News & Insights

States have future option to mandate dental benefits

Written by Bukaty Companies | August 6, 2024

A regulatory move by the Centers for Medicare and Medicaid Services (CMS) allows states to include adult dental care as an essential health benefit (EHB) that must be covered in individual and small group health plans in 2027.

Today there are 10 categories of EHBs defined by the Affordable Care Act (ACA). Each state has the authority to identify how the EHBs are defined in their respective benchmark plans available through the federal and state marketplaces.

States interested in including adult dental services into their benchmark plans can initiate the application process with CMS starting in 2025.

If included as an EHB, adult dental services could be subject to the same deductible that applies for medical services. Other ACA requirements impacting EHBs, such as the ban on annual and lifetime coverage limits and maximum annual out-of-pocket limits, would apply as well.

Employer-sponsored stand-alone dental plans, which are not subject to ACA requirements for comprehensive medical insurance, however, would presumably not be required to abide by these requirements.

Given the cost implications of an additional EHB, Bukaty Companies will continue to monitor this topic and its impact by state.