In the spirit of full disclosure I have to admit that up until a few months ago I was very much in the dark about the pediatric dental benefit under the essential benefits with PPACA. We knew it was going to be part of the essential benefit requirement and we knew the medical carriers would have to offer some option as part of the Essential Benefits, but we really didn't know how this would look and how our dental carriers would handle it.
If you are playing catch up with this portion of the bill and what it means, this fact sheet and PowerPoint from the National Association of Dental Plans are a great study.
In a nutshell, PPACA dictates that medical carriers in the small group and individual markets starting in 2014 must offer a pediatric dental benefit. The benefit must follow a benchmark set out from the state or HHS depending on the makeup of the Marketplace in the state. Michigan’s benefits are based on a Delta Dental Chip program plan, found here. It is a basic dental plan complete with Type 1, 2 and 3 services. Notice it does not include medically necessary orthodontia. We’re one of only two states who will not require it in the EHB (Essential Health Benefits).
The issue facing small groups is how to administer this new benefit. Will it be through the medical carrier or through a stand-alone dental like the ones we offer here at BPI? And what is the group's liability if they choose to ignore the mandate altogether?
Some medical carriers will 'embed' the pediatric dental. Others will offer it as an add-on or as a bundle. Embedded pediatric dental could be problematic. It will add expense to the family medical rate and the medical deductibles will apply to Type 2 and Type 3 dental services.
Medical carriers who choose to 'bundle' pediatric dental most likely will offer the option for the group to decline. The group who declines will have attest that it is fulfilling this portion of the EHB through another facet of the benefit package--most typically through a stand-alone dental carrier. This attestation will resemble closely the HRA attestations you see from certain carriers. The group will have to provide the medical carrier 'reasonable assurance' that the pediatric benefit is taken care of.
Interestingly though, if the group attests it has pediatric dental but does not, they are not liable in any way. Remember this is small group. There is no employer responsibility to offer coverage. The liability to provide the benefit falls back on the carrier. It is the carrier's responsibility to ensure they offer a full benefits package in the eyes of HHS. Hence, the attestation situation.
Blue Cross Blue Shield of Michigan and Priority Health are two carriers who will not embed but rather bundle. The Blues will offer Blue Dental as an option while Priority will offer a 'soft handoff' to Delta Dental to its clients.
Those dental carriers who wish to have a certified EHB plan must be certified both by the state and HHS. Most of the carriers who certify will simply enhance their current family coverage with the pediatric portion. It will cost a bit extra, but generally much cheaper than the medical offerings.
We’re excited to report MetLife along with the MMA will be an exchange certified dental plan. All small group policies will automatically be updated with the pediatric benefit 1/1/2014. The cost of about 2% in overall spend will be added at renewal. To learn more about how Met will be handling this, click here.
As for our other carriers, Companion Life produced these two very good pieces (ACA Dispatch Letters and ACA Q&A) regarding the dental benefit. They have chosen to take a wait and see approach for the first few months, but they do plan on filing a plan for next year and hope to have on ready by the second quarter. Kansas City Life similarly has plans to file but will not be certified 1/1/2014.
It’s safe to say it will be best to unbundle this benefit from the medical. The benefits will be cheaper and easier to access for the employees and groups. Of our portfolio, MetLife and MMA are certified EHB dental plans. Stay tuned to our email blasts and blog as we continue to update you on new guidance as it comes forth.