TrustWorks On Call: Ten Out of Ten Dentists

Behind the Headlines

Unpacking the forces driving healthcare's biggest stories.

1. CMS adds oral health training incentives to MIPS.

In the 2026 Medicare Physician Fee Schedule Final Rule, the Centers for Medicare and Medicaid Services (CMS) introduced its first-ever Merit-based Incentive Payment System (MIPS) improvement activity focused on oral health.
Qualified physicians can now earn MIPS credits, which tie a portion of Medicare Part B payments to quality and practice improvement measures, by conducting oral-health risk assessments in primary care settings, educating patients on oral health, and making referrals to dental care for patients with oral health needs.

TrustWorks Take: By including oral health activities in MIPS, CMS is sending several messages to primary care physicians (PCPs). First, it incentivizes them to pay more attention to oral health during patient encounters. Second, it encourages PCPs to build stronger connections with dentists through referral networks. Third, it fosters the mindset that oral health is critical to overall healthcare, and worthy of physicians’ attention, rather than relegating it to dentists alone and requiring a separate appointment. PCPs are already accustomed to performing baseline assessments of highly specialized parts of the body before making a referral, and this rule change is an attempt to add the mouth to this list.

Of course, this rule change only goes so far, given that traditional Medicare lacking robust dental benefits. CMS has been expanding the number of medically necessary dental services Medicare Part B covers, but just under half of Medicare have no dental coverage and see a dentist less than once a year. An oral health referral from a PCP falls flat when the patient lacks dental coverage. If a dedicated dental benefit is the endgame for Medicare, this MIPS initiative is a small, but important, first step. The next could be to add routine dental preventive care as a Medicare benefit, as even one dental visit or cleaning per year greatly improve oral health and therefore overall health.

2. CMS proposes rolling back adult dental essential health benefit.

In the Notice of Benefit and Payment Parameters for 2027 Proposed Rule, which sets the standards for Affordable Care Act (ACA) marketplace coverage, CMS has proposed prohibiting exchange plan insurers from including routine non-pediatric dental services as an essential health benefit (EHB).
This proposed rule reverses a policy finalized by the Biden administration that would allow states to add adult dental services as an EHB for marketplace plans; the Biden-era rule was set to take effect in 2027 and now may not take effect.
CMS justified the proposed policy reversal by pointing to statutory requirements that the scope of EHBs “be equal to the scope of benefits provided under a typical employer plan.”

TrustWorks Take: The reasoning offered by CMS to roll back this rule is frustrating and circular. Routine adult dental services cannot be an EHB because employer plans, which often take their cues from federal health policies, do not "typically" cover them. If the Biden administration’s rule was allowed to take effect, more employer plans would follow the example set by state exchanges in adopting routine dental coverage. And on the flip side, employers could take its reversal under Trump as a cue to reduce or drop dental coverage.

Over 60 percent private dental insurance is employer-sponsored. On top of that, state Medicaid programs have expanded dental coverage significantly in recent years (a trend that may reverse due to impending Medicaid cuts). In other words, routine adult dental coverage is already fairly routine. Instead of allowing states to accelerate its normalization, the federal government is proposing to reverse course. Dental advocacy groups made it very clear they oppose this rule during its comment period, which has now closed, leaving us to wait for the verdict of the final rule.

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Visualizing key trends from the healthcare industry

The MDI Effect: Putting the Mouth Back in the Body
Starting with medical school and extending through nearly every aspect of the practice of medicine, from care delivery to insurance billing, the teeth are treated as if they are a separate part from the rest of our body. As any good dentist would tell you, this artificial separation is far from harmless, because oral health has a robust, two-way connection to systemic health. Medical-dental integration (MDI) offers an obvious, yet surprisingly rare, solution to this problem: medical and dental professionals sharing information and coordinating care with each other to improve the health of the population. Those that have taken this leap are reaping the financial, quality, and growth benefits, but too few organizations are taking advantage of MDI.

The case MDI can make to overcome the deep-rooted inertia that has kept dentistry practicing separately from the rest of the medicine is strong and simple:

Oral and systemic health share many risk factors and preventive benefits.
Patients are recommended to see their dentist twice a year for cleanings, versus seeing their PCP only once a year for annual physicals.
Any systemic conditions detected during these integrated dentist visits can be treated earlier, leading to cost savings and better outcomes.
Patients benefit from the convenience of accessing dental and primary care at once, generating consumer loyalty.

