aso response to the ada issues paper on item number 881 ... · aso response to the ada issues paper...

ASO Response to the ADA Issues Paper on Item number 881 September 2016 1

ASO Response to the ADA Issues Paper on Item number 881

and the proposal to remove this from the 12th Edition of the ADA Schedule and Glossary

September 2016

1. Introduction

The Australian Society of Orthodontists (the ASO), which represents approximately 90% of all registered specialist orthodontists practising in Australia, opposes the deletion of Item 881 from the ADA Schedule. The ASO would like Item 881 be kept in the ADA Schedule indefinitely.

The ASO’s position reflects the view of our members, who have been consulted extensively on this issue. In addition, as the ADA is aware, a significant number of ASO members have contacted the ADA directly to express their views about the proposed deletion of 881 and to request the retention of 881 post the publication of the 12th Schedule.

The footnote in the 11th Schedule about the proposal to remove 881 from the 12th Schedule was read with disappointment by both the ASO and its members. Most ASO members interpreted this footnote as implying the ADA Council and its Schedule and Third Party Committee had ignored the views of the ASO and its members regarding an Item number that impacts directly on their practice.

As the ADA is aware ASO members are also ADA members and this issue has significantly added to existing pressure for the ASO to remove the compulsory ADA membership requirement that currently exists in the ASO constitution.

The ASO has advocated on behalf of its members for the retention of Item 881 as it is widely and appropriately used by specialist orthodontists in their practices. The ASO provided two written submissions to the ADA in June and August 2015, and stated our views at two face to face meetings in October 2015 and May 2016.

The proposal to remove Item 881 from the 12th Schedule is a unilateral decision of the ADA and its Schedule and Third Party committee and directly contravenes the wishes of the ASO and its orthodontist members.

The ASO requests the ADA Schedule and Third Party committee consult further and take into account the views of the ASO and its members. The ASO requests that the ADA immediately reverse its decision to delete Item 881.


2. Request for Specialist Only Number(s)

As a result of the footnote in the 11th Schedule indicating that Item 881 will not be continued in the 12th Schedule, a significant number of specialist orthodontists are calling for a new item number to be established for exclusive use by orthodontists registered with AHPRA as a dental specialist. There is significant support for this view among ASO members. The view is that a new item should mirror the wording of the existing Item 881 and should be used exclusively for a complete course of orthodontic treatment provided by AHPRA registered dental specialists in orthodontics.

Further, there are now calls that all 800 series item numbers be restricted to specialist practices only via HICAPS. As the ADA will be aware Item 881 was originally established by specialist orthodontists for sole use by the specialists. Whilst ADA policy (recently stated on page 11 of the March 2016 News Bulletin) states “Item numbers are not reserved for specialist dentists” the ADA is aware that ‘specialist only’ item numbers currently exist in the Medicare (Section 7) Cleft Palate Scheme, whose rules clearly state that Group C1 items are “reserved for specialist dentists registered in the specialty of orthodontics”. C2 and C3 procedures are similarly restricted to specialist prosthodontic and oral surgical specialists. In addition, the Department of Veterans Affairs has item numbers available for use by dental specialists only; these having been used satisfactorily for many years.

It is a commonly held, but distorted view that there is routine abuse of 881. Evidence has been offered in support of this by the private heath funds indicating such abuse is not regarded as a problem amongst registered specialist orthodontists but rather, such abuse is recorded as being from general dentists. This knowledge has furthered the call for the use of 881 to be restricted to registered specialist orthodontists.

3. ASO Comments on the ADA’s Arguments for the Deletion of Item 881

(i) ADA comment:

“All interested parties would find the coding more transparent if the individual phases were all identified”

ASO response:

The ASO requests access to the evidence supporting this claim.

In the ASO’s experience a key benefit of Item 881 is that it is a simple and efficient way to manage the invoicing of orthodontic treatment. It is simple for patients to understand, it reduces errors associated with more complex invoicing, and allows for straightforward payment plan options.

The vast majority of orthodontists quote patients a fixed fee for complete treatment, noting this is a fixed fee regardless of how many visits or extra effort and appointments may be required during the course of treatment. Further, “complete treatment” usually includes post treatment retention visits.


