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Heath: 

It is at times impossibel to determine the need for surgical extraction.  anyone who has taken out teeth for any length of time has been humbled by an extraction that was much more difficult that initially planned.  the unnecessary burden or preapproval for surgical extraction will cause delay to patient care due to requiring a consult for preapproval ultimately wasting time, money and tax payer dollars.

Sharon:

What do we do for someone that is in office with severe pain? Do we still need a prauth?

Creed:

Key Concerns- Delayed Care – Prior authorization can delay treatment for days or weeks, allowing pain and infection to worsen and increasing treatment complexity and risk.
Increased ER Use – When dental care is delayed, patients often seek emergency care, which provides only temporary relief and leads to repeat visits and higher system costs.
Higher Overall Costs – Delays can turn routine extractions into hospital-based cases requiring anesthesia, IV antibiotics, or admission—far more expensive than timely outpatient care.
Greater Medical Risk – Untreated infections can progress to serious conditions such as cellulitis, airway compromise, or sepsis, increasing morbidity and mortality.
Reduced Rural Access – Rural and low-income patients already face limited access. Added authorization requirements increase delays, travel burdens, and missed work, worsening disparities.
Requiring prior authorization for complex dental extractions delays essential care, increases emergency department use, raises total healthcare costs, and harms patient outcomes. Cost controls should preserve timely access to medically necessary treatment.
This policy risks reducing provider participation at our 45+ offices, directly harming Oklahoma patients.

Eric:

Preauthorization of surgical extractions will only hurt the patients.  This will increase ER visits and cost medicaid more money.  Simple solution is to pay simple and surgical extractions the same then there's no risk of upcoding and the costs of auditing for extactions basically go away.  It blows my mind the discrimination that general dentists can't be trusted as much as an oral surgeon when it comes to extractions. By volume I'm sure you see that general dentists are helping the medicaid patients more than all specialists combined and now we are trying to restrict their ability to care for the patients in a timely manner.  Also how can you predict via an xray whether a tooth will come out simply or surgically?  In my personal experience you cannot. Some teeth break, some bone is considerably harder than others. Its just creating more work for OHCA staff and providers but really it just punishes the patients. Easy solution: Make surgical and simple pay the same rate.

Nick:

Delayed Care – Requiring prior authorization delays treatment for days or weeks, allowing pain and infection to worsen, increasing treatment complexity and risk.

Increased ER Use – When dental care is delayed, patients often seek emergency care, which rarely fixes the source of the problem and leads to repeat visits and higher system costs.

Higher Overall Costs – Delays can turn routine extractions into hospital-based cases requiring anesthesia, IV antibiotics, or admission—far more expensive than timely outpatient care.

Reduced Rural Access – Rural and low-income patients already face limited access. Added authorization requirements increase delays, travel burdens, and missed work, worsening disparities. This also causes friction between the patient and dentist because the patients are often in pain and want resolution same day. When we explain to them that we require pre-authorization, frustration mounts and relationships are broken.

Conclusion- Requiring prior authorization for complex dental extractions delays essential care, increases emergency department use, raises total healthcare costs, and harms patient outcomes. This potential change will risk providers no longer wanting to participate or see Oklahomans in need. 

Brandon:

Requiring prior authorization for complex dental extractions creates unnecessary delays in care and leads to worse outcomes for patients. Authorization delays can allow pain and infection to progress, turning what should be routine procedures into more complex and higher-risk situations.

When dental care is delayed, many patients seek treatment in the emergency department, where they receive only temporary relief. This results in repeat ER visits and increased costs without addressing the underlying problem. Delays also increase overall healthcare spending, as extractions that could be completed safely in an outpatient dental setting may escalate into hospital-based cases requiring anesthesia, IV antibiotics, or admission.

From a medical standpoint, untreated dental infections can progress to serious conditions such as cellulitis, airway compromise, or sepsis. These risks disproportionately affect rural and low-income patients, who already face limited access to dental care and additional barriers related to travel, missed work, and scheduling.

There has also been a significant increase in audits related to surgical versus simple extractions, with surgical extractions frequently being down-coded. Our hope is that this proposed 

Loren:

Requiring prior authorization for surgical extractions—especially when more than one tooth is involved—will negatively impact patient care, access, and overall costs to the State of Oklahoma.

