Adult Dental Benefits at Risk
A newly proposed federal rule would reinstate a prohibition preventing routine adult dental services from being included as an essential health benefit under the Affordable Care Act. If finalized, the policy could limit states’ ability to expand comprehensive adult dental coverage beginning in 2027.
The Centers for Medicare & Medicaid Services (CMS) has proposed reversing a 2024 policy change that allowed states to include routine adult dental services as an essential health benefit (EHB) under the Affordable Care Act (ACA). The proposal appears in the United States Department of Health and Human Services’ Notice of Benefit and Payment Parameters for 2027, released on February 9, which outlines standards for qualified health plans offered through ACA Marketplace exchanges.
Under the 2025 Payment Notice, CMS removed a longstanding prohibition that prevented states from adding routine adult dental services to their EHB-benchmark plans. That regulatory shift opened the door for states to require comprehensive adult dental benefits without annual or lifetime dollar limits starting in plan year 2027. States were permitted to submit benchmark updates beginning in May 2025.
The newly proposed rule would reinstate the categorical prohibition on including routine adult dental services as an essential health benefit. CMS has indicated the change is intended to better align EHB requirements with the scope of benefits typically offered by employer-sponsored plans.
In addition, the proposal would reduce the required percentage of essential community providers within stand-alone dental plan networks from 35% to 20%, potentially affecting access for low-income and medically underserved populations. Coverage design influences utilization patterns, preventive care access, and long-term oral-systemic outcomes. CMS is accepting public comments through March 13 before issuing a final rule later this year. Click here to read more.