During the course of a 12 to 24 month treatment, patients may visit their orthodontist at varying intervals (usually every six weeks but occasionally between 4 weeks and 8 weeks). Further, in addition to the number of visits which may vary patient to patient, the length of visits will vary – for example depending on the type of adjustment needed. At the commencement of treatment an orthodontist cannot apportion fees across an unknown number of visits of varying lengths.

Consequently, the most transparent method of billing is to use Item 881 as it promotes transparency of cost, predictability in billing and the establishment of simple payment plans for patients. Most importantly this give greater certainty for the patient and the family as to the costs of care.

(ii) ADA comment:

“It is not used by a significant number of dentists and orthodontists without onerous administration or loss of rebates to patients.”

ASO response:


In the ASO’s experience use of 881 reduces administration costs by allowing treatment to be billed under one item number.

Further any level of rebate available to a patient is set by each individual private health fund regardless of the item number used, or the number of different item numbers used. In the ASO’s experience, the use of Item 881 actually enhances a patient’s prospects of maximising their available rebate. This ADA statement has no validity while PHI life time limits remain.

(iii) ADA Comment:

“Orthodontic Treatment Form pages 42 and 43: It is not widely used, is confusing and encourages incorrect multiple per visit use of 881.”

ASO response:


In the ASO’s experience the use of the Orthodontic Treatment Form is completely separate from and does not encourage incorrect multiple per visit use of 881.

Item 881 does not require that a practitioner fill out and submit the form printed on P.42 to the relevant health fund on the commencement of a course of orthodontic treatment. Most specialists do not use the form but rather, provide written communication to each patient outlining their overall care and associated costs (including payment planning options).

If Item 881 is discontinued, ASO members are seeking guidance on what format their treatment and fee letters should take. Orthodontists currently quote for the comprehensive treatment and formulate a payment plan independent of the phases of care.


The ASO questions how changing the current format will improve and assist the patient, the specialist or administrative staff of the practice of the PHI. Indeed, should item 881 be removed does the ADA propose that orthodontists no longer need to advise PHI’s of the proposed length or course of treatment?

4. ASO Arguments AGAINST the Deletion of Item 881

Item 881 has served orthodontic specialists for over 40 years and its specific use pre-dates the establishment of the ADA schedule. Indeed, it should be noted the ADA adopted Item 881 from the orthodontic specialty subsequent to its use by specialists for some years.

The ASO and its membership do not understand why the ADA is unilaterally wishing to delete Item 881 from the Schedule given it simplifies process, administration, procedures and payment plans for both patient and practitioner and the PHI’s. Simply put, it is an Item number that continues to work exceptionally well for specialists and has done so for decades.

Many ASO members have expressed serious concerns to the ADA regarding the implementation of new Schedule codes that will add cost and administrative burden to practitioners and which is to be implemented with insufficient lead-in time or communication.

This may be due to the Scheduling committee being unaware of the work that is required for specialist orthodontists to restructure their practice procedures and the administration involved should 881 be deleted.

The changes required in many specific orthodontic software packages, mostly written offshore, should not be under-estimated and would require very specific guidance from the Schedule Committee at least 2 to 3 years on advance of any future changes noting the usual periodicity of orthodontic treatment length.

Given these reasons, and those specified below, we would ask that the Schedule Committee reconsider their proposal to delete Item 881.

WHY 881 SHOULD STAY IN THE ADA SCHEDULE INDEFINITELY

(i) Patients and practitioners prefer using a single item number. It is clear, simple to understand and efficient for both parties. For patients it makes managing the family budget easier. For practitioners it simplifies billing, and allows for the calculation of transparent payment schedules with no possible interaction with HICAPS.

(ii) Use of Item 881 allows for transparent and simple payment schedules for patients – which is fair and patient friendly - it reduces the need for complex invoicing, and allows for straightforward payment plan options.

