February 28, 2024
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Aten�on: Recommenda�on on Dental Codes for Assignment to Clinical APCs for CY 2025
Submited via: outpa�entpps@cms.hhs.gov
Re: Recommenda�on on Dental Codes for Assignment to Clinical APCs for CY 2025

Dear Sir/Madam:
The American Associa�on of Oral and Maxillofacial Surgeons (AAOMS) represents more than 9,000 oraland maxillofacial surgeons in the United States. We recognize CMS’ overarching commitment to pa�entsafety 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 hospital outpa�ent departments. We appreciate the opportunity to provide
informa�on on select dental procedures/codes for CMS' evalua�on and considera�on for assignment toclinical ambulatory payment classiﬁca�ons (APCs) 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 hospital inpa�ent andoutpa�ent se�ngs that may be rendered to iden�fy, diagnose and treat oral or dental infec�ons linked
to certain acute condi�ons and Medicare-covered therapies. Among the services that may contribute to
the elimina�on of an oral or dental infec�on are a variety of dental surgical procedures including, but notlimited to, surgical interven�ons to facilitate tooth erup�on, alveoloplasty or ridge prepara�on andremoval of lateral exostosis of the jaws. Further, these procedures may be appropriate for payment
under the OPPS, given their ability to be safely furnished in the hospital outpa�ent se�ng.
Therefore, we submit the following CDT©1 codes for CMS’ considera�on regarding poten�alassignment to clinical Ambulatory Payment Classiﬁca�ons (APCs) under the OPPS:•••

Surgical procedures to facilitate tooth eruption as described by CDT© code D7283.
Alveoloplasty or ridge preparation procedures as described by CDT© codes D7320 and D7321.
Removal of lateral exostosis of the jaws as described by CDT© code D7471.

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, full1CDT© is a registered trademark of the American Dental Association.

thickness mucoperiosteal ﬂap eleva�on, osteotomy, debridement of surrounding �ssue and suturing ofwound closure.
In the context of Medicare covered dental services, such as those linked to heart valve replacement orrepair, organ transplant procedures and certain cancer treatments, these dental procedures underscorethe interdependence of oral health and overall systemic health. Ensuring that dental or oral sources ofinfec�on are addressed through dental interven�ons, such as those noted above can be cri�cal in
minimizing the risk of endocardi�s, improving the success rate of transplants and reducing thecomplica�on rates during cancer treatments.
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 orpserpico@aaoms.org.
Sincerely,

Mark A. Egbert, DDS, FACSAAOMS President

Adam S. Pitts, DDS, MD, FACS
Chair, AAOMS Committee on Healthcare Policy, Coding & Reimbursement2