States could add dental benefits mandate for small group plans in 2027
In a state that used that option, some dental health services might be available without annual spending maximums.
States might be able to add dental health benefits to the essential health benefits package for their individual and small-group health insurance markets in 2027.
If states did that, small-group plans would have to cover the dental benefits added to the EHB package without imposing annual or lifetime limits on spending on that type of care.
Adam Fox of the Colorado Consumer Health Initiative and Wayne Turner of the National Health Law Program briefed members of the National Association of Insurance Commissioners’ consumer liaison committee during a recent in-person meeting in Chicago.
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The deadline for new EHB benchmark selection for 2027 will be May 7, 2025, according to a copy of the EHB discussion slidedeck included in a liaison committee meeting packet.
Some of the other benefits that could be added to state EHB packages could include benefits for annual mental health wellness exams, coverage for home visits for women who have just given birth and improved coverage for diabetes care, Fox and Turner said.
EHB regulation basics
Federal law requires the U.S. federal government to leave most regulation of the business of insurance to the states. The NAIC is a group for state insurance regulators and helps state regulators share ideas about insurance regulation.
The EHB package is part of the Affordable Care Act framework for commercial health insurance.
The ACA requires small-group health plans at four different “metal levels,” or benefits richness levels, to cover set percentages of the actuarial value of a state’s EHB package. A bronze plan must cover about 60% of the value of the EHB package, and a top-level platinum plan must cover about 90% of the value of the EHB package.
The ACA itself requires individual and small-group plans to cover basic dental and vision services for children.
In the past, federal regulations prohibited states from including dental services for adults in their EHB packages.
The U.S. Department of Health and Human Services eliminated the adult dental services EHB restriction in April, in the final 2025 benefit and payment parameters regulations.
The future
Whether any state will really add significant dental benefits mandates to its EHB will depend on how willing federal officials are to keep the new regulations in place and how interested state officials are in using their new flexibility.
“Conservative states will likely take little or no action,” according to Amwins analysts. “More progressive states will embrace the decision to require insurers to implement and cover adult benefits.”
Fox and Turner emphasized during the NAIC presentation that states will have to provide “reasonable notice and an opportunity for public comment” before changing their EHB packages.
Although a state could not impose spending limits on dental benefits included in an EHB package, it could impose visit limits, the speakers said.
Efforts to add dental benefits to the EHB package could be popular with workers.
A recent PeopleKeep survey found that 91% of workers rated dental insurance as a somewhat or very important benefit.