August 18, 2022

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-4203-NC
P.O. Box 8013
Baltimore, MD 21244-8013
Submitted online via www.regulations.gov

Re: File Code CMS-4203-NC Request for Information on Medicare Advantage
Dear Sir/Madam:

The American Association of Oral and Maxillofacial Surgeons (AAOMS) represents more than 9,000
oral and maxillofacial surgeons (OMSs) in the United States. AAOMS appreciates agency efforts toadvance health equity and improve access to quality oral health care for Medicare-eligible
beneficiaries, particularly through the initiatives aimed to expand the Medicare Advantage
program.
Recent research has found that Medicare Advantage provides approximately $32.5 billion in
additional benefits annually and cost protections not available in Fee-For-Service Medicare 1.
Additionally, the Medicare Advantage program enables oral healthcare providers to participate in
the Medicare program and provide needed care to Medicare populations that would not otherwise
have access to oral healthcare under traditional Medicare Part B. Patients with Medicare
Advantage dental benefits have access to networks of qualified dental providers as well as costsavings from network rates and annual out-of-pocket limits. As such, AAOMS wishes to use thisopportunity to support the continued expansion of comprehensive dental benefits under theMedicare Advantage program.

As dentists and surgeons, AAOMS understands the important role oral health can have on apatient’s overall health, and we support efforts to ensure all Americans have access to affordable,
high-quality dental care. The expansion of dental benefits under Medicare Advantage is one avenue
that offers a more sustainable solution to offsetting oral health disparities and increasing access toquality dental care.
Milliman. Value to the federal government of Medicare Advantage. https://www.milliman.com//media/milliman/pdfs/2021-articles/10-20-21-value-federal-government-of-medicare-advantage.ashx. October
2021. Accessed August 5, 2022.
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The dynamic political environment and evolving health insurance space have brought theinequitable distribution of dental services for Medicare-eligible beneficiaries into sharp focus. In
this regard, Medicare Advantage has played an increasingly prominent role. Of the 28.9 million
Medicare Advantage enrollees 2, 94 percent currently have access to some form of dental coverage,
making Medicare Advantage the primary source of dental benefits for Medicare-eligible
beneficiaries 3.

Market research shows that dental services are amongst the most common and popularsupplemental benefits offered by Medicare Advantage Organizations 4. Plans offering mandatory orembedded supplemental dental benefits experienced a 43 percent uptick in enrollment in between
2018 and 2021 5, while enrollment in plans that mandate both preventative and comprehensive
dental benefits jumped from 37 percent to 71 percent during the same time period5.
These figures indicate not only the increasing importance of dental coverage for the Medicare
consumer but the fact that consumers are more mindful of the benefits they want and need,including coverage for more specialized dental care.

Over 99 percent of beneficiaries enrolled in a Medicare Advantage plan with dental benefits havecoverage for preventative services such as oral exams, prophylaxis and x-rays2. On the other hand,coverage for comprehensive dental benefits, including more specialized services such as
diagnostics, extraction services and periodontics, varies widely depending on the carrier andgeographic location 6. Only 70 percent of Medicare Advantage members enrolled in zero-dollar
premium plans have coverage for diagnostic services, 82 percent have coverage for extractions and62 percent have benefits for nonroutine dental services2. AAOMS acknowledges that the flexibility
with which the Medicare Advantage program may tailor plans to the individual health and financial
needs of their enrollees is integral to maintaining a competitive marketplace and broadening
consumer choice. However, data suggest there is a common and growing need for specialty
dental services across the Medicare-eligible population and AAOMS encourages CMS toconsider further incentivizing Medicare Advantage Organizations to offer a broad range ofservices as part of an embedded comprehensive dental benefit.

Milliman. Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2022 update.
https://www.milliman.com/en/insight/Dental-coverage-in-medicare-advantage-plans-nationwide-marketlandscape-2022-update. August 2022. Accessed August 5, 2022.
3Henry J. Kaiser Family Foundation. Medicare and dental coverage: A closer look.
https://www.kff.org/medicare/issue-brief/medicare-and-dental-coverage-a-closer-look/. July 2021. Accessed
August 5, 2022.
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Milliman. Trends in Medicare Advantage Optional Supplemental Benefits.
https://www.milliman.com/en/insight/trends-in-medicare-advantage-optional-supplemental-benefits. September
2021. Accessed August 5, 2022.
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Milliman. Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2021 update.
https://www.milliman.com/-/media/milliman/pdfs/2021-articles/9-29-21-ma_dental_landscape.ashx. September
2021. Accessed August 5, 2022.
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Henry J. Kaiser Family Foundation. Medicare Advantage in 2021: Premiums, cost sharing, out-of-pocket limits andsupplemental benefits. https://www.kff.org/medicare/issue-brief/medicare-advantage-in-2021-premiums-costsharing-out-of-pocket-limits-and-supplemental-benefits/. June 2021. Accessed August 5, 2022.
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The lack of dental care can negatively impact an individual’s overall health and exacerbate chronic
medical conditions3,7. However, the full scope of oral health care naturally must extend beyond theprovision of preventive dental services. For instance, the extraction of a tooth to eradicate an oral
infection may not necessarily be considered prophylactic in nature; however, such treatment may
help prevent an emergency room visit and the utilization of resource-intensive hospital services.
Non-traumatic dental conditions account for a significant portion of emergency department visits
annually, with risk of hospital admission due to such conditions increasing with age7.

Finally, of important note, the Medicare Advantage program has become increasingly diverse inrecent years, with enrollment among minority and dual eligible individuals growing by 111 percentand 125 percent, respectively, between 2013 and 2019 8. As such, the expansion of embedded
comprehensive dental coverage under Medicare Advantage would provide access to more
specialized dental services to an unprecedented number of individuals, many of whom represent
the most vulnerable of our nation’s population. This would in turn work to further the advancementof health equity, closing the gap in access to high-quality and affordable dental care.

Thank you for your consideration of these comments. Please contact Patricia Serpico, AAOMS
Director of Health Policy, Quality & Reimbursement, with any questions at 800-822-6637, ext. 4394
or pserpico@aaoms.org.
Sincerely,

J. David Johnson Jr., DDSAAOMS President

Agency for Healthcare Research and Quality (AHRQ). Emergency department visits involving dental conditions,2018. https://hcup-us.ahrq.gov/reports/statbriefs/sb280-Dental-ED-Visits-2018.pdf. August 2021.
8Milliman. Comparing the demographics of enrollees in Medicare Advantage and Fee-For-Service Medicare.
https://bettermedicarealliance.org/wp-content/uploads/2020/10/Comparing-the-Demographics-of-Enrollees-inMedicare-Advantage-and-Fee-for-Service-Medicare-202010141.pdf. October 2020.
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