Dental infections and severe pain often require same-day treatment. Delaying extractions while awaiting authorization increases the risk of worsening infection, emergency room visits, and unnecessary antibiotic use. Many Medicaid patients face transportation, work, and childcare barriers, making return visits difficult and leading to incomplete care.

Whether an extraction is surgical is frequently determined chairside after evaluation and imaging. Removing real-time clinical judgment interferes with appropriate treatment and creates a lower standard of care for Medicaid patients compared to others.

This added administrative burden will likely push more dentists to stop accepting Medicaid, further limiting access. Reduced dental access shifts patients to emergency departments, which is more expensive for the state and results in worse outcomes for patients.

I urge the agency to reconsider this proposal and prioritize timely, clinically appropriate care that keeps patients out of the ER and preserves provider participation.

Jeffrey:

my concern for the patients I see in rural Northeast Oklahoma is the concern of pre-authorization for surgical extractions. I see a lot of desperate patients that have a difficulty getting to the clinic and having the flexibility to treat patients to the best of our abilities when they present themselves to the clinic whether that be one extraction or seven extractions, I think is a pertinent consideration. 

Shanon:

Delaying dental extractions shifts care into emergency rooms, increasing healthcare spending and worsening patient prognosis, to the point of life threatening infections. I encourage the agency to pursue policies that allow dentists to treat patients without unnecessary delay.

Benjamin:

Thank you for the opportunity to provide feedback on the proposed prior authorization requirements. While we understand the goal of cost-containment, we have significant concerns regarding the unintended clinical and financial consequences of delaying essential dental care.

Our primary concerns are outlined below:

1. Clinical Risks and Delayed Access to Care Prior authorization often delays treatment by days or even weeks. During this window, acute dental issues—such as pain, swelling, and localized infection—frequently worsen. This delay not only increases the medical risk to the patient but also significantly increases the complexity of the eventual surgical intervention.

2. Escalation of System-Wide Costs

Delaying timely extractions often leads to "downstream" costs that far exceed the price of the initial procedure:

Emergency Room Utilization: Patients in pain frequently seek help at ERs. These visits typically provide only temporary relief (antibiotics/analgesics) without addressing the root cause, leading to recidivism and high hospital billing.

We are writing to express serious concerns regarding prior authorization requirements for dental extractions. While intended for cost-control, this policy creates several critic

Madison:

Prior authorization requirements can delay care, causing pain and infection to worsen leading to increased risk and complexity of treatment. Untreated dental infections may progress to serious, life-threatening conditions such as cellulitis, airway compromise, or sepsis, increasing morbidity and mortality. Treatment delays can escalate routine extractions into hospital-based procedures requiring anesthesia, IV antibiotics, or inpatient admission which is significantly more costly than prompt outpatient care.

Without timely dental care, patients often turn to emergency departments, where they receive only temporary relief. This leads to repeat visits and higher overall healthcare costs.

Rural and underserved communities already face significant access barriers. More authorization requirements increase delays, travel burdens, and missed work, further deepening health disparities.

In conclusion, requiring prior authorization for complex dental extractions delays medically necessary care, increases emergency department use, raises overall healthcare costs, and negatively impacts patient outcomes. These changes also risk discouraging provider participation ultimately reducing access to care for Oklahomans who need it most.

Kellan:

Concerns Regarding Proposed Prior Authorization for Surgical Extractions

Treatment Delays – Requiring prior authorization can postpone care by days or weeks, allowing pain and infection to progress, increasing clinical complexity and patient risk.

Increased Emergency Department Utilization – When timely dental treatment is unavailable, patients often turn to emergency rooms for temporary relief, resulting in repeat visits and higher healthcare system costs.

Escalating Overall Costs – Delays may convert straightforward outpatient extractions into hospital-based procedures requiring anesthesia, intravenous antibiotics, or inpatient admission, significantly increasing expenses.

Heightened Medical Risk – Untreated dental infections can advance to serious, potentially life-threatening conditions such as cellulitis, airway compromise, or sepsis.

Worsened Access for Rural and Low-Income Patients – Populations already facing access barriers are disproportionately affected. Additional authorization requirements increase delays, travel demands, and lost work time, deepening existing disparities.

