of Annual Information Reports

Affordability

NADP values oral health and the role of the dental benefits industry in improving access to affordable, quality dental care. National and state health and tax policy can impact the affordability of benefits for individuals and employers.

5/21/18: NADP Testimony to Ohio House Insurance Committee opposing proposed non-covered services legislation
4/2/18 NADP Testimony to Rhode Island Senate Committee on Health and Human Services on a bill pertaining to non-covered services
2/2/18: NADP Letter to the Governor of New York regarding his proposed “Windfall Profit Tax” on insurers
3/27/17: NADP Letter to Maine Joint Standing Committee on Insurance and Financial Services Opposing LD 900 on non-covered services and balance billing
9/6/16 NADP Comments to Department of the Treasury: Supporting Proposed Changes to the Calculation of ACA Premium Tax Credits
5/17/16: U.S. Senators Letter to Department of the Treasury: Requesting the Cost of Stand-alone Dental Benefits be Included in the Calculation of ACA Premium Tax Credits
4/11/16 NADP Comments to Ohio Senate Insurance Committee: Opposing non-covered services legislation HB 95
1/11/16: NADP Comments to Massachusetts Jt Committee on Financial Services: Opposition to MA HB 951
9/30/15 NADP Comments to CCIIO: Regarding Proposed Essential Health Benefit Benchmarks for Plan Year 2017

Individual and Small Business Coverage

[Text describing issue]

12/13/16 NADP Comments to Department of Labor responding to a proposal to increase reporting requirements under Form 5500
5/15/15 NADP Comments to IRS: Regarding Excise Tax on High Cost Employer-Sponsored Health Coverage

Discount Dental Plans

Discount Dental Plans, also referred to as Provider Access Organizations, Dental Referral Plans and Access Plans, provide consumers an opportunity to pay lower fees for services through a network of participating dentists. Unlike insurance plans, Discount Dental Plans do not assume insurance risk, make payments or reimbursements to members or dentists, issue claims forms, offer free or prepaid services, or use utilizations review protocols.

4.22.16 NADP Comments to South Carolina Department of Consumer Affairs: Regarding Discount Medical Plan Organization Proposed Regulation

HIPAA, Privacy and Cybersecurity

[Text describing the issue]

11/14/16 NADP Comments to New York Department of Financial Services: Regarding Proposed Cybersecurity Requirements 23 NYCRR 500
7/24/15 NADP Comments to CMS regarding the Health Plan Identifier

Dental Provider Networks

Dental provider networks give enrollees access to critical oral health services along with financial incentives to obtain care in the dental plan’s network. NADP actively participates in policy discussions impacting networks including topics such as contracting, network adequacy and provider directories.

4/27/18 NADP Comments to the New Hampshire Insurance Department on a proposed network adequacy regulation
1/9/18 NADP Comments to the Connecticut Department of Insurance on proposed network adequacy regulations
2/3/17 Joint Letter to Maryland Insurance Administration Regarding network access standards
7/14/16 NADP Comments to NM Office of Superintendent of Insurance: Requesting exemption from medical credentialing forms
5/27/16 NADP Comments to Georgia Office of Insurance and Safety Fire Commissioner Regarding implementation of SB 302 on provider directories
5/10/16 NADP Comments on U.S. H.R. 3323: Opposing the “DOC Access Act” related to extreme contractual issue
3/11/16 NADP Comments to California Department of Managed Health Care Regarding a checklist for implementation of SB 137 on provider directories
11/9/15 NADP Comments to the CA Department of Insurance: Responding to Proposed Provider Network Regulations
7/27/15 NADP 2nd Comments to CMS: Regarding Submission of Machine-Readable Data (see 5.29.15 for 1st comments)
5/29/15 NADP Comments to CMS: Regarding Submission of Machine-Readable Provider Network Data

Delivery of Care

[Text describing the issue]

4/5/18 NADP Statement on the Opioid Crisis and Role of Dental Plans
1/19/17 NADP Comments to Washington Senate Health Care Committee Supporting SB 5158 regarding Dental Service Organizations
6/22/16 NADP Comments to the Texas Sunset Commission: Regarding Dental Support Organizations and the Staff Report on the State Board of Dental Examiners
1/28/16: NADP Comments to Washington Senate Health Care Committee: Opposing SB 6318 regarding Dental Service Organizations

Public Programs

Because a substantial number of Americans receive dental services covered by government-funded programs like Medicaid, Medicare, and CHIP, NADP advocates for the stability and continued funding of these and similar initiatives.

7/31/18 NADP Letter to the Kentucky Department for Medicaid Services Regarding changes to the Medicaid Alternative Benefit Plan
1/5/18 NADP Letter to CMS Regarding Proposed 2019 Policy and Technical Changes to the Medicare Advantage Program
11/23/17 NADP Analysis Shows Adults with Medicaid Preventive Dental Benefits Have Lower Medical Costs for Chronic Conditions
10/30/17 Community Statement on Medicare Coverage for Medically Necessary Oral and Dental Health Therapies
8/25/17 NADP Letter to Ways and Means Health Subcommittee Providing feedback for the Medicare Red Tape Relief Project
7/27/15 NADP Comments to the Centers for Medicare & Medicaid Services: Responding to Proposed Rules regarding Medicaid and Children's Health Insurance Program (CHIP) Programs
6/12/17 Joint Letter to Congress Supporting CHIP
4/24/17 NADP Letter to CMS Responding to Medicare Advantage Request for Information
1/30/17 Joint Letter to CMS Regarding the Medicare Advantage benchmark cap
10/14/16 Joint letter to Congress Supporting CHIP