February 28, 2024
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Aten�on: ASC CPL Pre-Proposed Rule Recommenda�on Request for CY 2025
Submited via: Medicare Electronic Applica�on Request Informa�on System
Re: Informa�on to support recommenda�ons for addi�on to the ASC CPL via the Pre-Proposed Rule
Recommenda�on Process for CY 2025
Dear Sir/Madam:
The American Associa�on of Oral and Maxillofacial Surgeons (AAOMS) represents more than 9,000 oral
and maxillofacial surgeons in the United States. We recognize CMS’ overarching commitment to pa�ent
safety but wish to emphasize that evolving technology and treatment modali�es have allowed forincreasingly complex procedures to be performed safely and eﬃciently across a wide range of carese�ngs, including ambulatory surgery centers. We appreciate the opportunity to provide informa�on on
select dental procedures/codes for CMS' evalua�on and considera�on of their poten�al inclusion in theAmbulatory Surgery Center Covered Procedures List (ASC CPL) for CY 2025.
OMSs rou�nely evaluate and safely treat pa�ents with a wide range of complexi�es across various carese�ngs. Therefore, we oﬀer addi�onal services to consider for coverage in the ASC se�ng that may berendered to iden�fy, diagnose and treat oral or dental infec�ons linked to certain acute condi�ons andMedicare-covered therapies.
Among the services that may contribute to the elimina�on of an oral or dental infec�on are a variety ofdental surgical procedures including, but not limited to, surgical interven�ons to facilitate tootherup�on, alveoloplasty or ridge prepara�on, excision of both benign and malignant lesions of so� �ssue
and/or bone, removal of benign nonodontogenic cysts/tumors, surgical incision and drainage ofextraoral so� �ssue and removal of foreign bodies from both hard and so� �ssue. Further, theseprocedures may be appropriate for payment under the ASC payment system, given their ability to besafely furnished in the ASC se�ng.
Therefore, we submit the following CDT©1 codes for CMS’ considera�on regarding poten�al addi�onto the ASC CPL:••

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Coronectomy as described by CDT© code D7251.
Surgical procedures to facilitate tooth eruption as described by CDT© codes D7280 and D7283.

CDT© is a registered trademark of the American Dental Association.

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Alveoloplasty or ridge preparation procedures as described by CDT© codes D7320 and D7321.
Excision of benign soft tissue lesions as described by CDT© codes D7410, D7411 and D7412.
Excision of malignant soft tissue lesions as described by CDT© codes D7413, D7414 and D7415.
Excision of benign intra-osseous lesions as described by CDT© codes D7450 and D7451.
Removal of benign nonodontogenic cysts and tumors as described by CDT© codes D7460 andD7461.
Excision of bone tissue, including exostosis and reduction of osseous tuberosity as describedby CDT© codes D7471 and D7485, respectively.
Surgical incision and drainage of extraoral soft tissue (complicated) as described by CDT© codeD7521.
Surgical removal of foreign body from mucosa, skin, subcutaneous alveolar tissue or themusculoskeletal system as described by CDT© codes D7530 and D7540.

It can be demonstrated 2 that these procedures:••••••••Do not generally result in extensive blood loss.
Do not require major or prolonged invasion of body cavities.
Do not directly involve major blood vessels.
Are generally not emergent or life threatening.
Do not commonly require systemic thrombolytic therapy.
Are not designated as requiring inpatient care.
Are not limited to a CPT unlisted surgical procedure code.
Are not other excluded by current regulation.

In consulta�on with our panel of experts, these services have been iden�ﬁed to commonly require preopera�ve evalua�on and management, pre-opera�ve imaging, administra�on of anesthesia, fullthickness mucoperiosteal ﬂap eleva�on, osteotomy, debridement of surrounding �ssue and suturing ofwound closure.
Permi�ng Medicare payment in the ASC se�ng for certain dental surgical services, speciﬁcally thosethat are inextricably linked and deemed medically necessary for the iden�ﬁca�on, diagnosis andtreatment of oral or dental infec�ons, may contribute to the consistent applica�on of Medicare dental
coverage and payment policies across various care se�ngs.
Addi�onally, ASCs have the poten�al to mi�gate many of the external pressures that currently act asbarriers in access to care. The lack of and/or limited hospital-based OR access is exacerbated by ongoing
medical staﬃng shortages and industry-wide inﬂa�on. Other challenges exist for pa�ents unable toaccess hospital facili�es because of geographic or transporta�on limita�ons. Indeed, industry research
indicates the health care system as a whole beneﬁts when procedures migrate to less costly carese�ngs.

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Covered Surgical Procedures, 42 CFR § 416.166

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Thank you for your considera�on of these comments. Please contact Patricia Serpico, AAOMS Director ofHealth Policy, Quality & Reimbursement, with any ques�ons at 800-822-6637, ext. 4394 or
pserpico@aaoms.org.
Sincerely,

Mark A. Egbert, DDS, FACSAAOMS President

Adam S. Pitts, DDS, MD, FACS
Chair, AAOMS Committee on Healthcare Policy, Coding & Reimbursement3