The Children's Dental Health Project, Washington, wants all health plans and all dental plans to use the same form to describe the dental benefits they do or do not offer.
The Dental Dental Plans Association, Oak Brook, Ill., wants regulators to make it clear that new rules governing a new Summary of Benefits and Coverage (SBC) apply only to major medical coverage, not to "excepted benefits" such as dental coverage.
The National Association of Dental Plans (NADP), Dallas, does not say which plans should have to abide by the SBC rules but seems to assume the rules will apply only to dental plans sold through the new government health insurance exchanges.
Representatives from those groups talk about SBC dental plan issues in comments on SBC requirements the U.S. Department of Health and Human Services (HHS) has been developing with the Employee Benefits Security Administration (EBSA), an arm of the U.S. Labor Department.
EBSA recently posted 322 comments on the proposed SBC regulations on its website.
The proposed regulatios would implement Section 2715 of the Patient Protection and Affordable Care Act of 2010 (PPACA), which calls for the government to create a standardized health plan description document, to help consumers do a better job of shopping for coverage, by March 2012.
PPACA also is supposed to set up a system of health insurance exchanges that will distribute subsidized health coverage to individuals and small businesses starting in 2014.
Most of the commenters focus on issues relating to major medical coverage, and general issues, such as a request that the government push back the effective data of the SBC rules at least a year past March 2012. But Catherine Dunham of the Children's Dental Health Project, Evelyn Ireland of NADP, and Kim Volk of Delta Dental focus on dental issues.
Dunham acknowledges in her comment that much of the general SBC form would be irrelevant to stand-alone dental insurers.
"However, due to the structure of typical dental coverage and the potentially significant out-of-pocket benefit and expensive limits, the SBC should inform consumers of these attributes as they make decisions about coverage options," Dunham says.
Requiring all plans to use the same form would help meet that goal, Dunham says.
Ireland suggests that dental plans should use a grid-based form, with each plan to be compared having its own column. Each plan feature, ranging from the plan phone number, to the annual deductible, to a description of any orthodontia benefits, would get its own row.
The grids, and the exchange consumer interfaces, "should be designed in a way that offers consumers the opportunity to seek progressively more in‐depth information," Ireland says. "For example, the grid may have information listed that is linked to a more extensive explanation of the benefit."
Some carriers might put procedures such as root canals in different categories than other carriers do, Ireland adds.
"Carriers may place procedures in different categories," Ireland says. "For instance, root canals are classed as basic by some carriers and major by others. This gives the consumer the opportunity to tailor their information load based on their own interest and needs."
Customers may be especially interested in a tool that helps them identify whether their dentist is in a plan's network, Ireland adds.
At Delta Dental, Volk wants exchanges to develop SBC requirements that would apply only to the pediatric dental benefits that are required by law to be sold alongside exchange major medical coverage.
"We recommend that the agencies add at the end of the requirement a new subsection with respect to 'scope and applicability' expressly providing that these requirements do not apply to 'excepted benefits,'" such as dental, Volk says.