Sunday, May 24, 2015

What are the “Powers That Be” saying when it comes to Medicaid dental fraud and overtreatment?

Below are select excerpts from the transcript and powerpoint slides of a January 2015 CMS Learning Lab Weninar entitled “Advancing Program Integrity for Medicaid Dental Programs: Federal, State and Stakeholder Efforts”.  The Webinar was held by Medicaid-Chip State Dental Association’s (a must check out website) Lynn Douglas Mouden, DDS, MPH, Chief Dental Officer with the Centers for Medicare and Medicaid Services (CMS), (also associated with a host of other organizations). Speakers included:

First, John Hagg, Director of Medicaid Audits, Office of Inspector General, US Department of Health and Human Services, His presentation begins on page 3.

Second, Meridith Seife, MPA, Deputy Regional Inspector General, Office of Evaluations and Inspections,, 212-264-2000. Her presentation beings on page 5, about 2/3 the way down the page, and; 

Third, Linda Altenhoff, DDS Chief Dental Officer with the Office of Inspector General, Texas Health and Human Services Commission (THHS). Her part of the presentation at the bottom of page 7.

(Bios of each speaker can be found on page 2 of the transcript)

I found a few things troubling, that I’ll discuss later.

Below are the excerpts from Ms. Seife  portion where she speaks about the latest (at the time) OIG Questionable Billing Dental Medicaid Reports:

Who we are:
•The Office of Evaluation and Inspections (OEI) conducts national evaluations of HHS programs from a broad, issue-based perspective.
•We are working on a series of studies evaluating Medicaid pediatric dental services in selected States.

So why are we looking at Medicaid dental services? Well, as I'm sure many of you know, in recent years, there have been a number of high-profile cases where certain dentists and dental chains were found to have engaged in some extremely abusive dental practices. Although such cases represent an extremely small number of bad actors, they can have truly devastating effects on children. Dentists have been found guilty of routinely extracting healthy teeth, performing unnecessary pulpotomies, or putting stainless steel crowns on teeth that didn't need them. Obviously our primary concern is that no kid should ever have to endure unnecessary treatment, or that treatment that doesn't meet basic standards of care. But this can also have a significant impact on taxpayers as well.

The primary goal of our evaluations was to use Medicaid claims data in a way that could accurately identify dental providers who exhibited patterns of questionable billing. We're doing this currently in four states. In 2014 we issued reports on providers in New York, Louisiana, and Indiana. And our California report will be issued early this year. Although we were somewhat limited in doing these studies in only a few selected states, we hope that these reports will serve as a model for how other states can use their Medicaid data to identify potentially problematic providers in their Medicaid programs, and, hopefully, to target their resources more effectively in looking at those providers.

So I've already referenced, a few times, this idea of questionable billing, but I haven't really defined what it means. It's based on a type of analysis that the OID has done in other parts of Medicare and Medicaid, but this is the first time we've applied such an analysis to dental services. What is it? It's really just a method of determining certain billing patterns that are significantly different from one's peers.

We base these analyses on certain key measures that we developed in consultation with numerous experts. We spoke with law enforcement officials who specialized in working dental fraud cases. We also spoke with dental experts in state Medicaid agencies and CMS. We also received a tremendous amount of help from experts within the AAPD and that ADA.

Once we developed these measures, we then analyzed Medicaid's claim data in each state to identify extreme outliers or questionable billers, as we referred to them in our report. Specifically, we use these measures to identify providers who received extremely high payments per child, provided an extremely large number of services per day, provided an extremely large number of services per child per visit, and/or provided certain selected services, such as pulpotomies and extractions, to an extremely high proportion of children.

Once we developed these measures, we then analyzed Medicaid's claim data in each state to identify extreme outliers or questionable billers, as we referred to them in our report. Specifically, we use these measures to identify providers who received extremely high payments per child, provided an extremely large number of services per day, provided an extremely large number of services per child per visit, and/or provided certain selected services, such as pulpotomies and extractions, to an extremely high proportion of children.

Just to give you a sense of what those outliers look like, here is an example of a questionable billing analysis on average Medicaid payments per child by individual dentists. As you see, the vast majority of dentists are clustered around the median and mean amount, with an average payment of about $200 per visit. But, of course, way out towards the left, you start seeing outliers that are very different from that amount. For example, you can see that one outlier was paid over $1,100 per visit on average.

