National Committee on Vital and Health Statistics (NCVHS)

Subcommittee on Standards and Security

Testimony of:
The American Dental Association

March 3, 2004

Prepared and submitted by:
Albert H. Guay, D.M.D.
Chief Policy Advisor
American Dental Association
211 East Chicago Avenue
Chicago, IL 60611
312-440-2844 (voice)
312-440-2520 (fax)

Dr. Cohn, members of the Subcommittee and my colleagues in the health care community.  Good morning.  As you know, my name is Al Guay and I am the Chief Policy Advisor at the American Dental Association.  On behalf of the Association I would like to express our appreciation of the NCVHS interest in dental attachments.  Today I will discuss ADA policy on attachments, the current methods of providing attachments and finally how attachments could promote administrative simplification.

The ADA policy on attachments is that they are not necessary in the vast majority of claims and in those cases, all the information necessary for claims adjudication could be included in the dental claim itself.   The ADA has worked with payers, dental providers and vendors to develop claim formats, both electronic and paper, which meet the needs of all interested parties.  This has been quite successful, as many payers have reduced their requirements for attachments when dental claims are submitted electronically.

Unfortunately, there is no agreement on the situations for which attachments are required.  Consequently, most dental offices submit far more attachments than are required in an effort to avoid payment delays.  Most dental attachments are radiographs, but periodontal charts and operative reports are generally requested for specialized treatment.

Today, most dental attachments are submitted in the same envelope with a paper claim.  Often when the dentist submits an electronic claim and separately mailed attachments, the payers have difficulty in successfully matching the claim to the attachment.  This usually requires duplication of the attachment and delays payment.  Scanned attachments may be submitted to a repository for viewing by a dental consultant, but the current technology is proprietary and the image generally lacks clinical quality.  This may also require resubmission of the attachment and again delays payment.  The ADA does not support this approach because it is not standards based.  Rather, the ADA supports the use of DICOM images for image transfers, but dental plans do not currently accept DICOM images.

In the interest of administrative simplification, the ADA proposes that the data content of the dental claim be reduced from a maximum data set to a minimum data set.  This data set would be consistent with the information on the ADA paper claim that is sufficient for adjudication of most claims by most third party payers.  Additional information that may be required in certain specified situations by payers under contract would be provided in a supplemental attachment.  This would permit 90% of the claims to be processed expeditiously with only the essential information.  The remaining 10% of dental claims would be subject to exception processing with the dentist providing the additional information upon request and as required for payment.  This approach has been successful in the pharmacy industry where the median pharmacy claim amount is comparable to the median dental claim amount.  Further simplification would result if all payers were to agree on the criteria for attachments.  The dentist would know in advance what additional information might be required for prompt adjudication.  Clear and unambiguous criteria for submission of attachments can support successful implementation of a national standard.  The ADA is proposing to work with the National Association of Dental Plans and the Delta Dental Plans Association on this effort.

Thank you for the opportunity to share these ideas with you.  I would be pleased to answer any questions the Subcommittee members may have.