Conclusion

Mandating prior authorization for complex dental extractions delays medically necessary care, increases emergency department use, 

Granger:

Authorization delays shift care from dental offices to emergency departments. ER treatment for dental disease is costly, temporary, and often repeated. Timely dental care is safer for patients and far more cost-effective. This proposal should be reconsidered in light of its impact on patient outcomes and costs.

Anvy:

I strongly urge to reconsider the proposed requirement for prior authorization for surgical extractions. This will create significant barriers to timely dental care and will negatively impact the wellbeing of the patients. Dental pain and infection are often urgent conditions. Many patients present with severe pain, swelling, abscess or risk of systemic infection that require immediate treatment. Requiring preauthorization will delay necessary care, prolong patient suffering, and increase the risk of complications that could otherwise be prevented with prompt treatment. Kindly request the authorities to reconsider this policy.

Jaden:

There are several concerns I have with this change as a oral health care provider (DMD):

- Delays care for patients in pain or with active infection

- Worsens clinical outcomes by allowing infections to progress

- Drives patients to emergency rooms for dental problems

- Increases healthcare costs for the state

- ERs cannot provide definitive dental treatment

- Leads to repeat ER visits rather than resolution

- Interferes with real-time clinical judgment

- Adds administrative burden without clear benefit

- Discourages dentist participation in Medicaid

- Reduces access to timely dental care

- Increases reliance on antibiotics instead of definitive treatment

- Creates a lower standard of care for Medicaid patients

Please reconsider this change as it would effect patients more then you would know.

Fatima:

I am writing to testify against Prior Authorization (PA) for Medicaid dental services. PA is a barrier that harms patients and the healthcare system.

1. Patient Harm: PA delays care for those in acute pain or with active infections. These delays allow infections to progress into systemic issues, requiring more invasive and costly interventions. This creates a lower standard of care for Medicaid patients.

2. Systemic Inefficiency: When care is delayed, patients are driven to Emergency Rooms. ERs cannot provide definitive dental treatment; they offer only palliative care (antibiotics/painkillers), leading to repeat visits and higher state costs. Furthermore, PA increases reliance on antibiotics, undermining antibiotic stewardship.

3. Provider Burden: Administrative hurdles discourage dentists from participating in Medicaid, worsening the provider shortage. PA interferes with real-time clinical judgment, allowing administrators to override licensed professionals.

I urge the committee to eliminate PA for dental services to ensure timely, definitive care and reduce long-term costs

Samuel:

Many surgical extractions are urgent and cannot safely be postponed. Infections, swelling, and severe pain often require immediate intervention. A preauthorization requirement risks delaying emergent care that should be addressed promptly to prevent complications, hospital admissions, or the need for more extensive treatment.

Requiring preauthorization for surgical extractions will further delay necessary treatment. When patients in pain are unable to receive timely dental care, they are more likely to seek help in hospital emergency rooms, increasing overall healthcare spending without improving outcomes.

Emergency room visits for dental pain are costly to the state and ineffective at resolving the underlying problem. Emergency departments cannot provide definitive dental treatment and typically manage these patients with antibiotics and pain medication, which only delays care and often leads to repeat visits.

This policy would negatively impact patient care while increasing costs for the state. I respectfully urge you to reconsider this proposal and support policies that allow timely access to necessary dental treatment, improve patient outcomes, and reduce unnecessary healthcare spending.

Hannah:

Requiring preauthorization for dental extractions is severely detrimental, primarily by delaying care for patients in pain or with active infection, which ultimately worsens clinical outcomes by allowing infections to progress. This barrier often drives patients to emergency rooms for dental problems, which, increases healthcare costs for the state since ERs cannot provide definitive dental treatment and this often leads to repeat ER visits rather than resolution. For providers, the requirement interferes with real-time clinical judgment and adds administrative burden without clear benefit, thus discouraging dentist participation in Medicaid and reducing access to timely dental care. The result is a reliance on temporary fixes like antibiotics instead of definitive treatment, which effectively creates a lower standard of care for Medicaid patients.

