March 7, 2023
Health Insurance & Long-term Care Issues Committee
National Council of Insurance Legislators
Re: Medical Loss Ratios (MLR) for Dental Health Care Services Plans Model Act
Dear Committee Members:
On behalf of the undersigned members of the Organized Dentistry Coalition, we urge you toadopt the Medical Loss Ratios (MLR) for Dental Health Care Services Plans Model Act (theModel Act). The Model Act, sponsored by Del. Steve Westfall (WV), will be presented to theHealth Insurance & Long-term Care Issues Committee for consideration on March 12 th. MedicalLoss Ratio laws serve to maximize patients’ investments in their health care coverage plans.
Adopting this act will help dental patients receive greater value from their dental insurance
products and therefore, improved access to dental care.
Medical Loss Ratio is a simple measure of the percentage of insurers’ revenue spent on actualcare. Measuring insurers’ investment in care is not a new concept, but in recent years there has
been an increasing concern about insurance products’ lack of transparency and whether they
provide true value for patients. On the major medical side, lawmakers have acted upon thisconcern using MLR data to better ensure health care value for patients. Medical plans in allstates are now required to spend 80-85% of their premium revenue on actual care or refund topatients an amount that would equate to reaching this percentage. Insurers refunded $5.5 billion
in the last three years this policy was in place, according to the Centers for Medicare andMedicaid Services1. Health insurers are being held accountable for the products they market.
Dental insurers are not held to any such similar standard.
Dental insurance was not included in the national MLR reforms in 2010, but dental patientsdeserve the same protections, and clearly want them. In November 2022, Massachusetts votersapproved a standard-setting MLR ballot question by a substantial, bipartisan, 72 percent.
Adopting the Model Act at NCOIL would be one of the first steps to ensure dental patients
across the country enjoy the same protections as found under medical insurance MLR
guidelines. Leading health care thinktanks on both sides of the aisle agree. The Consumer
Choice Center, a right-leaning organization, suggested that adding a requirement for a medicalloss ratio for dental insurers would help promote price transparency and provide incentives toreduce administrative waste. This would help reduce costs for patients.2 Similarly, theProgressive Policy Institute says dental plans should be subject to greater regulation to ensurethat consumers’ and employers’ premium dollars are going toward actual dental care. 3
Adopting the Model Act would serve to promote accountability among dental insurers. We urge
NCOIL to take the lead in promoting the same accountability that has existed for over a decadefor health plans and adopt the Model Act. On behalf of our members and their patients, wethank you for your consideration. Please contact Chad Olson at 312-440-3520/olsonc@ada.org
with any questions.

1 Medical Loss Ratio Data and System Resources
2 Dental Insurance Reform 2021 Policy Note
3 Dental insurance: Plans without protections

Sincerely,
American Dental Association
Academy of General Dentists
American Association of Oral and Maxillofacial Surgeons
American Academy of Periodontology
American Academy of Pediatric Dentistry
American Academy of Endodontists
American Association of Oral and Maxillofacial Pathology
American College of Prosthodontists
American College of Orthodontists