ASO member comment:

x With the 881, our treatment was a package and was paid off through monthly payments due on a set date (e.g. the 1st of each month). This package included all breakages, extra appointments and general adjustments. Essentially, our payment plan does not directly reflect the appointment dates (patients decide on payment


plans suitable for their budget, and treatment is scheduled for the benefit of the patient to progress treatment). How can we do this when we can only invoice an 831 item on the visit date (as opposed to a set date per month)?

(iii) Use of Item 881 reduces the administrative burden for both patients and practitioners - the ability to use Item 881 for a patient undergoing a full course of treatment reduces administrative costs and simplifies administrative procedures.

(iv) Use of Item 881 reduces the potential for error in billing - as billing is simplified by using only one item number. This is easy for patients to understand, reduces the error associated with more complex invoicing, and allows for straightforward payment plan options which are appreciated by both patient and practitioner.

(v) Use of Item 881 avoids the need to charge per visit or by length of visit – which ensures best treatment for the patient, and minimises patients or parents skipping appointments thinking they will be charged more for them.

ASO member comment:

x When an orthodontist bills full treatment under 881 the number of appointments made is not relevant to billing. Thus if patients come in with a breakage or problem with their braces they are fitted in for an appointment. If a short appointment solves the issue then that is accommodated. If a longer appointment is required, the patient may have a further appointment scheduled. With one item number patients do not need to be billed per visit or by length of visit. If patients have to pay for each appointment it is likely they will ‘save’ any breakages up to be managed in one appointment, from their point of view hopefully saving a fee but ultimately this may not be in their best interests or ensure best treatment.

(vi) Use of Item 881 makes quoting and invoicing administratively straight forward and allows post treatment care at no cost to the patient.

ASO member comment:

x We quote patients the total cost of complete treatment regardless as how many visits or any extra material required. Now if we have to itemise the breakdown of the complete treatment: o how we can apportion the adjustments item as it can vary in intervals (usually

most clinician see patient every six weeks but occasionally we need to adjust every 4 weeks or 8 weeks) and number of visits (10 or 20 visits) as well as the length of the visit (7 min vs 30 min adjustment)

o how to allocate the cost of retainers and type of retainer (fix or removable) and number of retention visits as many clinicians monitor their patients for quite sometimes. I for one do not charge patient again if he or she turns up for an appointment in 5 or 10 years’ time as the initial fee for item 881 includes the visit.


(vii) Item 881 allows an orthodontist to determine the best appliances for comprehensive care, with the patient being able to obtain the maximum rebate that reflects the complexity of the service rendered.

(viii) Item 881 allows the orthodontist to determine the best treatment path and alter options as treatment progresses without compromising care due to billing or heath care fund restraints.

ASO member comment:

x There is no way of gauging patient co-operation and abnormal growth prior to commencement of active treatment. The various twists and turns of appliances required to achieve a final result will often result in utilisation of multiple item numbers and repeats of item numbers. I have previously detailed a normal Class II case where I have bonds coming on and off the same teeth during active treatment. I have given many other examples of prolonged or late bonding eg second molars erupting into crossbite during retention stages. The use of many item numbers in various unusual patterns will only create a situation which appears fraudulent. Why create a situation which will lead to unnecessary PHI investigation?

(ix) Item 881 allows for technology developments

ASO member comments:

x Item numbers available do not cover the changing technology and auxiliary appliances as part of the single comprehensive course of care, e.g. Temporary Anchorage Devices, Forsus Springs. Should Item Number 990, not otherwise specified be used? The Patient will not be able to claim any amount on this item.

x The proposed inadequate list of appliances used does not cover the whole range of appliances required. Use of any specific appliance will not dictate the final treatment provided by that particular appliance. There is no need to list appliances – the result is what matters, regardless of numbers or type of appliance utilised. Again, there is no allowance for the range of times taken for various treatments.