Process for Conducting Audits
•Audit Notification Letter / Entrance Conference
•Define: Audit Objectives, Scope, and Methodology
•Data Collection and Analysis
•Exit Conference
•Draft Report
•Auditee Comments
•Final Report

So, before I get into what we found, I do want to make just a few brief points about our methodology. One of the biggest challenges in conducting this type of an analysis is to be sure that you're comparing similar peer groups. Obviously you don't want to compare a general dentist in private practice with an oral surgeon working in a hospital setting. So, first, we separated out general dentists from other selected specialties. And once we grouped each peer group appropriately, we then established key thresholds for each of the measures.

These thresholds were established using a statistical method that's known as the "Tukey method." For the more statistically inclined among you, it basically calculates values that are greater than the 75th percentile plus three time its interquartile range. For those of you that are not statistically inclined, it's simply a way of identifying really, really extreme outliers. It also does this in a way that takes in the overall distribution into account. It means that you will not just be taking the top ten billers on a particular measure, it has to be significantly different from the norm. As a result, in a number of case, we found no outliers at all for a specific measure.

I should emphasize that this analysis does not confirm that a particular provider is engaging in fraudulent or abusive practices. Some providers may be billing extremely large amounts for perfectly legitimate reasons. Our position is simply that these providers are significantly different enough from the norm that it warrants further scrutiny.

So, using those measures, we identified a number of dental providers with questionable billing in each of the states we looked at. In total, we identified 151 providers with questionable billing, and Medicaid paid these providers over $56 million for pediatric dental services in 2012.

Questionable Billing Examples:
New York :
•Dentist averaged 16 procedures per child, compared with a statewide average of five.
•Dentist extracted the teeth of 76 percent of children he treated, compared with a statewide average of 10 percent.
•Three dentists each provided an average of 146 or more services per day, compared to an average of 27 services for other dentists in the state.

We also found that a significant proportion of these questionable billers were concentrated in certain dental chains. As many of you know, systemic problems within specific chains is a concern to many policymakers. In the three states we've reviewed so far, between one-third to more than half of the questionable billers worked for certain dental chains. Many of these chains had been previous investigated for providing services that were medically unnecessary or that failed to meet professionally recognized standards of care.

So it's probably most instructive to give you some more details about some of the billing practices we found among these providers. In New York, for example, one dentist averaged 16 procedures per child, compared with a statewide average of five. Another dentist extracted the teeth of 76% of children he treated, compared with a statewide average of just 10%. In Louisiana we identified three dentists who provided an average of 146 or more services per day, compared to an average of 27 services for other dentists in the state.

FindingsWe also identified dentists who performed an unusually high number of pulpotomies. For example, one dentist provided pulpotomies to 19% of the children that he served, compared to an average of only 3% of other dentists in the state. Another dentist provided 13 pulpotomies during the same visit to a 3-year-old child. In Indiana we identified a dentist who averaged over a thousand dollars in Medicaid payments per child, compared with an average payment of only $254 for other dentists in the state. We also identified four dentists who provided extremely large amounts of behavior management, which includes the use of papoose boards and other restraints.

These four dentists billed for behavior management for more than half of the children they served. And, again, this is compared to a statewide average of only 5%.

So to sum up, these findings do raise concern that certain providers may be billing for services that are not medically necessary or were never provided. It also raises concerns about the quality of care provided to Medicaid children. A concentration of questionable billers within specific chains also raises concerns. You know, again, just to reiterate, although some of this billing may be legitimate, providers who billed for extremely large amounts of services do warrant further scrutiny.

State Medicaid programs should:

1.Increase monitoring of dental providers to identify patterns of questionable billing,
2.Closely monitor billing by providers in dental chains,
3.Ensure that States employ adequate safeguards to monitor providers under managed care, and
4.Take appropriate action with dental providers who had questionable billing.

So what do we recommend to the states? You know, first we recommended that states increase their monitoring of dental providers to identify patterns of questionable billing. We really encourage these states to proactively use claims data to both identify billing patterns that are highly unusual, as well as to target the state's resources to conduct necessary follow up. We also recommended that states take a closer look at certain dental chains, specifically those that have a high concentration of providers with questionable billing.

•Findings raise concerns:
•Certain providers may be billing for services that are not medically necessary or were never provided,
•Quality of care provided to children with Medicaid,
•Concentration of providers in chains raises concerns that these chains may be encouraging their providers to perform unnecessary procedures to increase profits.
•Although findings do not prove that providers either billed fraudulently or provided medically unnecessary services, providers who bill for extremely large numbers of services warrant further scrutiny

Also, since several of the states we reviewed were moving towards the managed care model for their dental services, we recommended that states work to ensure that they will continue to have adequate safeguards to monitor providers under their new managed care systems. Finally, we recommended that states take appropriate action with the dental providers that we identified in these reports.*

Excerpts of Linda Altenhoff, DDS,Chief Dental Officer,Office of Inspector General,Texas Health and Human Services Commission:

Topics Covered During Presentations
•Public perception of healthcare fraud, waste, and abuse through various media
•State rules and regulations
•Texas Dental Practice Act and Texas Medicaid Rules
•Professional Guidance
•American Dental Association’s (ADA) Ethics and Code of Professional Conduct (2012) and Dental Records (2010)
•American Academy of Pediatric Dentistry (AAPD) Oral Health Policies and Clinical Guidelines
•American College of Dentists Ethics Handbook for Dentists
•Centers for Medicare & Medicaid Services (CMS)
•Medicaid Compliance for the Dental Professional (2014) video
•Website resources available for dental providers
•Texas State Board of Dental Examiners
•Texas Secretary of State –email notices of rule updates

Proving fraud, waste, and abuse in health-care services, especially those funded through state and federal tax dollars, is one of the many tasks that offices of inspector generals have been assigned. In speaking with dentists, their staff members, and legal representatives from across the U.S., I often hear the admission of "I didn't know what I was doing wasn't right," or "How's the dentist and provider supposed to know this? Where is this information available?" or even, "Is it really -- it's just an administrative error, what's the big deal?" Well it is a big deal, and providing opportunities for health-care providers and their staff members to learn and understand what their role is in preventing and possibly identifying health-care fraud, waste, and abuse is critical. The earlier this information can be provided the better.

Therefore, Texas OIG has developed and is cultivating opportunities to speak with current, potential, and academic dental team members. It's especially important to be inclusive of all dental team members so that there's a shared understanding of the information conveyed and their responsibilities.

We've been able to establish working relationships with organized dentistry and dental hygiene, including the state components of the American Dental Association, Academy of General Dentistry, the American Academy of Pediatric Dentistry, and the American Dental Hygienist Association. We've also worked closely with the Oral Health Coalition, with our schools of dentistry, both for undergraduate and post-doctoral candidates, and with our dental hygiene programs across the state.

Some of the things that we'd like to cover during our presentations is to raise the awareness among attendees of the public perception about health care fraud, waste, and abuse that's available through various media outlets. And typically the presentations that we give are anywhere from 50 minutes, so just under an hour, to the longest so far has been a three-hour presentation. These do include excerpts from various media outlets covering health care fraud stories. And to address the questions posed regarding where this information is found, we talk about the various online resources available to health-care professionals, including the State Licensing Board, the Medicaid Rules and Provider Reference Manuals, but we also discuss nationally developed professional guidelines, including those around ethics and professional standards, as well as clinical and professional guidelines, and on the slide you see some of the references that we have, including the American Dental Association's Ethics and Code of Professional Conduct, which was updated in 2012, and their Dental Records documentation that was provided in 2010.

We also have the American Academy of Pediatric Dentistry's oral health policies and clinical guidelines, which serves as a great resource not only for the practicing dentists and their staff to be aware that this resource is out there and available, but also as we are conducting any of our audits, we use those as reference materials as well.

And then, of course, to reinforce the issue around ethics and the professional standards that we as health-care providers are being held to, we also bring up and recognize the American College of Dentist Ethics handbook for dentists.

One other aspect, which we've used on several occasions, is the Medicaid Compliance for Dental Professionals video, which has been made available through the Centers for Medicare and Medicaid Services. This is a 56-minute video clip that goes into the importance of compliance and having a compliance program, and we used this to, again, help to educate and reinforce. But this is something that is an expectation if they are involved in providing services to the Medicaid population, but also just to, again, raise the awareness that this is an important component of their day-to-day practices.

We provide information to the attendees with regards to other resources that are available to them, including rules associated with professional licensure and Medicaid services. Since those are being constantly evolved, we encourage the dental team members to sign up for notifications from our secretary of state's office so that, again, we can address the questions as to, well, where do we find this information.

We also encourage by receiving those notices about rules, pending rule changes and such, gives them an opportunity to participate in the public comments segments that are offered during those rule development processes. And to be able to stay abreast of any of these potential or pending changes that may affect their business models. Again, referencing the American Dental Association, the Academy of General Dentistry, and the American Academy of Pediatric Dentistry, and the valuable information that can be found within those websites.

During the various presentations, I reinforced the importance of providing professionally appropriate health-care services to the population that the providers have chosen to serve. One of the most popular aspects of the presentations, other than the video clip that I referenced earlier, has been the redacted examples of non-compliance that I found during the dental record reviews that I've conducted.

I've reached out to the dental faculty at the three schools of dentistry here in Texas because I feel that it's important, even for them to understand how what they have taught and are supporting within the academic environment, how that is being implemented when they go out into the real world of dental practice. So maintaining those good record-keeping skills and good clinical skills are important for those graduates, whether they are finishing up their initial post-doctoral dental school environment or if they are in a post-doctoral program as well.


We also, during the presentations, really tried to engage the attendees by offering them some examples and questioning them as to how they perceive what is being shown on screen. I'll show you some of those examples that we share. So the panoramic image that's in the upper left of the slide shows extensive dental treatment that was provided on this patient when he was 15 years of age, in which all the services that you see on that, which includes root canal therapy and crowns, was all done on a single visit, and the work was done within three months prior to this X-ray having been taken.

So in showing this, it shows that here, within a very short period of time, there's already failure of the services that were provided, but the services provided did not meet standard of care, as established within the dental profession, and that created some long-lasting trauma for this particular patient. The X-ray on the upper right, I ask and pose the question is this a bite wing or a periapical X-ray, and typically I get the response that, yes, is a periapical X-ray, which is there to show the full tooth, the roots of the tooth and the supporting structure.

However, this particular X-ray, along with three others, were billed out as bite wing X-rays. The example of the documentation in the lower left of this slide is from a record that I reviewed, and it points out not only that there's inadequate documentation of the services that were provided but there's also a misuse of the dental procedure codes that were billed, which may be either due to a lack of understanding of the appropriate use or possibly an intentional miscoding of the services performed.

And then on the lower right, this is an example that was sent to our office by a dentist who had been seeing this child. The child was seen by a different practice, had been solicited to come to that practice, and then the mother, being dissatisfied, came back to the original dentist, and the photographs and X-rays demonstrate teeth in which services were billed and paid, and yet the services were not rendered, and it's an obvious indication that there was no medical necessity for the services that were billed out. The only saving grace on this was that this child was not subjected to unnecessary treatment, but as taxpayer, we were subjected to having paid for services that weren't rendered.

So, in closing, one of the things is that it's critical that program directors and managers coordinate and/or facilitate and encourage contractors and state program staff to take an active role in reaching out to health-care providers, organizations in academic institutions to identify opportunities to engage in sharing information about fraud, waste, and abuse, and the importance of efforts to change the perception that Medicaid and other health-care payer resources are a blank check or an unlimited credit card that they are entitled to overindulge with.*

Next to speak was Mary Foley, RDH, MPH, Executive Director Medicaid-CHIP State Dental Association

As most of you are aware, the Medicaid-CHIP State Dental Association is a national membership organization representing all state Medicaid and CHIP dental programs. Our work serves to improve Medicaid dental program administration through infrastructure and capacity, through collaboration with Medicaid dental program stakeholders.

Program administrators and their stakeholders have been particularly interested in this topic for many of the reasons you just heard about. Two years ago, at the MSDA annual symposium during the open forum, participants raised serious concerns about the practices of state agencies and their audit contractors. In particular were the concerns of dentist providers who were being audited for no apparent reason. During the meeting, we, MSDA agreed to convene a program integrity summit and invite a group of expert stakeholders to open the conversation to better explore the issues and potential solutions.

2014 Program Integrity Summit
•To identify and explore emerging Program Integrity issues affecting all stakeholders of Medicaid and CHIP Oral Health programs;
•To gain consensus on general strategies to address these issues; and
•To develop a strategy for policy recommendations to advance Program Integrity for all key stakeholders.

In February of 2014, was the convening of Medicaid and CHIP Oral Health Integrity Summit. We invited a group of national, federal, and state stakeholder representatives to discuss the issues associated with Medicaid dental program integrity. The meeting was held in Washington, D.C…. representatives from the state Medicaid dental programs included Kentucky, Texas, Tennessee, and Oklahoma, along with the Texas Office of the Inspector General and the Tennessee Medicaid Program Integrity Unit. Federal representatives were invited from CMS, both at the Center for Medicaid and CHIP Services, as well as the Center for Program Integrity.

2014 Program Integrity Summit Participants
State Representatives
   •Kentucky, Texas, Tennessee, Oklahoma Medicaid dental programs
   •Texas Office of the Inspector General
   •Tennessee Medicaid Program Integrity
Federal Representatives
   •CMS, CMCS & CPI; HRSA; HHS Office of the Inspector General; US District Attorney’s Office; and the FBI;
   •DentaQuest, Delta Dental of South Dakota, Delta Dental Plans Association, National Association of Dental Plans
   •National Professional Leadership Organizations
   •Medicaid-CHIP State Dental Association
   •American Dental Association
   •American Association of Pediatric Dentistry
   •Policy Makers

We had HRSA representatives, a representative from the Office of the Inspector General, the U.S. District Attorney's Office, and the SDI. Representatives from the payer community included DentaQuest, Delta Dental of South Dakota, Delta Dental Plan Association, and the National Association of Dental plans. And then, of course, representatives from national, professional leadership organizations, representatives from the Medicaid-CHIP State Dental Association, the American Dental Association, the American Academy of Pediatric Dentistry, and then, of course, there were policymakers in attendance as well.

And just so you know, we worked closely with several state Medicaid PI experts, including David Weeks from Tennessee, and Dr. James Gilchrist who were both instrumental in guiding us in the preparation for this meeting.

The charge for the summit was to open a dialogue among policymakers and stakeholders who share an interest in maintaining the program integrity of Medicaid, CHIP, and Title V programs to ensure the administration and delivery of quality, cost-effective oral health-care services to their beneficiaries.

The purpose of the summit was to specifically identify and explore emerging program integrity issues affecting all stakeholders of Medicaid and CHIP oral health programs. To gain consensus on general strategies to address these issues and to develop a strategy for policy recommendations to advance program integrity for all key stakeholders.

Dental Medicaid Solar System

Medicaid beneficiaries are the center of the Medicaid program universe. This slide was presented by Dr. James Gilchrist at our PI Summit, and I share it with all of you today to reemphasize that Medicaid beneficiaries are the primary focal point that all Medicaid programs are responsible for. That said, it should be noted that program administrators are held accountable for taxpayer dollars as they are used to fund their programs.

Recommendations for Provider Organizations
•Provide education to members in all aspects of Program Integrity and Medical Necessity
•Share audit practices by all federal and state agencies that affect dental provider service delivery
•Share audit practices by federal and state contractors
•Develop risk management programs for member dentists
•Develop a model guideline for “dental (medical) necessity” for use by states establishing and updating benefit payment policies

Recalling who was at the table, everyone agrees that managing Medicaid program integrity is a complex task in this day and age. There are a variety of federal and state agencies that have authority in this platform. That is why MSDA invited, in addition to the Medicaid dental program administrators, the various federal agencies who share that authority, again, the OIG, the FBI, and two of the centers within CMS. But the roles and responsibilities associated with managing the program integrity at the program level have changed. What traditionally was exclusively managed by the state, may now, in part, be managed by external contractors.

RAC stands for Recovery Audit Contractors. These contractors have the responsibility of identifying potential abusers. What is particularly interesting, and confusing to many, is the fact that different RACs may use different protocols for how they undertake their work. So there's no quick or dirty manual that we can use or read to understand how these practices and protocols are implemented. It's very complex.

We are most definitely in the age of accountability, and with advances in technology comes the ability to monitor provider behavior and billing practices, unlike in the past, as we heard earlier today. This technology is what allows for improved detection of provider treatment norms and, thus, the extreme outliers, and those are the concerns of many. However, what was most striking at the summit to the Medicaid providers was the confusion due to multiple authorities and the use external contractors and what independent and integrated roles they play. So there is that complexity and that's just the way the system is made up at this point.

Recommendation for Providers
•Read the provider manuals –“contracts”
•Identify differences in policies, benefits and payments across plans and contract agreements
•Gain understanding of rules and regulations regarding Prior Approvals
•Acquaint billing staff with Program Integrity and Medical Necessity policies by state and by plan

There are recommendations at this point that I would like to go forth with you, and the first is a recommendation for the federal agencies. The group made recommendations that federal agencies need to and should collaborate, communicate, coordinate, and cooperate with other partnering federal and state programs more readily. To establish transparent policies to the degree possible and protocols to the degree possible to support all efforts, to collaborate with MSDA, the American Dental Association, and the American Academy of Pediatric Dentistry, along with other provider organizations, and to provide education and technical assistance to help those involved understand federal law and regulations.

Recommendations for Medicaid-CHIP State Dental Association
•Monitor federal and state Program Integrity legislation and regulation
•Monitor state “Medically Necessary” policies and protocols
•Identify variability in policies across states
•Identify variability in policies across plans
•Identify roles and responsibilities of various state and federal authorities
•Publish annual national reports

The recommendations to the state programs were, again, to collaborate, communicate, coordinate, and cooperate with other federal programs, as well as other in-state programs, to establish transparency in policies and protocols, to collaborate with MSDA, ADA, and ADT, and state provider organizations to gain input and share information for new regulation policies and practices, and to assist in the education of providers and, of course, beneficiaries as well.

There were recommendation also to payers and other contractors, and it was recommended that payers who are working and doing the roles of traditional Medicaid programs would have done but they follow the same recommendations that were made for the state, and also, to maintain a positive attitude throughout the practice and remember that here in the United States we are innocent until proven guilty.

Recommendations for provider organizations included the provision of education to members in all aspects of personal integrity and medical necessity. It was recommended that these organizations share audit practices by all federal and state agencies that affect dental provider service delivery, to share audit practices by federal and state contractors and to develop risk management programs for member dentists; to develop a model guideline for dental medical use necessity for use by states establishing and updating benefit payment policies; to participate in state regulatory meetings to provide input and guidance in Medicaid policy development; and finally, to send representatives to participate on state Medicaid program integrity advisory committees.

The group had recommendations for dental providers as well, and those recommendations included the recommendations that dental providers read the provider manuals, that these manuals serve as contracts, and when a dentist signs up to becomes part of a network, a Medicaid network, they are signing a contract. And that when you read those contracts, dental providers should identify differences in policies, benefits, and payments across plans and contract agreements, even within the same state. This should gain understanding of rules and regulations regarding prior approval and acquaint billing staff with program integrity and medical necessity policies by state and by plans, as some dental provider may work in more than one state.

There were further recommendations as well for dental providers, and those included to bill only those services eligible for payment by the plan, to document reasons for all treatment and billing practices, to provide evidence or be prepared to provide evidence for medically necessary services, and to participate in state regulatory meetings, to provide input and guidance in Medicaid policy development.

There were finally recommendations for the Medicaid-CHIP State Dental Association, and that was to monitor federal and state program integrity legislation and regulation; to monitor state medically necessary policies and protocols across the U.S.; to identify variability in state policies' to identify variability and policies across plans' to identify the roles and responsibilities of various state and federal authorities; and to publish annual national reports to the best degree possible.

Next Steps:
•Convene Program Integrity workgroup
•Gain consensus on priority areas
•Educate federal and state administrators about dental care
•Develop resource materials for stakeholder groups
•Establish infrastructure to educate and train Medicaid providers
•Educate dental providers about:
   •Federal authority, legislation and regulation
   •State authority legislation, regulation, policies
   •Roles and responsibilities of states, plans, providers, and beneficiaries
   •What to expect from agents authorized to uphold program integrity
   •Risk Management: ways to avoid allegations of fraud and abuse
   •Treatment and billing practices

In closing, the group identified next steps, and those steps are to release this report that comes from the summit, and I will share with you that that report is expected to be available by the 2015 symposium which is going to take place this June in Washington, D.C. And basically for stakeholders need to continue this conversation, to continue monitoring and continue education of all involved.*

Related Links

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MSDA Learning Lab Slides, January 28, 2015

MSDA Learning Lab Transcript, January 28, 2015

AAPD Pediatric Oral Health Research and Policy Center Audit, February 2015

Interesting statement by AAPD in regards to Audits that are harmful to both provider and Medicaid recipients. -

Inconsistency with AAPD Clinical Guidelines.Auditing criteria should be consistent with AAPD Clinical Guidelines. (page 1)