On behalf of the National Dental Association (NDA), representing dentists and the patients we serve across the United States, the NDA has written to CMS Administrator Mehmet Oz, M.D., M.B.A. to strongly oppose the proposed reinstatement of the prohibition on non-pediatric (adult) dental services as an Essential Health Benefit (EHB) under the Notice of Benefit and Payment Parameters for 2027.
This policy reversal would disproportionately harm underserved communities, veterans, low-income populations, rural families, seniors, working adults, and individuals with chronic health conditions. Oral health is not elective. It is essential.
We cannot Make America Healthy Again while carving oral health out of essential health.
Adult Dental Coverage Is a Health Equity Imperative
The NDA's opposition is grounded in evidence and lived reality. Our members practice in communities where untreated dental disease leads to devastating consequences across every dimension of health and wellbeing.
Infection, dental pain, and preventable emergency department visits
Lost wages, sick days, and reduced employment stability
Exacerbation of diabetes, cardiovascular disease, and pregnancy complications
Higher morbidity and mortality rates in underserved communities
Recidivism from substance abuse recovery programs
When adult dental coverage is excluded from EHB protections, working adults — particularly those in underserved communities — are forced to delay care until conditions become acute. The cost is borne not only in dollars, but in dignity, employment stability, and life expectancy. Reinstating this prohibition would widen already unacceptable oral health disparities.
The Market Has Evolved
36 states currently have Qualified Health Plans that embed adult dental benefits. Over 38 states provide enhanced or comprehensive adult dental benefits in Medicaid. Major national carriers have demonstrated the administrative capacity to deliver integrated dental benefits across product lines.
There is no credible evidence that including adult dental services as an EHB destabilizes markets. There is substantial evidence that excluding them destabilizes families.
Congress granted the Secretary authority to evolve Essential Health Benefits standards in response to medical evidence and market realities. Today's realities demand inclusion, not retrenchment.
Essential Community Providers (ECPs)
The NDA also opposes the proposed reduction of Essential Community Provider participation thresholds from 35% to 20%.
In communities already facing workforce shortages and clinic capacity constraints, reducing ECP standards risks creating "ghost networks" that exist on paper but fail patients in practice. For low-income families, network adequacy determines whether care is accessible at all.
Policy inflexibility must never come at the expense of patient access.
Medical Loss Ratio / Dental Loss Ratio
The NDA strongly opposes weakening Medical Loss Ratio enforcement and supports extending transparent Dental Loss Ratio (DLR) reporting to Stand-Alone Dental Plans.
Consumers deserve to know that the premiums they pay are meaningfully directed toward patient care — not administrative overhead or executive compensation. Transparent and enforceable DLR standards will advance accountability, consumer protection, transparency, and fiscal responsibility.
The Stakes
Underserved and marginalized communities already experience disproportionate rates of untreated decay, periodontal disease, tooth loss, and oral-systemic complications. Rolling back adult dental EHB protections will increase:
- Emergency room utilization
- Missed work days
- Preventable disease progression
- Public health expenditures
- Health disparities
- And finally — deaths
NDA's Formal Requests to CMS
The National Dental Association respectfully urges CMS to:
- 1 Maintain the removal of the prohibition on adult dental services as an Essential Health Benefit.
- 2 Preserve current Essential Community Provider participation standards.
- 3 Strengthen — not weaken — MLR enforcement and extend standardized DLR reporting to Stand-Alone Dental Plans.
The NDA will continue to advocate for policies that protect access, promote equity, and recognize oral health as integral to overall health.
NDA Day on the Hill 2026
The NDA has invited CMS leadership to attend the NDA Day on the Hill to discuss the impact of this proposal on vulnerable communities nationwide.
Thursday, May 7, 2026 — Washington, D.C.
Wallace J. Bellamy, DMD
President — National Dental Association
Leslie E. Grant, DDS
Legislative Chairman / Past President — National Dental Association
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