Davis:

Requiring preauthorization for complex dental extractions would be a harmful policy that delays necessary care for patients who are often already in significant pain or suffering from active infection, where time-sensitive treatment is critical. Such delays allow infections to worsen, increasing the risk of systemic complications, avoidable hospitalizations, and long-term health consequences that could have been prevented with timely definitive care. Importantly, dentists often cannot determine with certainty whether an extraction will be complex in advance—while some cases are clearly difficult, others become complicated unexpectedly when a tooth fractures, roots curve, or unforeseen issues arise during the procedure. When dental treatment is postponed, patients are frequently driven to emergency rooms, which are ill-equipped to manage dental disease beyond temporary measures such as pain control or antibiotics. ERs cannot provide definitive dental treatment, leading to repeat visits that fail to resolve the underlying problem while significantly increasing healthcare costs for the state. This cycle promotes inappropriate reliance on antibiotics instead of definitive surgical care, contributing to antibiotic resistance and poorer

Brett:

I am a dentist in Tulsa, and I have been seeing Medicaid patients for 12 years. These are the negatives I see with this policy.

-Delays care for patients in pain or with active infection -Worsens clinical outcomes by allowing infections to progress -Drives patients to emergency rooms for dental problems -Increases healthcare costs for the state -ERs cannot provide definitive dental treatment -Leads to repeat ER visits rather than resolution -Interferes with real-time clinical judgment -Adds administrative burden without clear benefit -Discourages dentist participation in Medicaid -Reduces access to timely dental care -Increases reliance on antibiotics instead of definitive treatment -Creates a lower standard of care for Medicaid patients Please DO NOT do this, this will only drive more providers  away. 

Andrew:

Concerns

Delays care for patients in pain or with active infection Worsens clinical outcomes by allowing infections to progress Drives patients to emergency rooms for dental problems Increases healthcare costs for the state ERs cannot provide definitive dental treatment Leads to repeat ER visits rather than resolution Interferes with real-time clinical judgment Adds administrative burden without clear benefit Discourages dentist participation in Medicaid Reduces access to timely dental care Increases reliance on antibiotics instead of definitive treatment Creates a lower standard of care for Medicaid patients

Chad:

As a Medicaid dental provider, I strongly oppose the Oklahoma Health Care Authority’s proposed rule requiring prior authorization for complex (surgical) dental extractions. These procedures are often medically necessary and time-sensitive. Delays for patients with infection or severe pain allow conditions to worsen, increasing the risk of hospitalization.

This policy will push patients into emergency rooms, which cannot provide definitive dental treatment. Instead, patients receive temporary care such as antibiotics and pain medication, leading to repeat ER visits and higher costs for taxpayers.

Prior authorization interferes with real-time clinical judgment, adds administrative burden, and creates a lower standard of care for Medicaid patients. It will further discourage participation and cause more providers to stop accepting Medicaid, reducing access to timely dental care statewide.

Rather than saving money, this rule is likely to increase overall Medicaid spending while harming patients, providers, hospitals, and taxpayers. I urge OHCA to reconsider.

Matthew:

I urge you to oppose the proposal to require prior authorization for Medicaid dental services in Oklahoma. This policy would delay necessary care, worsen patient outcomes, and increase costs to the state.

Medicaid dental care frequently involves patients in severe pain or with active infection. Delaying treatment allows disease to progress, increasing the risk of serious and preventable complications. Prior authorization interferes with real-time clinical judgment and replaces timely care with administrative delay.

When dental care is delayed or denied, patients seek treatment in emergency rooms. ERs cannot provide definitive dental care and typically offer only temporary pain relief or antibiotics. This leads to repeat ER visits, unresolved infection, and significantly higher costs than treatment provided in a dental office.

Prior authorization also promotes unnecessary antibiotic use instead of definitive care, contributing to antibiotic resistance. The added administrative burden discourages dentist participation in Medicaid, reducing access to care—especially in rural and underserved areas.

