CMS Update on Medicare Part D

Dentists who treat Medicare patients must either enroll in the program or opt out in order to prescribe medication to their qualifying patients with Part D drug plans. So, if you are a dentist who writes prescriptions for elderly patients on Medicare, you need to opt in.

CMS postpones Medicare Part D enforcement until 2019

November 01, 2016 (ADA News) — The Centers for Medicare & Medicaid Services announced Oct. 31 that it is once again delaying the enforcement of the Medicare Part D prescriber enrollment requirement.

The new deadline for providers to enroll is Jan. 1, 2019.

CMS published a final rule in May 2014 and an interim final rule in May 2015 stating that prescribers must be enrolled or validly opted out in order for their written prescriptions to be covered under Part D.

Previously CMS said that enforcement of this requirement would begin on Feb. 1, 2017, but the agency said Oct. 31 that it also "recognizes the need to minimize the impact on the beneficiary population and ensure beneficiaries have access to the care they need."

To do this, the agency said it plans to "implement a multifaceted, phased approach that will align full enforcement of the Part D prescriber enrollment requirements with other ongoing CMS initiatives."

The Association continues to seek a legislative repeal of the requirement and continues to support H.R. 4062, bipartisan legislation introduced in 2015 that calls for removing the mandate that certain providers, including dentists, be enrolled in Medicare in order for pharmacists to be reimbursed.

For more information on the CMS delay, visit This article can also be found at

View the ADA website for additional info:

Update from Spring 2016


In a conversation with CMS today we confirmed that “opting out” is not an option for any provider who treats patients in a Medicare Advantage plan and wishes their patients to receive the benefit from the MA plan. This is true whether the provider is in-network for the MA plan or not (for PPO-type MA plans). The MA organization is required to check the opt out list on a regular basis. Remember if a dentist has already opted out they can reverse their decision within 90 days. 

We also confirmed that enrolling either using the 855I (full enrollment) or the 855O (ordering and referring provider) are valid options for a dentist treating patients with an MA plan.

If a non-contracted dentist enrolls in Medicare using the 855i this does not mean the dentist is now an MA plan participant i.e. in-network for the MA plan.

The video that ADA has on CPS continues to be the most accurate information we have on this topic (other than the change in date noted above) --

The ADA has a slew of information readily available on its website regarding the opt in/out deadline for Medicare.  There is even a flow chart of sorts that should make it fairly easy for dentists to decide whether or not they should enroll or not.  The info can all be accessed from:

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