February 6, 2024
Centers for Medicare & Medicaid Services
Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development
Attention: Document Identifier CMS-10883
7500 Security Boulevard
Room C4-26-05
Baltimore, MD 21244-1850
Submitted online via www.regulations.gov
Re: Document Identifier CMS-10883 American Dental Association (ADA) Dental Claim Form
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. As AAOMS continues to actively engage in theevolving landscape of healthcare policy and administration, we are pleased to offer our insights andrecommendations regarding CMS' progression towards accepting the American Dental Association(ADA) dental claim form.
Oral and maxillofacial surgeons are highly skilled healthcare professionals with expertise in diagnosing
and treating a wide array of dental and medical conditions, injuries and deformities affecting the head,neck, face, jaws and the associated oral and facial tissues. Their scope of practice covers diverse
procedures, including the removal of wisdom teeth, correction of jaw misalignment and the treatmentof jaw and mouth tumors and cysts.
Given the extensive and varied expertise of OMSs in handling a wide spectrum of procedures, it isessential to consider the most effective means of reporting these services to Medicare. AAOMS supports
CMS’ intent to accept the ADA dental claim form for Medicare covered dental services, althoughcautions CMS against the exclusive use of the ADA dental claim form in the context of dental service
claims.
This is based not only on the familiarity and proficiency that OMSs have developed with the CMS-1500
form, and its electronic equivalent, but also on the clinical reality that many scenarios meeting
Medicare’s coverage criteria may involve procedures that are both dental and medical in nature.
Therefore, a reporting method that adequately reflects the dual characteristics of these services is
crucial for accurate and appropriate billing and payment. As such, AAOMS encourages CMS not torequire the use of the ADA claim form exclusively for the submission of dental services/Current Dental
Terminology (CDT)©1 codes to Medicare.
Request for confirmation on continued use of the medical claim form by OMSs
Numerous practice management software systems used in oral and maxillofacial surgery are designed tofacilitate the generation and submission of both dental and medical claims, reflecting the field's broad
and multifaceted scope of practice. This functionality is important, given the frequent necessity in oral
and maxillofacial surgery to address both dental and medical aspects of patient care.
Should CMS proceed with the implementation of the dental claim form, it could create potential
uncertainty for dental providers, especially oral and maxillofacial surgeons in determining the mostsuitable claim form for submissions that involve both Current Procedural Terminology (CPT)©2 codes andCDT© codes.
Therefore, in the interest of maintaining a streamlined, efficient and uniform process for OMSs
nationwide, we seek explicit confirmation from CMS. We wish to ensure that oral and maxillofacial
surgeons will retain the ability to submit claims for both dental and medical services for Medicare
beneficiaries using the CMS-1500, regardless of whether CMS implements acceptance of the ADA
dental claim form.
Integration of referring provider information on dental service claims
Some Medicare Administrative Contractors (MACs) advise including the treating medical physician’sname and NPI as the referring provider on medical claims for Medicare-covered dental services. AAOMS
acknowledges inclusion of this information may help facilitate the adjudication process for dental
service claims and aid MACs in determining Medicare coverage eligibility.
However, we note that the ADA dental claim form does not have a designated field for referring
provider information. Given the importance of demonstrating care coordination between dental andmedical providers, especially in establishing “inextricable linkage,” this could impact dental providers’ability to comply with Medicare program requirements or adhere to the guidance issued by the MACs.
While we acknowledge that the 837D electronic standard may offer the functionality to integratereferring provider information, the application of this feature and its requirements can vary significantly
across different dental carriers, software systems and third-party claims administrators.
Given this variability, and the lack of a dedicated field for such information in the claim form itself,AAOMS encourages CMS to consider the development and provision of guidance for dental providers
when billing Medicare-covered dental services, specifically, how dentists might include referring
provider information on both paper and electronic dental service claims.
For example, CMS may instruct providers to use Box 35 (Remarks) on the ADA form or provide
alternative methods CMS may deem appropriate. We believe that clear and consistent instructions
across both the CMS-1500 and ADA claim forms are imperative. Such guidance would not only assist in12CDT© is a registered trademark of the American Dental Association.
CPT© is a registered trademark of the American Medical Association.

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maintaining high standards of coordinated care but also ensure adherence to claim submission
requirements.
Consideration of modifier usage on dental service claims
CMS has emphasized the use of Healthcare Common Procedure Coding System (HCPCS) modifiers as
crucial for indicating Medicare coverage eligibility for dental services. However, a significant distinction
arises with the ADA dental claim form, which, unlike the CMS-1500 form, does not support modifier use.