Most concerning, this policy creates a lower standard of care for Medicaid patients compared to those with private insurance, worsenin

Adam:

This rule will further increase the regulatory and administrative burden on already overworked dental practices. Ultimately, it will drive more providers to stop participating in the program, which may the be goal. My key concerns:

Delays care for patients in pain or with active infection Worsens clinical outcomes by allowing infections to progress Drives patients to emergency rooms for dental problems Increases healthcare costs for the state ERs cannot provide definitive dental treatment Leads to repeat ER visits rather than resolution Interferes with real-time clinical judgment Adds administrative burden without clear benefit Discourages dentist participation in Medicaid Reduces access to timely dental care Increases reliance on antibiotics instead of definitive treatment Creates a lower standard of care for Medicaid patients

Nate:

I think that it would be very difficult to apply this rule change. Having prior authorizations for surgical extractions is going to make it more difficult for these individuals to receive the care that they need. There are multiple instances where patients have pain in multiple areas of their mouth and want to have extractions done in different quadrants. Having to wait for a preauthorization before treating these patients because some of the extractions may need to be surgical is going to hinder the process and care given.

Colby:

As a treating doctor, my primary concern is that prior authorization will delay necessary care—sometimes by days or weeks. During these delays, I frequently see patients’ pain, swelling, and infections worsen, increasing medical risk and treatment complexity.When timely dental care is unavailable, patients often seek help in emergency departments, where only temporary relief through pain medication or antibiotics is typically provided. This leads to repeat visits, ongoing patient suffering, and higher overall healthcare costs.Delays can also turn routine outpatient procedures into hospital-based surgical cases. I have seen patients require IV antibiotics, anesthesia, or inpatient admission—costs that far exceed those of timely extractions.Untreated dental infections are not benign. Delayed care increases the risk of serious, potentially life-threatening complications, including cellulitis, osteomyelitis, airway compromise, and sepsis.These issues disproportionately affect rural and low-income patients who already face barriers to specialty care. For these reasons, I believe prior authorization for complex dental extractions risks delaying essential care, increasing emergency department use,raisingcosts,andworseningpatientoutcomes

Karla:

I am a Medicaid dental provider and am very concerned about the upcoming changes and their impact on patient care. These changes will delay treatment for patients in pain or with active infection, allowing conditions to worsen and leading to poorer clinical outcomes. Patients will be pushed into emergency rooms, which cannot provide definitive dental care and often result in repeat visits rather than resolution, increasing healthcare costs for the state.

These policies interfere with real-time clinical judgment, add administrative burden without clear benefit, and encourage reliance on antibiotics instead of definitive treatment. They create a lower standard of care for Medicaid patients, discourage dentist participation in Medicaid, and reduce access to timely dental care. I urge reconsideration of these changes to protect patients and preserve access to care.

James:

I am a soonercare dental provider. Surgical extractions should not require prior authorization because they often address acute pain, active infection, or urgent dental issues where delays can harm patients.

Requiring pre-approval delays care for those in severe pain or with progressing infections, worsening clinical outcomes and increasing risks like abscesses or systemic spread.

This forces patients to seek treatment in emergency rooms, where ERs provide only temporary relief (e.g., antibiotics, pain meds) without definitive dental care, leading to repeat visits, unresolved problems, and higher overall healthcare costs for the state.

Prior authorization interferes with real-time clinical judgment by dentists, adds unnecessary administrative burden without proven benefit, and discourages provider participation in Medicaid—reducing access to timely care.

It promotes over-reliance on antibiotics instead of extraction (the definitive treatment), creating a lower standard of care for Medicaid patients compared to others.

Exempting surgical extractions from prior auth aligns with emergency exemptions in many programs and prioritizes patient health over bureaucracy.

Cooper:

It would be a problem for patients, dentists and practices.  More patients will end up in the emergency room, it'll end up costing the State more money. And more patients will be disadvantaged because of this policy.   

Deboria:

When dental care is delayed, patient suffering increases and infections worsen. Many patients turn to emergency rooms when pain becomes unbearable, driving up state costs without solving the underlying problem. I encourage the agency to remove this proposed barrier to timely dental care.

Brandon:

Requiring prior authorization for complex dental extractions creates significant delays in care, often pushing treatment back days or even weeks. During this time, pain and infection can worsen, making what should be routine procedures more complicated and risky. When timely dental care is not available, many patients turn to emergency departments, where they receive only temporary relief and frequently return, driving up overall healthcare costs. Delayed treatment can also cause infections to progress to serious, potentially life-threatening conditions such as cellulitis, airway compromise, or sepsis, increasing medical risk for patients. These impacts are especially harmful for rural and low-income populations, who already face limited access to dental services. Additional authorization requirements add travel burdens, missed work, and further delays, worsening existing disparities. Ultimately, prior authorization for complex extractions does not reduce costs or improve outcomes; instead, it increases system-wide expenses, harms patients, and risks discouraging providers from participating in care for Oklahomans who need it most.

