May 6, 2021
The Honorable Nancy Pelosi
Speaker
U.S. House of Representatives
H-222
U.S. Capitol
Washington, D.C. 20515

The Honorable Charles Schumer
Majority Leader
U.S. Senate
S-221
U.S. Capitol
Washington, D.C. 20510

The Honorable Kevin McCarthy
Minority Leader
U.S. House of Representatives
H-329
U.S. Capitol
Washington, D.C. 20515

The Honorable Mitch McConnell
Minority Leader
U.S. Senate
S- 230U.S. Capitol
Washington, D.C. 20510

Dear Speaker Pelosi, Majority Leader Schumer as well as Minority Leaders McConnell and McCarthy:
The American Association of Oral and Maxillofacial Surgeons (AAOMS) represents more than 9,000 oral andmaxillofacial surgeons (OMSs) in the United States. We would like to express deep concern withcongressional efforts, such as the Medicare Dental Benefit Act of 2021 (HR 502/S 97), to expand coverage forcertain dental items and services under part B of the Medicare program.
Oral and maxillofacial surgery is the surgical specialty of dentistry and one of the few dental specialties
whose members perform Medicare-covered procedures that range from the removal of cancerous tumors in
the mouth/jaw area and the extraction of infected teeth to prepare a patient’s jaw for radiation cancer
treatment to repairing tissue or bones in the facial area following trauma. As such, our members haveextensive experience with the Medicare program.
As dentists, we understand the important role oral health can have on a patient’s overall health, and we
support efforts to ensure all Americans have access to affordable, high-quality dental care. We further
recognize that many low-income seniors have difficulty affording dental care given the limited dental
procedures covered by Medicare. Medicare dental coverage is currently limited to a few procedures involving
certain medically compromised patients. For example, Medicare will cover an oral exam for a patient prior toundergoing a Medicare-covered kidney transplant – but not any dental treatment needed to ensure thesuccess of the transplant. 1

1 Medicare Benefit Policy Manual. Chapter 15, Section 150. CMS.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c15.pdf. Accessed May 4, 2021.

While we appreciate the intent of proposals such as the Medicare Dental Benefit Act, it is important toconsider who is lacking access to dental care and whether an expansion of dental services through theMedicare Part B program is the best solution. Many seniors obtain dental care either through dental
coverage offered by their Medicare Advantage (MA) plans or by paying out-of-pocket. The percentage ofMedicare beneficiaries with an MA plan is rising annually, and 68 percent of MA plans now offer some formof dental benefits. 2 MA plans also provide coverage to a significant number of lower-income seniors. 3 Forseniors who utilize a MA advantage plan for their dental benefits, there is no need to take away this caredelivery option.
On the other hand, low-income seniors may not be able to afford to pay extra for supplemental dental
benefits through a MA plan or pay out-of-pocket for their dental treatment. For these seniors, state Medicaid
programs should be considered. Most states already offer adult dental Medicaid services. Expanding those
programs to include low-income seniors – even if partially funded by the federal government – would be amore efficient way to expand coverage to this population than the creation of a new federal program.
In addition, the current benefit provided by the Medicare Dental Benefit Act covers only 80 percent of apatient’s cost for preventative and basic treatments and caps the patient’s costs at 50 percent for major
treatments. This is below the private insurer industry standard of 100 percent of preventative and 50 percent
of major treatment costs, respectively. 4 In sum, while middle- and higher-income seniors may benefit fromthe potential of legislative proposals such as HR 502/S 97 to reduce costs, low-income seniors may not beable to afford preventative and basic treatment care due to the bill’s cost-sharing obligations.
AAOMS also has concerns about the reimbursement process. Any legislative proposal to expand dental
benefits under Medicare Part B would subject dental and oral services defined in the bill to the Medicare
physician fee system, which was designed for the medical coding system and not the dental coding system.
Requirements such as diagnosis coding, global service periods and multiple procedure discounts are just a
few of the Medicare payment policies we are concerned about because they do not currently align with thedental coding system. As a result, dental services may end up significantly undervalued after going throughthe Medicare physician fee setting process. Furthermore, the vast majority of dentists are unfamiliar with theadministrative requirements associated with being a Medicare Part B provider. If reimbursement is not highenough to incentivize dentist participation and the provider administrative requirements are too onerous,
many dental providers will forgo participation in the program and low-income seniors will remain without
access to quality dental care. Finally, additional significant costs associated with providing dental coverage
under Part B could trigger neutrality cuts for currently covered medical procedures that will impact all
Medicare providers.
AAOMS agrees with Congress that some low-income seniors lack access to affordable dental care and, as aresult, are forgoing care that can have significant positive implications on their overall health. However, wedisagree that a dental benefits expansion under Medicare Part B is the best solution to this problem andask Congress to consider the following alternative approaches: 1) Mandate CMS expand the circumstancesin which Medicare Part B will cover dental procedures related to a Medicare-covered medical procedure; 2)provide additional federal funding to allow states to provide consistent Medicaid dental coverage for low-

2 A Dozen Facts About Medicare Advantage in 2021. Henry J. Kaiser Family Foundation. https://www.kff.org/medicare/issue-brief/medicare-advantage-2021-spotlight-first-look, October 2020. Accessed May 4, 2021.
3 Social Risk Factors Are High Among Low-Income Medicare Beneficiaries Enrolled in Medicare Advantage.
https://bettermedicarealliance.org/wp-content/uploads/2020/09/BMA-Q3-Data-Brief-FIN.pdf. September 2020. Accessed May4, 2021.
4 Dental Benefits Basics: What do dental plans normally cover? National Association of Dental
Plans. NADP.org/Dental_Benefits_Basics/Dental_BB_2.aspx. Accessed May 4, 2021.

income seniors; 3) incentivize more MA plans to offer dental benefits to their enrollees; and 4) explore aMedicare dental benefit outside Part B.
We would be pleased to work with you and your colleagues further on this important issue. Please contact
Jeanne Tuerk, AAOMS manager of government affairs, at 800-822-6637, ext. 4321, or jtuerk@aaoms.org.
Sincerely,B.D. Tiner, DDS, MD, FACSAAOMS President