Federal Comment Period for the NH Medicaid 1115 Waiver Application including the Dental Benefit for Pregnant Women

The New Hampshire Department of Health and Human Services Office of Medicaid Business and Planning has submitted an 1115 Demonstration Project Waiver Application that includes a Dental Pilot Project for the state’s Medicaid-qualified pregnant woman. 

The full waiver, which addresses mainly mental health and substance abuse services, does include expanded oral health and dental services aimed at identifying and treating high risk and dental disease in pregnant women with a goal of impacting the health of the mother and their young children. 

According to Medicaid.gov, Section 1115 of the Social Security Act gives the Secretary of Health and Human Services the authority to approve experimental, pilot, or demonstration state projects promoting the objectives of the Medicaid and CHIP programs.  An approved waiver gives the state the opportunity to

  • Expand eligibility to individuals not otherwise covered by Medicaid or CHIP;
  • Provide services not typically covered by Medicaid; and
  • Use innovative service delivery systems that can improve care, increase efficiency, and reduce costs. 

The purpose of these state demonstration projects is to give states the additional flexibility to design and improve their programs while demonstrating and evaluating different policy approaches.  In general, 1115 demonstration projects are approved for a 5-year period, are typically renewable for 3 years, and must be “budget-neutral” to the federal government. 

  • Regarding oral health, the proposed NH waiver is designed to provide 
  • Oral health education to pregnant women and young mothers;
  • Education on the oral health impact of smoking, supported by the current smoking cessation program benefit; and
  • A Dental Benefit Pilot Project that provides a near-comprehensive dental benefit for pregnant women entering the program up to their child’s age of 5.

At NHOHC, we believe the pilot is an opportunity to target a specific and distinct group that is easily accessed and easily measured; and that improved oral health in this population will result in financial savings to Medicaid and reduction in uncompensated care funding for dental care for the mother and her children. 

This supports the expectation that with improved oral health through early preventive care, it is reasonable to expect long-term savings for the Medicaid program. Additionally, integration of the learning and behavior change may mean that the mother will begin any subsequent pregnancies from the stand point of better health thereby leveraging the educational and service activities from the pilot program into the health of future children by delaying exposure to the bacteria that causes decay. The waiver also presents an opportunity for cross-disciplinary support and intervention. 

We encourage NH Medicaid to implement the standards for both the educational and pilot project that are not only supported by evidence-based science but are consistent with best-practice, accepted clinical standards, and recognized in the 2012, National Maternal and Child Oral Health Resource Center published “Oral Health Care During Pregnancy: A National Consensus Statement – Summary of an Expert Workgroup Meeting” that was written to provide guidance to the many health professionals involved in the care of pregnant women. 

The expert workgroup consisted of individuals with expertise in prenatal and dental care including representatives from the American Academy of Pediatrics, American Academy of Pediatric Dentists, American College of Gynecologists, American Dental Association, the American Dental Hygienists’ Association, the American Association of State and Territorial Dental Directors, the Medicaid-CHIP State Dental Association, the National Maternal and Child Health Center, and many more committed to improving the oral health of pregnant women and their children. The document and other relevant publications are available at: www.mchoralhealth.org

The 1115 Waiver oral health education and pilot program addresses many of the Consensus recommendations including:

  • Preventive, diagnostic, and restorative dental treatment is safe throughout pregnancy and is effective in improving and maintaining oral health;
  • Educating pregnant women about preventing and treating dental caries is important for women’s oral health and the future oral health of their child;
  • Dental decay, caused by bacteria, is transmittable from mother to child, and education and counseling may reduce incidence.

CMS has done a preliminary review of the NH Medicaid 1115 Waiver Application that is pending and has opened a 30-day window for stakeholder and consumer comments into the process. That comment window ends on August 6, 2014. Using the link below, you can find the waiver and the opportunity to present your comments.  Feel free to cut & paste from this narrative. 

You may submit comments using the Questionnaire and typing in your comments or by uploading a document.  The questionnaire will close on Aug 8th 2014 at 11:00 pm.  You may view already submitted comments or download files submitted by others from the Summary of Results page. 

When submitting your comments, please remember that you are addressing your comments to the federal level to Health and Human Services Secretary Sylvia Mathews Burwell and CMS Administrator Marilyn Tavenner.  Comments are important to the federal process. 

Please take time to let your support of this important Medicaid Dental Pilot Project be known.   YOU make a difference. Every submission is counted.