Dental plans are asking the National Association of Insurance Commissioners to think about them when it is helping to set up the new health insurance exchanges.

Kathryn Paul, chair of the Health Care Reform Implementation Task Force at the Delta Dental Plans Association, Oak Brook, Ill., hopes to testify on behalf of the association Friday at a hearing organized by the NAIC’s Exchanges Subgroup.

The NAIC, Kansas City, Mo., organized the subgroup to help with implementation of the health insurance exchange provisions of the Patient Protection and Affordable Care Act (PPACA), a Mouthcomponent of the federal Affordable Care Act package.

One Delta Dental goal is to give individuals and small employers who use the exchange system the freedom to choose whether to buy dental coverage and major medical coverage from the same carrier or from separate carriers.

“The purchase of medical benefits should be separate from the purchase of dental coverage, and forced tie-in sales should not be allowed,” Paul says in a written version of her testimony posted on the Exchanges Subgroup’s section of the NAIC website.

The Law

Republicans are trying to block implementation of PPACA and the rest of the Affordable Care Act. If PPACA takes effect as written, the health insurance exchange provisions will create new entities that will help individuals, families and small groups use new federal income tax subsidies to shop for health coverage.

A state can set up one exchange or several exchanges for its residents, and it also can decide to let residents participate in a multi-state exchange.

The “qualified health plans” sold through the exchanges will have to offer what the U.S. Department of Health and Human Services (HHS) decides is “minimum essential benefits.”

All major medical carriers, inside and outside the exchanges, will have to sell coverage on a guaranteed-issue, mostly community-rated basis, without using health status to decide whether to

issue coverage or set rates.

Individuals who want to meet Affordable Care Act health coverage requirements and avoid paying penalties will have to have a minimum level of pediatric dental coverage for their children, and carriers that sell qualified health plans through the exchanges will have to provide that minimum level of pediatric dental benefits.

Another Affordable Care Act provision will let carriers sell stand-alone dental plans through the exchanges.

“In our mind, stand-alone dental products will be either policies providing coverage for the mandated pediatric benefits that will supplement major medical coverage to ensure that individuals have all of the required benefits of the essential benefit package or coverage, such as adult coverage, which will be made available to individual and to small employers to ensure that individuals are allowed to maintain the family coverage that is presently available in the marketplace,” Paul says in the written version of her testimony.

Dental Vs. Medical

Paul, chief executive officer of Delta Dental of Colorado, Denver, says the Affordable Care Act treats dental coverage differently from major medical insurance because it is different.

Pediatric dental care, in particular, is primarily preventive, the treated conditions rarely are life threatening, and the cost of care is significantly less than the cost of medical care, Paul says.

Because of those differences, Congress chose not to impose the same Affordable Care Act it imposed on major medical insurers on dental insurers, Paul says.

But Congress does want consumers to have an easy time understanding and comparing all products offered through the exchanges, and information about dental benefits should be as transparent as possible, Paul says.

“We believe the NAIC should develop a separate, stand-alone summary of coverage and benefit document for dental benefits once HHS has identified the pediatric benefits that will be part of the essential benefit package,” Paul says. “This separate document will allow individuals to compare the various dental benefit offerings, thus allowing consumers to make an educated choice on what dental coverage best suits their individual needs.”

Plans also should provide separate pricing for dental benefits, including pediatric dental benefits, so that consumers understand the cost of the benefits, Paul says.

Paul says the NAIC also should think carefully about what types of exchange rules that apply to major medical plans should also apply to pediatric dental plans and other dental plans.

Paul says the four major sources of rules are:

  1. Certification requirements for qualified health plans.
  2. Essential health benefits requirements.
  3. New Affordable Care Act insurance reform rules.
  4. Existing Health Insurance Portability and Accountability Act rules.

Some health plan certification requirements, such as those designed to prevent readmissions to the hospital after major surgery, obviously apply only to major medical coverage, Paul says.

“Other certification requirements, such as the requirement to ensure a sufficient choice of providers in a manner consistent with applicable network adequacy provisions, are clearly important consumer protection that should apply to both medical and dental coverage,” Paul says.

Other health insurance exchange coverage from National Underwriter Life & Health: