1. Pediatric Dental Coverage in State and Federally Facilitated Marketplaces Colin Reusch Senior Policy Analyst Children’s Dental Health Project

2. 2 ACA Dental Coverage: The Basics Intended to be part of comprehensive pediatric coverage EHB category 10: “pediatric services, including oral and vision care” Must be offered up to age 19 in marketplaces, small group, & individual coverage Accompanied by numerous oral health provisions (most unfunded)

3. 3 How the ACA Changes Dental Benefits Makes it part of essential health benefits (EHB) Attempts to subsidize through tax credits Limits cost-sharing (out-of-pocket maximums) Removes annual and lifetime dollar limits on coverage (children only) Plans must offer child-only plans (up to age 19) Limits orthodontic coverage to medically necessary Integrates oral health into medical coverage via preventive services

4. 4 ACA Preventive Oral Health Services Must be covered by all qualified health plans (QHPs) at no cost: –Oral health risk assessment by pediatrician for young children & referral to dentist –Fluoride supplements for children w/out fluoridated water –Fluoride varnish application by pediatrician for all children under age 5

5. 5 HOW IS DENTAL COVERAGE DIFFERENT?

6. 6 Marketplaces can offer dental differently Pediatric Essential Health Benefits Qualified Health Plan (QHP) Stand-Alone Dental QHP Including Dental (embedded) Stand-alone dental plans must be allowed to offer QHPs can be exempt from offering dental ACA does not require purchase of stand-alone dental States may require purchase Stand-alone dental not considered in Premium Tax Credit calculation

7. 7 Dental plans are treated differently Stand-alone Dental Plan Optional to purchase (unless state requires) Separate insurance policy & premium Separate deductible Separate out-of-pocket maximum Adult coverage options available No cost-sharing reductions Some consumer protections may not apply QHP w/ Embedded Dental Dental benefits part of health plan (QHP) One premium for health and dental May have unified deductible or separate deductible for dental Individual or family plan includes dental for children; some plans may include adult dental Cost-sharing reductions apply All consumer protections apply

8. 8 Affordability measures apply differently Separate & additional OOP max for stand-alone dental plans. For 2015 plan year $350 for one child $700 for 2 or more

9. 9 Tax credits sometimes forget dental Alexandria, VA family of 4 w/ annual income of $70,650 Premium limit = $6,712 (9.5% of income) 2 nd lowest cost silver plan (includes dental) = $9,636 Tax credit: $9,636 – 6,712 = $2,924 Dental premium (2 kids) = $0 Total premium obligation = $6,712 (9.5% of income)

10. 10 Tax credits sometimes forget dental Richmond, VA family of 4 w/ annual income of $70,650 Premium limit = $6,712 (9.5% of income) 2 nd lowest cost silver plan (no dental) = $8,959 Tax credit amount: $8,959 – 6,712 = $2,247 Estimated dental premium (2 kids) = $552 Total premium obligation = $7,264 (10.3% of income)

11. 11 WHAT DID THE 2014 PLAN YEAR LOOK LIKE?

12. 12 Pediatric dental offerings: 2014 State-based marketplaces: CA, NV, WA – must be sold stand-alone KY, NV, WA – requirement to purchase CT – all QHP standard plan designs embed dental & largely protect from high deductibles DC, RI, VT – all QHPs chose to embed UT – very limited benefits in dental offerings FFM & Partnership marketplaces: No restrictions on plan types No requirement to purchase stand-alone plans

13. 13 About a third (34%) of all health plans in the federally-facilitated marketplaces include pediatric dental coverage in their products. Less than 1% include adult dental coverage. Plan documents aren’t always clear on how cost-sharing & deductibles apply to dental benefits. Source: CDHP analysis of health plan information data: https://www.healthcare.gov/health- plan-information/ QHPs with Embedded Pediatric Dental Coverage by State (FFM & Partnership Marketplaces)

14. 14 Take-Up of Stand-alone Coverage Adults account for vast majority of take-up but adult dental not part of EHB & not subsidized No data on embedded pediatric dental take-up. Data Source: ASPE Enrollment Report: http://aspe.hhs.gov/health/reports/20 14/MarketPlaceEnrollment/Mar2014/ ib_2014mar_enrollment.pdf

15. 15 What Does Coverage Cost? Embedded in QHPStand-alone Plan Average Premium $5.11 (attributable portion of premium) $30.98 (70% AV) $38.89 (85% AV) Average Deductible When separate: $34.21 When unified: $2,935 $41.10 Source: ADA Health Policy Resource Center, “Health Insurance Marketplaces Offer a Variety of Dental Benefit Options.”

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17. 17 State Policy Changes: 2015 plan year CO – requiring purchase of pediatric dental CA – allowing embedded dental & standardizing OOP maximums (reducing dental OOP by $350) CT – including stand-alone adult dental offerings DC – finalizing standard QHP plan designs & separate deductibles for pediatric dental

18. 18 Federal Policy Changes: 2015 2015 Notice of Benefit and Payment Parameters: Stand-alone dental max OOP reduced: –$350 per child, $700 for multiple children –Applies to FFM & state- based marketplaces

19. 19 Priorities moving forward Encouraging QHP dental integration Network adequacy Risk for duplicative coverage? Affordability impacting take-up Tax credit applicability Transparency/shopping experience Consumer education Navigator/assister training Data!!!

20. 20 A FINAL WORD ABOUT CHIP

21. 21 Children’s Health Insurance Program (CHIP) 8+ Million children covered Funding runs out in September 2015 Millions of children would transition to marketplace coverage At least 2 million low-income would kids without subsidized coverage Marketplace coverage not comparable – dental a prime example

22. 22 Questions? Colin Reusch, MPA creusch@cdhp.org 202.417.3595 www.cdhp.org