On July 2, the Iowa Medicaid Enterprise (IME) and Iowa Department of Human Services (DHS) jointly released an informational letter to all Iowa Medicaid-enrolled dentists regarding the transition of children's Medicaid fee-for-service to DWP Kids. The letter emphasizes the 90-day window to fully transition: "During the initial 90-day transition period, any Medicaid FFS non-expired prior authorizations will be honored through September 30, 2021. In addition, claims submitted to either DDIA or MCNA from a non-network provider will be honored (if medical necessity is met) by the dental plans through September 30, 2021." Read the full letter here
IDA has been working to obtain clarification from IME and the DHS regarding recent comments or instructions they have provided regarding Medicaid billing. IME and DHS have indicated that it may be acceptable for dentists to enter into private pay arrangements with individuals who are covered by Medicaid. IDA agrees that this is acceptable if the service is a non-covered service, such as a cosmetic procedure, or if the patient chooses to exercise his/her rights under HIPAA to not submit the particular claim to Medicaid, which is rare with regard to dental services. However, IDA is concerned that IME and DHS’s current stated position is contrary to the prior stated position of IME and DHS as well as statutes and case law.
Furthermore, IDA is concerned that such arrangement could violate the current provider agreements with the managed care organizations Delta Dental and MCNA. IDA is continuing to communicate with IME and DHS to obtain clarification on their position. If you enter private pay arrangements with Medicaid patients when the matter does not involve a service that is not typically covered or is not as a result of the patient asking you to pay for the service privately due to confidentiality concerns, there is a risk that you will be in violation of federal regulatory requirements, your provider agreement with the managed care organization(s), and/or exposing yourself to a Medicaid fraud issue. IDA will update members as it continues to communicate with IME and DHS on this issue.