(x) Item 881 allows for transfer cases - particularly relevant in transient populations – which

ensures patient treatment can continue – in the best interests of the patient


x Currently I use the 881 item number in transfer cases – while I do not fit the appliance in these transfer cases I have viewed the progressive adjustments as a continuation of a complete course of orthodontic treatment. Also the 881 code did allow for progressive billing and thus could be used for progress payments. I practice in a mining town in central Queensland which has a highly transient population. Consequently, there are a significant percentage of patients that transfer in and out of the practice with ongoing orthodontic treatment. Many of these will transfer to us still requiring 12-18 months of active treatment prior to


debond. My understanding is the 831 code can only be used once for the procedure. If I do not fit the appliance I assume it is not appropriate to use the 831 code. Some transfer cases will have 10-15 adjustment appointments before I can use the 833, 811 and 845 codes. The 871 orthodontic code should not be used with 831 and I would assume in these transfer cases the previous orthodontist would have billed using the 831 code.

x Seeking guidance as to what item numbers are appropriate to use in a case where a patient transfers in fixed appliances mid-treatment. I have taken over three such transfer cases since the 1st of March. There is no item number I can see to apply and I do not think it is fair to the orthodontist or the patient that no item number can be given for what can easily be for a further 18 months of treatment or 15 attended appointments.

x Question: how an incoming transfer patient under active treatment who has been billed out with your proposed Items 831 x 2 is to be billed for their continuing active treatment from their second [or third, or fourth] Orthodontist, when your Item 871 orthodontic adjustment states categorically that 871 is not to be used with item 881 or 831?

(xi) Use of 881 assists in reducing arguments about amounts owing or outstanding and increases chances of a practitioner recovering 100% of billed fees as treatment stages is not related to the fee payment schedule.

(xii) Under 881 orthodontists can set up a contract payment plan and work with the patient or parent responsible to ensure the account is paid in full by the time the active stage of treatment is completed. In many members’ experience once braces are off it is often harder to recover any outstanding amounts.


x Use of 881 simplifies billing thus reducing arguments about amounts owing or outstanding and increases chances of a practitioner recovering 100% of billed fees. Under 881 orthodontists can set up a contract payment plan and work with the patient or parent responsible to ensure the account is paid in full by the time the active stage of treatment is completed. In many members’ experience once braces are off it is often harder to recover any outstanding amounts.

x Orthodontists can provide payment plans tailored to patient circumstances and that don’t make the cost of treatment prohibitive. A payment plan set up under Item 881 enables the cost of treatment to be spread over the time of active treatment.

Our most common form of treatment takes 18 months to 2 years to complete. Under the 881 item number we set up a contract for the cost of treatment. So that once treatment starts a legally binding agreement is made. We ensure we


set the contract up in the right names, we do offer split contracts for separated parents and we set up the charges to ensure we are not having to chase money once the treatment has ended. Unfortunately, over 18 – 24 months of treatment many changes can occur to the family unit. Parents can separate, move away, health issues can occur and employment circumstances change.

Because of the age group we find regularly that patients become adults during their treatment and parents expect the child to take over the payment. As we have a duty of care towards our patients from the moment treatment starts we are committed to ensuring the treatment is completed in its entirety. At the time we are required to deband the patients and charge the 833/811 item numbers, the patient will have to pay a single significant amount towards their treatment, and a lot of patients will struggle to meet this payment and we will in many cases spend a lot of time chasing debts. Also patients who may still be in debt for their treatment at the time of deband could easily then transfer to another provider to remove their braces under the 833/811 item numbers to avoid paying the amount they owe us for treatment provided.

(xiii) Item 881 can assist in ensuring that that treatment will be completed as parents or patients are not fixated on per visit fees and seeking to minimise visits to reduce costs.


x If 881 is deleted and treatment is linked to a fee for each appointment it is likely orthodontists will be asked to remove braces before treatment is finished. In every practice there are always a few patients whose treatment is prolonged in the effort of ‘finishing’ the case. It is likely orthodontists will be faced with the dilemma of patients wanting their treatment finished and this being related directly to payment of fees. At the moment orthodontists persist with these cases until they are satisfactorily finished.

x The removal of Item 881 will likely lead to more arguments between practitioner and patients and/or parents under a mistaken belief that their orthodontist is extending treatment for further fees.

x Using individual item numbers for each visit for orthodontic treatment can

arguably lead to increased fees and thus patients and parents confused about their treatment and commitment. Use of one Item number does away with these arguments and this confusion.

x Apart from interceptive orthodontic treatment we orthodontists routinely uses

item 881 to provide complete orthodontic treatment for our patients. It’s like building a house.....we don’t itemise as how many bricks or roof tiles, how much soil, cement or concrete to complete the job. In Asian countries orthodontic treatment is fully itemised. For examples patients will be quoted as how much is the fixed appliance, cost of each adjustments, cost of material such as elastic, retainers and periodic checks. Hence the patient will have no idea of the final


cost as the adjustment visits could be 10 X or may be 20 X. Some patient will visit the orthodontist intermittently in order to save money.