What an integrated practice looks like can vary from basic co-location to holistic collaboration, but more integration tends to result in stronger benefits.

To learn more about the budding field of MDI, we decided to talk to some experts in the field:

Dialing In

Sharing insights from our work with clients

Three Questions with the founders of Olive Tree Advisory Group:
Mark Schafer, MD, Randy Roisman, and Laurie Sicaeros
Olive Tree Advisory Group is a boutique healthcare consulting group whose expertise includes helping health systems and large medical groups design, develop, and implement medical-dental integrated (MDI) clinics.

1.) Why are medicine and dentistry separated in the first place?
MS: It all goes back to education, which has some historical explanation from back when we were first establishing our medical and dental schools. But now, the separation of oral health from the rest of medicine is just an unquestioned fact of medical life. When I was in medical school, I received almost no training on oral health or how dental conditions affect the rest of the body. Most doctors simply are not taught about the oral-systemic connection or what medical-dental integration even means. Dental schools teach more about the body than medical schools teach about the teeth, which makes it easier to pitch dentists on the benefits of MDI. That’s why they love to make the joke to physicians, “Did you know the teeth and mouth are actually a part of the body?”

In real practice, though, the connection is clear. There are research studies that document the link between periodontal disease and diabetes, cardiovascular risk, fertility, pregnancy-related concerns, Alzheimer’s, and multiple types of cancer. For example, preventive dental care during pregnancy alone has been associated with better maternal outcomes. Medical-dental integration supercharges collaboration and creates deep integration and uses that to improve patient care.

2) What inspired you to integrate medical and dental practices, and how have you operationalized it?
RR: The idea came from nearly two decades of experience leading a very large, multi-specialty dental group in the Los Angeles area. Many of those patients had complicated medical histories, which meant we were frequently consulting with the patients’ physicians before certain dental procedures.

Over time that raised a bigger question. If we are already coordinating care informally, why is the system not designed to support that collaboration?

I spent years studying the oral-systemic connection. After I transitioned to the medical side of healthcare in 2013, my focus shifted from essentially academic research to how integration could work at scale. Dr. Schafer, Laurie, and I found each other working together at a health system, and when we started exploring various integration options, we looked at different operational models such as building clinics, acquiring practices, or forming joint ventures. Ultimately, we successfully created one of the first integrated medical-dental practice models in the country, which served as the blueprint and proof of concept for the work we do at Olive Tree.

The health systems that tend to be a good fit are financially stable, interested in growth and a larger footprint, and led by teams thinking strategically about diversification, both in terms of service lines and revenue streams. It does not necessarily need to be a hospital system. A large medical group with a strong primary care footprint, multiple specialties, and a strong patient base is often enough.

3) Why should health systems pursue medical-dental integration, and what roadblocks should they expect?
LS: The value shows up in several ways. For health systems and large medical groups, medical-dental integration creates a broader strategic opportunity. MDI is about more than just care coordination. You can also see it as a thoughtfully adjacent service line, a new access point for patient acquisition and retention, and a way to diversify revenue while staying aligned with whole-person care and value-based objectives.

Regarding patient access, healthy patients who are on top of their care typically see their physician only once a year, while they see their dentist every six months. That creates more opportunities to identify issues early. You also cast a larger net for patients who struggle to access care. Roughly 30 percent of primary care patients do not have a regular dentist, and similarly many dental patients do not have a primary care physician.

For health systems, integration supports population health and value-based care by improving outcomes and reducing cost of care. Systems focused on growth can also benefit by expanding services, reaching new patients, and opening new clinics. Also, coming from a strategy role in health systems, I could not believe the margins dental practices typically run. A 15 to 20 percent operating margin is very reasonable for dental practices, whereas at a health system, it is a sign we need to check our math again!

The biggest roadblocks are structural. Medicine and dentistry still operate as separate industries. Electronic health records do not always line up, although there are now solutions for that. Some dental groups worry about losing independence, and there can be cultural challenges on the health system side, as well. We are not saying the integration is easy, only that it is very much worth it. When done well, medical-dental integration strengthens the overall enterprise.

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