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American Dental Education Association


Volume 2, No. 95, April 19, 2023

Biden Administration Announces Expansion of Health Coverage to DACA Recipients
 
The Biden administration announced [ [link removed] ] that it would expand Medicaid coverage and access to the Affordable Care Act’s Insurance Market Exchanges to include Deferred Action for Childhood Arrivals (DACA) recipients. The expansion will be accomplished through the issuance of a proposed rule that would amend the definition of “lawful presence,” for purposes of Medicaid and Affordable Care Act coverage, to include DACA recipients. The Department of Health and Human Services plans to have the proposed rule released by the end of April.
 
The administration also released a fact sheet [ [link removed] ] in conjunction with their announcement.

ED Issues Update to Third-party Servicer Proposed Guidance
 
The U.S. Department of Education (ED) issued guidance in the form of a “Dear Colleague” letter regarding third-party servicers (TPSs). The guidance, which was issued on Feb. 15 and updated on Feb. 28, clarifies that outside entities performing the functions of student recruiting and retention, providing software products and services involving Title IV administration activities or providing educational content and instruction, are defined as a TPS. As such, the institutions that contract with these entities are subject to reporting requirements with respect to the entities, and the entities themselves are subject to annual, non-federal audits of the Title IV-relevant functions they perform, if such functions are covered by the audit guide. In short, the guidance expands the definition of a TPS.
 
The “Dear Colleague” expands the definition of a TPS to include providers who handle student recruitment and application activities, and who provide consumer information, among other things. (See the non-exhaustive list in the “Dear Colleague” letter of functions and services that, if outsourced by an institution to a third party, would render that third party a TPS subject to the TPS requirements.)
 
Under the proposed guidance, reporting requirements for TPSs would increase and restrictions on the location of these providers as well as where TPSs store their data, would be instituted, among other restrictions. The guidance would be effective Sept. 1.
 
The proposed guidance garnered over 1,000 comments. The majority of which expressed concern about the new requirements and confusion over the lack of clarity in some of the requirements. For example, one concern of the medical education community was how would this guidance impact residencies and other clinical training relationships. It was not clear whether hospitals and other clinical training facilities would fall under the proposed TPS definition.
 
In response to the significant amount of concern regarding the proposed guidance, on April 11, ED issued an update to its TPS guidance. In its update, of importance to the medical education community, ED states that clinical and externship opportunities do fall under the revised TPS definition because they “they are closely monitored by qualified personnel at an institution.” ED also pushed back the proposed guidance’s effective date. “Specifically, [ED] will delay the effective date of the guidance letter, and the September 1, 2023, date will no longer be in effect. The effective date of the revised final guidance letter will be at least six months after its publication, to allow institutions and companies to meet any reporting requirements. Deadlines for audit and contractual requirements will follow in fiscal years that begin after the effective date for the reporting requirements.”
 
ED notes that it will issue a final guidance letter though there is no date by which their review will be complete. In the meantime, previous “Dear Colleague” letters GEN 12-08, GEN 15-01 and GEN 16-15 (as amended by our March 8, 2017 electronic announcement) will remain in effect.

Maryland Considering Expanding Dental Coverage to Those Ineligible for Health Care Coverage Due to Immigration Status
 
The Maryland General Assembly has sent a bill [ [link removed] ] to Gov. Wes Moore (D) that if signed or allowed to become law, will require the Maryland Health Benefit Exchange and the Maryland Department of Health to develop a report comparing options for offering affordable health care and dental care coverage to state residents who are ineligible for the state Medicaid and CHIP programs, qualified health plans or stand-alone dental plans due to immigration status. The report must be submitted to the General Assembly by Oct. 31, 2023.
 
Several states have already expanded [ [link removed] ] state-funded health care coverage for individuals or groups regardless of immigration status.

Washington State to Send Dentist and Dental Hygiene Compact to Governor
 
The Washington State Legislature has passed a bill [ [link removed] ] that would allow the state to join the dentist and dental hygiene compact. If signed by Gov. Jay Inslee (D), Washington would become the first state to pass compact legislation.
 
Licensure compacts serve as a means for creating licensure reciprocity among states that join. They have become a popular method for increasing licensure portability among licensed professionals. To date, 49 states and territories [ [link removed] ] have adopted at least one licensure compact, and licensure compacts are already in place for at least 15 other professions.
 
Compacts are legally binding contracts and, in order to join, states must pass substantially similar legislation. The Council for State Governments (CSG) has completed model legislation [ [link removed] ] for states that wish to join the compact.
 
When states join, licensees in compact member states are granted the opportunity to apply for a “compact privilege” that will allow them to practice in another member state. Under the current draft of the compact, license holders will be granted the opportunity to apply for compact privilege if they:
 • Hold a license as a dentist or dental hygienist;
 • Graduate from a Commission on Dental Accreditation-accredited program;
 • Successfully complete a clinical assessment for licensure, with “clinical assessment” currently defined as an examination or process required for licensure as a dentist or dental hygienist, as applicable, that provides evidence of clinical competence in dentistry or dental hygiene;
 • Have passed a National Board Examination of the Joint Commission on National Dental Examinations or another examination accepted by rule as a requirement for licensure;
 • Meet any jurisprudence requirements;
 • Complete a criminal background check;
 • Submit an application and pay applicable fees; and
 • Comply with requirements to submit specified information for administrative purposes.

 
Compacts are overseen by commissions that consist of representation from each compact state. Commissions are granted the authority to grant “compact privilege” and create commission rules to which member states agree to comply. The compact will be enacted, and a commission will be created to oversee the dentist and dental hygiene licensure compact after seven states have joined the compact. To date, legislation that would allow states to join the compact has been introduced in seven states [ [link removed] ] .

ADEA Advocacy in Action
This appears weekly in the ADEA Advocate to summarize and provide direct links to recent advocacy actions taken by ADEA. Please let us know what you think and how we might improve its usefulness.
 
Issues and Resources
 • Applications open [ [link removed] ] for Ryan White Part F Dental Reimbursement Program
 • Applications open [ [link removed] ] for HRSA Dental Public Health Research Fellowship
 • ADEA report [ [link removed] ] on teledentistry
 • ADEA report [ [link removed] ] on the Impact of the COVID-19 Pandemic on U.S. Dental Schools
 • ADEA policy brief [ [link removed] ] regarding overprescription of antibiotics
 • For a full list of ADEA memos, briefs and letters click here [ [link removed] ] .

Key Federal Issues [ [link removed] ]

ADEA U.S. Interactive Legislative and Regulatory Tracking Map [ [link removed] ]

Key State Issues [ [link removed] ]

The ADEA Advocate [ [link removed] ] is published weekly. Its purpose is to keep ADEA members abreast of federal and state issues and events of interest to the academic dentistry and the dental and research communities.
 
©2023
American Dental Education Association
655 K Street, NW, Suite 800
Washington, DC 20001
Tel: 202-289-7201
Website: www.adea.org [ [link removed] ]

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B. Timothy Leeth, CPA
ADEA Chief Advocacy Officer
 
Bridgette DeHart, J.D.
ADEA Director of Federal Relations and Advocacy
 
Phillip Mauller, M.P.S.
ADEA Director of State Relations and Advocacy
 
Brian Robinson
ADEA Program Manager for Advocacy and Government Relations
 
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