March 13 Comment Deadline - Oppose Proposed Rule Limiting States’ Ability to Include Adult Dental Services as an Essential Health Benefit
The Centers for Medicare & Medicaid Services (CMS) is proposing to reverse course on an important policy that removed a prohibition on states' ability to include adult dental services as an essential health benefit (EHB). The Trump Administration wants to reestablish the prohibition on adult dental services as essential for plan year 2027.
Oral health is integral to overall health and well-being. Preserving state flexibility to choose to include oral health as an essential health benefit for adults, something the ADA supports — rather than limiting them — enables states to protect access to care while ensuring consumers have meaningful and affordable plan choices.
Patients who use the ACA Marketplace are often individuals more likely to forego dental care when they hit their annual maximum. When adult dental services are included as an EHB, states can support more comprehensive coverage options and help ensure key Marketplace consumer protections apply, improving affordability and reducing fragmentation in coverage for patients. Preserving this flexibility can also strengthen plan accountability and transparency, including through medical loss ratio (MLR) standards that help ensure premium dollars support patient care.
It's more than just losing the essential health benefit option; that's alarming. The dental insurance industry is hailing this as a victory. We must be the louder voice to urge CMS to do what is right for dental care access.
Dentists need to strongly oppose reinstating the prohibition on non-pediatric dental services as an essential health benefit. We urge you to contact CMS to let them know how this proposal is unfair to states and their citizens.
Please submit comments before March 13, 2026, to stand up for accessing dental care and preserving states’ ability to provide the best affordable dental plans.
For more information on the essential health benefit for adults, visit: https://www.ada.org/ehb
Thank you for your dedication to protecting oral health in this country.
Steps on How to Contact CMS:
Please copy the sample comments below, then click the Comment Now button. This will take you to the Regulation.gov site pictured here:
Then click the comment button.
Please paste the sample comments into the comment section To add your input into the federal record, take a moment to personalize the provided text.
Next, follow the steps on the website to submit your comments.
This should only take a few minutes. Sample comments below can help protect adult dental services.
CMS-
Dentists like me do not support reinstating the prohibition on adult dental services as an essential health benefit. Oral health is integral to overall health and well-being. We must help address longstanding gaps in oral healthcare coverage for adults across the nation. That is why I support including dental coverage as an “Essential Health Benefit” or EHB option for both children and adults inside and outside of Marketplace plans. I ask that CMS preserve a state’s flexibility to choose to include oral health as an essential health benefit for adults.
Here are the reasons to include dental services as an essential health benefit:
- It would help states support more comprehensive, affordable coverage options for patients.
- It would help ensure key Marketplace consumer protections apply to adult dental services when included as an EHB, as they do for pediatric services currently.
- It would support affordability and reduce fragmentation in coverage for consumers.
- It supports transparency and accountability, including strong MLR standards, so premium dollars are directed to patient care rather than insurance companies' salaries and overhead.
The decision to include adults was made with a diligent review of extensive stakeholder feedback, including from the ADA. Prohibiting states’ ability to include adult dental as an essential health benefit would go against broader goals to foster greater competition, lower overall health care costs, and reduce fragmentation in healthcare for consumers.
Please do not prohibit states from including adult dental benefits as an EHB for qualified health plans.
