ADA President George Shepley and Executive Director Raymond Cohlmia offered suggestions for a smooth transition between Medicaid and CHIP in comments filed on November 4. They cited Kaiser Family Foundation data, which estimates that before COVID-19, about 10% of Medicaid/CHIP enrollees were disenrolled and reenrolled in one year.

In the letter, the ADA suggests expanding dental participation in Medicaid through the reimbursement and reduction of administrative burdens, including the easement of credentialing and audit processes and encouraging the payment of clean claims within 15 days of their submission.

The ADA also commended CMS' proposal to eliminate waiting and lockout periods for dental care within CHIP coverage.