Coalition Praises Proposed Rule on Dental Tax Credits



The US Treasury Department has proposed a rule clarifying the inclusion of subsidies for pediatric dental benefits purchased in the federal and state health insurance marketplaces as part of tax credits for all families. A coalition of dental organizations including the ADA, Children’s Dental Health Project (CDHP), Delta Dental Plans Association, and National Association of Dental Plans has praised the proposal.

Representatives of the coalition worked with Sen. Debbie Stabenow (D-Michigan) to advocate for affordable coverage of pediatric dental benefits in the marketplaces. They also urged the Treasury to equally apply Advanced Premium Tax Credits under the Affordable Care Act (ACA) to pediatric dental benefits.

The ACA allows children’s health and dental coverage to be offered separately, though the federal Internal Revenue Service has interpreted the law in a way that makes it unlikely for families to receive a tax credit for stand-alone pediatric dental coverage. The proposal reverses that interpretation and clarifies how the cost of dental coverage for children applies in calculating a family’s premium tax credit.

“Starting in 2019, families purchasing both a health plan that does not include pediatric dental coverage and a stand-alone pediatric dental plan would receive a tax credit amount based upon the premiums of both a benchmark health plan and a benchmark dental plan,” said Colin Reusch, senior policy analyst at the CDHP.

During the past 3 years, the coalition found that many states did not have pediatric dental coverage within their medical benchmark plan. As a result, tax credits for pediatric dental premiums were not included in overall subsidy calculations. The proposal will ensure pediatric dental benefits are included in the benchmark calculation regardless of whether they are embedded in a medical policy or offered separately on the marketplaces.

“This ensures that all families eligible for premium tax credits get the full amount to which they are entitled, regardless of how they purchase their children’s dental coverage,” Reusch said. “While this proposed rule does not remove all financial barriers associated with marketplace dental coverage, CDHP is pleased that the US Administration has heard our concerns and is moving to make access to affordable dental coverage a little easier for families and children.”

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