This difference is essential for dental providers preparing to submit claims to Medicare using the ADA
dental claim form, particularly in scenarios where claims are submitted to obtain a denial to facilitate
third-party payer adjudication.
The variance in modifier support between the medical and dental claim forms poses a unique challenge
for dental providers. CMS' requirement for HCPCS modifiers to indicate dental services not covered by
Medicare cannot be met by the current version of the ADA dental claim form, complicating claim
management for dental providers.
This situation underscores the need for CMS to consider the structural differences of the ADA form
when developing and issuing guidance to dental providers. It is imperative for CMS to collaborate withprofessional associations, dental providers and relevant stakeholders to find practical solutions andprovide clear, detailed guidance on the submission of dental service claims that require or would
benefit from inclusion of HCPCS modifier(s).
This could include accommodating the unique aspects of the dental claim form and providing strategies
to ensure dental providers are able to communicate service details accurately and effectively to theirlocal Medicare carriers.
Consideration of ICD-10-CM code capacity on the dental claim form
While ICD-10-CM codes are not universally mandated for dental carriers in claims adjudication, theirutilization is significant in certain contexts. Specifically, diagnosis codes are pivotal in capturing thenuances of a patient encounter and substantiating medical necessity.
The expansion of Medicare dental benefits, with a focus on dental services integral to the success ofcertain covered medical procedures, amplifies the importance of diagnosis code reporting. ICD-10-CM
codes serve as key indicators for the MACs to assess medical necessity and, consequently, coverage fordental services. Several of the MACs have issued recommendations on diagnosis codes to streamline
dental claims processing, including the reporting of appropriate codes to describe the dental condition
being treated, linked medical condition and relevant Z-codes for additional clinical context. This
indicates the complexity of dental encounters, especially in cases linked to Medicare-covered medicaltreatments.
We note the ADA claim form allows for the reporting of only four ICD-10-CM codes, in contrast to the 12ICD-10-CM codes accommodated on the CMS-1500 form. AAOMS believes this should be aconsideration for CMS in developing guidance for dental providers who will eventually use the ADA
claim form for billing Medicare-covered dental services. We encourage CMS to engage in collaboration
with professional associations and dental providers with expertise in dual reporting to both medicaland dental carriers to address the reporting of diagnosis codes.

3Such collaboration can play a pivotal role in developing and issuing guidance that addresses the uniqueaspects of reporting linked dental services effectively.
Provider specialty classification for oral and maxillofacial surgeons
Oral and maxillofacial surgeons have the flexibility to enroll in the Medicare program under either CMS
provider category “19 – Oral Surgery (Dentist only)” or “85 – Maxillofacial Surgery,” provided theindividual practitioner satisfies CMS’ criteria. This enrollment flexibility is a direct result of AAOMS’collaboration with CMS nearly two decades ago. At that time, AAOMS advocated — and CMS ultimately
agreed —that specialty category “19,” while generally encompassing all dental specialties andcorresponding to dental Taxonomy Code 1223S0112X, did not adequately capture the range of services
provided by OMSs. In contrast, specialty category “85,” which may be crosswalked to Taxonomy Code
204E00000X under the Allopathic and Osteopathic Physicians, aligns more closely with the scope andcomplexity of OMS practice.
In their letter dated April 13, 2007, CMS announced a change to Medicare enrollment materials,
enabling board-certified OMSs to enroll in the Maxillofacial Surgery specialty category “85”. This change,
which has since been implemented, allows OMSs of various degrees – whether Doctor of Medicine,Doctor of Dental Surgery, or Doctor of Dental Medicine – to be recognized under this specialty due tothe similarity in their procedural scope. Additionally, CMS not only planned but also implemented new
instructions for Medicare contractors, which directed the incorporation of three additional criteria forenrolling physicians in specialty category “85”: board certification through the American Board of Oraland Maxillofacial Surgeons, malpractice coverage through the OMS National Insurance Company, orpossession of a current state specialty license in oral and maxillofacial surgery.
Given this context, we wish to draw CMS’s attention to the importance of not restricting payment forcovered dental services solely to those dental providers enrolled under CMS category “19.” Such alimitation could inadvertently overlook the specialized care, including the provision of Medicarecovered dental services, furnished by OMSs enrolled under category “85.”Thank you for your consideration of these comments. Please contact Patricia Serpico, AAOMS Directorof Health Policy, Quality & Reimbursement, with any questions 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 & Reimbursement4