As we reported in our last story about the fee schedule, Texas Health and Human Services Commission (HHSC) Provider Finance was holding a public hearing to receive comments on the proposed Medicaid reimbursement rate changes, including the long-awaited dental rate reallocation, on July 22. The session, led by HHSC reimbursement analyst Cole Hancock, addressed updates that could take effect on September 1, 2025, impacting these fees along with fees for Maternal Fetal Medicine Radiological Services and Applied Behavior Analysis Services.
A nine-minute highlight version of the hearing video is below as well as transcripts of testimony.
Substance of the hearing
The hearing lasted just under an hour and fifteen minutes. Most testimony was given on the other issues. However, two dentists, one representing the TDA, spoke to the dental fees along with four anesthesiologists.
A key point at the start of the hearing is that Mr. Hancock stated,
“We will review all comments and additional information received today. Updates and final rates will be published in a provider notification on the TMHP website if the proposed rates are approved …Implementation of all fees will depend on approval to proceed from executive management. If no significant negative comments are received and approval is granted by executive management, HHSC will instruct the claims processing contractor to implement the rates. If significant negative comments are received. HHSC Provider Finance will summarize concerns and present alternatives for executive decision.(TDMR emphasis)“
TDA wants to ensure all funds are allocated
The following is the testimony of Dr. Armin Aliefendic.
“Good morning. I’m Dr. Armin Aliefendic. I’m a board-certified pediatrician in Waxahachie, Texas. I treat Medicaid-enrolled children, many with special health care needs. I speak today on behalf of the Texas Dental Association, the TDA, regarding the Texas Health and Human Services Commission’s proposed changes to Medicaid dental reimbursement rates.
“During the recent regular legislative session, TDA worked with lawmakers and stakeholders to secure Rider 39 in the HHS budget. This rider directs HHS to 1. Restore reimbursement rates for all Medicaid dental procedure codes, excluding the unbundled first dental home codes, to the February 28th, 2025 level. It also implements a uniform rate increase for 48 key dental procedure codes supporting the full scope of dental care for Medicaid patients, including diagnostic, radiographic, preventive, restorative, surgical, and supplemental services.
“These changes are essential to improving dentist participation and ensuring access to quality dental care for vulnerable children. The proposed rate increases are for the benefit of the entire Medicaid dental program.
“According to estimates from HHSC provided to lawmakers during the 89th Legislative session, Rider 39 allocates an estimated $146,277,546 in combined state and federal funds for this purpose. Yet the right hearing packet does not clearly show whether these funds were fully applied. TDA respectfully requests that HHS provide a clear explanation of its rate-setting methodology to confirm full implementation of Rider 39.
“TDA also supports the proposed increase for the first Dental Home program, which benefits children aged 6 to 35 months. The new total reimbursement of $145.16 for visits is also a welcome improvement.
“However, further action is needed. Sedation and anesthesia reimbursement remain inadequate. The TDA supports aligning rates for code D9222, D9223, D9230, and D9248 to the 40th percentile of 2025 dental fees. Without this, dental anesthesiologists won’t participate in the program, leaving many children without access to essential care.
“In closing, TDA urges HHSC to fully implement Rider 39 funding and address sedation and anesthesia reimbursement gaps. These steps are vital to maintaining a Medicaid dental network capable of meeting the needs of Texas children.
“Thank you for your commitment and for improving the access to dental care.”
“Leaving Medicaid”
The testimony of Dr. Ayham Nahhas.
“Hello, my name is Ayham Nahhas. I’m a dentist in Houston, Texas.
“I’ve been a Medicaid provider for over ten years. And I see mainly children in my office who have Medicaid. They make up the majority of my patients.
“So I just wanted to express my disappointment with this fee revision. The ADA Health Policy Institute lists Medicaid fees for Texas Children’s dental care at 42.1% of private dental fees for 2024, which was already pretty difficult to deal with. We’ve experienced about 50% inflation since 2007, when the last real fee increase was.
“So this 5% increase that we’re seeing in this revision is really insufficient. It’s a slap in the face. Honestly, it’s insulting. It does not account for all the increased costs that we have suffered. And what’s worse than that is the reversion to the pre-March 1st fees on several codes that are just unthinkable. The ceramic crown fee went up from $252 to $698, and now it’s going back down to $252. So if you think about the 42% number, this is way lower than that. That doesn’t even, I don’t think, reach 25% of an average fee for a crown. So there’s no way that dentists are able to cover their overhead, to be able to offer that procedure to their patients.
“I understand that the porcelain-fused-to-metal crown code increased slightly, but, this is just to me, just does not make any sense. I mean, to force us to use noble metal when gold is at an all-time high. It’s just a waste of taxpayer money. It’s not logical.
“Furthermore, on molars, porcelain-fused-to-metal and porcelain crowns are not covered at all. And then, high noble metal, the fee for that code actually went down again at a time when gold is at an all-time high. I understand there are limitations to the budget, but telling us that we have to use gold and high-noble metals does not make any sense. That’s not a budget issue. That’s just a common-sense issue.
“And then the fee for surgical extractions has also been reduced. I’m not sure how you can expect dentists to do surgery practically for free. I’m just shocked at this fee schedule, and I just wanted to express that it’s extremely disappointing. And I’m sure it will result in many of us leaving the Medicaid system.”
We will have to see if any further change occurs.