(xiv) Use of Item 881 simplifies the relationship with health funds for both the orthodontist and patient.


x The administrative burden on practitioners is minimised by the use of 881. Orthodontists do not need to get involved with health funds or set up special arrangements for patients – Item 881 suits all fund requirements.

x Administratively, we can only have 1 charge for different procedures that are added as a part of the treatment eg 833, 811 and 845. We cannot have different charges for the same item number for different health insurance funds or even different plans in the one fund.

(xv) Use of 881 means that all patients can be treated similarly when they are debanded ensuring administrative ease.

ASO member comment:

x Use of 881 means the reception team is not required to doing things differently for different patients at deband time, particularly relevant when agreements or payment plans are entered into 18 – 24 months earlier.

(xvi) The use of 881 ensures the patient will be entitled to claim their full rebate regardless

of which health fund and its requirements.


x Health insurance funds have different rules, lifetime limits, annual limits, percentage paid per charge. Patients expect us to be able to ensure they receive their full entitlement possible from health insurance. This is possible under 881.

x Regardless of what each health insurance rules are, in relation to annual limit, lifetime limit, percentage of charge, etc use of one Item number as Item 881 means a patient can receive their full benefits and all they are entitled to. In the case of full braces over 2 years of treatment time, up to three calendar years of claiming is permitted.

x Under the item number 881 patients can get back their full entitlement for their length of active treatment time, as long as their treatment meets the requirements of 881.

x Health fund calendar years - if we are dividing payment plans over for example 3 years Item Number 831 x 2 could be used in the first year, then 871 subsequent years. As we do not charge per adjustment it makes the timing/issuing of these payments and receipts difficult - are the funds going to pay as much for a 871 as 881 of do we need to issue multiple receipts - some


patients like to pay in lump sum amounts (then we would need to know how exactly much each patient can get back from their fund to make sure they did not miss out on any payments). Patients experience enough problems trying to get rebate information from their funds without complicating things.

(xvii) Use of Item 881 ensures that a patient gets their full rebate entitlement which they may not be entitled to under multiple item number billing due the lifetime limits or 3 year limits imposed by health funds.


x Most Health Funds structure their rebates over a 3-year period. Most of our patients are unaware of this as the Funds make promises of $2500-$3000 orthodontic cover without explaining to patients that it is drip fed over a number of ‘treatment years’. With improvements in Orthodontic treatment times it is nearly impossible to coordinate payment plans across this 3 year period. Because the 881 included the retention phase of treatment it made it achievable for patients to obtain their 3rd year rebate simply by having a retention check appointment 6 months or even 12 months post treatment and logging it as an 881. There is no item code for retention check appointments which is an intrinsic part of the post orthodontic care regime. (There is an item code for the retainers themselves, if needed, but not the appointment.)

x As the Health Funds determine their own rebate schedule the patient ultimately

loses due to the differing rules amongst each fund and the rebate structures imposed by the funds. With treatment times improving cases can be completed in 10 months or less. Patients’ treatment commencement times will be dictated further by Health Funds to facilitate multiple year claiming. 881 allows for the ongoing retention phase to benefit the patient.

x With the Health Funds that charge lifetime and annual limits, people are aware

of exactly how much they would get back at the beginning, so there are no surprises.

x In regards to the life time limits though, from our experience the limit covers all orthodontic item numbers, all item numbers that begin with 8. For example some patients would require two phases of treatment, each at a different stage of their development. For example Item no 829 then later 881. These patients would not have been eligible to receive as much back for their 881 treatment as patients who had only had an 881 treatment. This was because they had already used some of the lifetime limit when they had claimed under the 829 treatment. We have always been pleased that we can use the item numbers for diagnostics etc as they do not use orthodontic item numbers which means they don’t eat in to a person’s lifetime limit.

(xviii) Item 881 covers retention as well as treatment – this ensures patients can claim their maximum rebate. If 881 is deleted this will not be the case.



x AHM will only pay rebates on the “active treatment phase”. This therefore excludes retention check and retainers themselves which disadvantages those whose funds pay in yearly instalments. If item 881 was in use it covers both the active and passive phases.

x As Health Funds make their own rules with regards to rebates and yearly limits the patient’s access to their money/rebate is limited. eg. If a fund only pays on ‘active treatment’, patients can never get their 3rd year rebate.

x The promise from a fund to deliver $3000 on orthodontics is misleading when that fund then says we only drip feed at $500/year and then there is no corresponding item code for retention.

(ixx) The removal of 881 will create significant cost and require significant work to change billing and administrative procedures for no real benefit to either the patient or the practitioner.

Our members’ views are that the significance of this change may not have been appreciated by the ADA Scheduling and Third Party Committee when they proposed the footnote in the 11th Schedule.


x In proposing to delete this Item number the ADA are asking a significant number of their members to change their paperwork, procedures, information packs, terms and conditions, software and billing programs. We have examined how we might implement the changes outlined in the new schedule and have found it to be extremely difficult and problematic. These changes require us to overhaul our entire quoting, invoicing and payment systems. Additionally, we would need to train our staff in the new procedures. Overall, this change will prove costly for the practice.

x We strive to have trusting and good relationships with our patients, but the confusion they will be facing will only cause more problems. We already get such a backlash when health insurance representatives give patients the wrong information that we get blamed for.

x This is a major change for a Specialist Orthodontic practice. All our paperwork, procedures, information packs, terms and conditions, utilisation of our software needs to be changed. We all would have thought that a change as major of this could only be implemented when all the details have been sorted out, but we are having to do this blind with the idea that we have to cover ourselves for every eventuality.


(xx) Deleting 881 leaves irregularities in billing and potentially opens up orthodontists to fraud claims.

ASO member comments: x How do we stand any chance of altering our billing procedures to fit the new 11th

Schedule when [the Scheduling] committee are offering no workable solutions to billing irregularities which will be created by the implementation of the proposed orthodontic item codes in the 11th Schedule?

x Some of my patients will have Item 881 used in 4 years’ time, on completion of their active treatment. They will be billed for their retention stages, as part of the billing procedure used currently with Item 881. To offer another retention item number for these patients completing their active treatment after April 2018 would be fraudulent. I need at least a five year period of notice to discontinue Item 881 without committing fraud.

x As 871 is no longer available for our patient’s per visit adjustment fee, we are unsure what item number to use.

o Most appliances based on patient compliance are charged per adjustment visit (871), but as this is now not applicable (i.e. these visits are certainly anticipated at the time of insertion of the appliance) do we charge the item number e.g. 823 in the case of a Twin Block Appliance or 821 for an Upper Removable Appliance at each visit over the entire course of treatment including initial fabrication and fitting and all subsequent visits to adjust the appliance?

o If the latter is the case, the concern is that the patient’s lifetime limit with their health fund may be completely used up on an initial phase of treatment leaving them with no refund available if they require subsequent treatment with Full Fixed Appliances.

x I will need at least a 48-60 month phase out notification for my PHI patients who have

already commenced their active treatment utilising item 881. I will also require a much more satisfactory orthodontic coding system than that offered in the 11th Schedule. A reasonable period of notice is also essential.

(xxi) If 881 is removed then what is the proposal to allocate a generic one off charge for deband and records that is paid at the end of the treatment that:

1) ensures we receive payment to complete treatment (ie we don’t want too much to be charged unnecessarily at this time). By this time we have done all the work to complete the treatment and we require payment for this as agreed at the commencement of treatment;

2) ensures we can provide patients with the opportunity to receive their full entitlement for the procedure despite their insurance companies’ requirements;


3) to ensure we limit any chance of human error at reception ie a procedure that enables our admin team to post a code at this time that enables a one off amount for these procedures. This would ensure that everyone having this procedure has the code posted to them without staff looking up agreements with the patient that were made 2 years previously. The demands on the front desk are large and fast enough as it is. Things will get missed if a straightforward procedure can’t be implemented.

5. Health Insurance Funds – issues post publication of 11th Schedule

The ASO has also received feedback from its members indicating significant confusion, time wasted and patient dissatisfaction post the footnote about 881 being deleted in the 12th Schedule being published.


x Patients are angry and confused. They do not understand why changes were being made when there was so little information available.

x Some members are seeing a $500-$600 difference in what the same fund will pay for 831 of the first arch and 831 of the second.

x Patients are saying different health funds are rejecting claims under 881.

x A patient [who is a member of Defence Health told her orthodontist they have] said that they will not allow the 881 item number for any orthodontic treatment that begins from the 1st of April, 2016.

x Two health insurance funds have explained they are still only going to give an annual rebate for 831. One of which is only $300. The patient will need to represent the initial statement showing the 831 charge each year to receive their annual limit. From this we will have to deal with patients who say they can’t pay until they get their rebate back. This will just make more work for orthodontists having to reprint initial statements.

x For treatment commencing 5th of April, 2016 HCF have said they will not accept item number 881, that they will only accept item number 831 once. That the patient has a lifetime claim limit of $2,200 but that we must provide a detailed written explanation of the treatment plan.

x Two patients have provided feedback - the first that BUPA are unaware of any changes in item numbers. The second that BUPA understands there will be confusion so they will behind the scenes treat the accounts the way they need to be if the incorrect item number is used.

x HCF and HIF do not recognise 881 and will only accept individual item no’s. The problem that arises with this is detailed below.

o When a fee letter is being done for upper and lower braces, the Item no used for each account, in the payment plan offered, is 831 (Frequency of 2). Oasis does not


allow you to enter frequency of 2 when entering these accounts, so once the account is entered, you have to manually amend each account to frequency of 2, which then brings the value of the account to zero. You then have to manually amend the value of the account to the correct amount.

o On a quarterly payment plan over an 18 month or 24 month period, you have six to eight accounts to manually amend for each patient. When a patient requests to pay monthly, fortnightly or even weekly, there are literally dozens of accounts to individually amend.

o When doing a payment plan for a patient getting a functional appliance or expander and braces, it’s again more user friendly to use Item 881 than have to break it down into individual item no’s, as previously mentioned above.

o HCF has stated that item 881 would again be recognised if it was a number restricted to specialist only usage.

6. Conclusion

The Australian Society of Orthodontists has consistently opposed the deletion of Item 881 from the ADA Schedule. The ASO’s view is that Item 881 should be kept in the ADA Schedule indefinitely.

The ASO’s position reflects the views of our members. The proposed deletion of this item number directly impacts negatively on the vast majority of specialist orthodontic practices.

The current oversupply of general dentists - arising from an increase in the number of dental schools and previous increases in dental immigration - only recently opposed by the ADA - has directly contributed to the current oversupply of general dentists and the increase in general dentists attempting complex orthodontics.

This has led to an increased abuse of item 881 and the increase in indemnity claims in relationship to orthodontics - as the ADA will be aware the most common indemnity claim is general dentists’ orthodontics.

Whilst the ADA may be attempting to correct Schedule abuse through the deletion of the most commonly used number for specialist orthodontists - the more productive and effective route would be for the ADA to work with its largest specialist cohort to encourage the PHI’s to limit rebates from this number to specialists. This would allow specialist practice to continue as it has for decades and allow generalist to continue to operate with increase itemisation accuracy though the remainder of the 800 series.

The ASO requests that the ADA immediately reverse its decision to delete Item 881 from the 12th Schedule and remove the comment in the 11th schedule notifying an intention to delete this item. This footnote is unnecessarily raising confusion for the specialist community, its patients and the PHI’s. Further given this Item number has operated in both the interests of the patient and the specialist for decades it should remain in the Schedule indefinitely.

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aso response to the ada issues paper on item number 881 ... · aso response to the ada issues paper...

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