Julian:

Delayed and Worsened Care – Requiring prior authorization for surgical extractions can postpone treatment by days or weeks, during which time pain and infection may progress, increasing procedural difficulty, complications, and risk to the patient.

Increased Emergency Department Utilization – When timely dental treatment is unavailable, patients often turn to emergency departments, which typically provide only temporary relief rather than definitive care, resulting in repeat visits and unnecessary strain on the healthcare system.

Higher Total Healthcare Costs – Delays in care can convert straightforward outpatient extractions into complex hospital-based interventions requiring general anesthesia, IV antibiotics, or inpatient admission, significantly increasing overall costs compared to prompt treatment.

Elevated Medical Risk – Untreated odontogenic infections can advance to serious and potentially life-threatening conditions such as cellulitis, deep space infections, airway compromise, or sepsis, increasing morbidity and mortality.

Disproportionate Impact on Rural and Underserved Patients

Kaitlyn:

To whom it may concern,

Please reconsider the potential requirement for prior authorization for more than 2 surgical extractions to be completed in one day. Doing so would be a great disservice to our patients and to our OHCA population. Doing so would greatly delay needed treatment for our patients. Many of our patients travel to get to us, and many of them require multiple extractions-often needing a combination of simple and complex extractions. The ability to provide these services same day without prior authorization allows us to better serve our community and their dental needs. Thank you. 

Ashley:

Requiring prior authorization for surgical extractions delays treatment for patients who are often in severe pain or have active infection. When care is postponed, infections worsen and patients frequently seek relief in emergency rooms. ERs cannot provide definitive dental care and are far more expensive than treatment in a dental office, increasing costs for the state and worsening outcomes for patients. I strongly urge the agency to reconsider this requirement for surgical extractions. Working in an area that is already extremely underserved, this creates yet another challenge, for both patients and doctors. I also question the ability of someone behind a computer to determine what makes an extraction simple or surgical. Dentistry is not this predictable. 

Van:

I am a Medicaid provider and I believe prior authorization (PA) for complex dental extractions is a BAD idea for patient safety. I urge the REFUSAL of this mandate for the following reasons: Delayed Care & Poor Outcomes: Infections are progressive. Forcing patients in pain to wait for approval allows localized issues to become systemic emergencies.

ER Over-utilization: When dentists cannot act, patients turn to ERs. Hospitals cannot provide definitive dental treatment, leading to a costly cycle of palliative care and repeat visits that drain state resources.

Clinical Interference: Surgeons must be able to pivot from simple to surgical extractions mid-procedure based on real-time complications. PA punishes clinicians for acting in the patient’s best interest.

Access Crisis: The administrative burden discourages Medicaid participation, shrinking the provider network and creating a lower standard of care for vulnerable populations.

PA mandates for extractions do not save money; they simply shift costs to emergency departments and worsen public health. We must allow for timely, definitive treatment.

Joel:

These are my key concerns for these updates needing pre-auths for extractions:

Delays care for patients in pain or with active infection.

Worsens clinical outcomes by allowing infections to progress.

Drives patients to emergency rooms for dental problems.

Increases healthcare costs for the state.

ERs cannot provide definitive dental treatment.

Leads to repeat ER visits rather than resolution.

Interferes with real-time clinical judgment.

Adds administrative burden without clear benefit.

Discourages dentist participation in Medicaid.

Reduces access to timely dental care.

Increases reliance on antibiotics instead of definitive treatment.

Creates a lower standard of care for Medicaid patients.

Devin:

This is not a good idea.

If our primary purpose is to ensure appropriate billing, then honestly the standards need to be expanded not lessened. As a Medicaid provider, the only Medicaid dentist in Blanchard, I find it is already tough to tell patients that I can’t address all of their emergent issues at the time of their visit, and now the idea is to make it even harder for them?

This would definitely lead to me no longer accepting this form of insurance. Not to mention all of the following reasons:

Delays care for patients in pain or with active infection Worsens clinical outcomes by allowing infections to progress Drives patients to emergency rooms for dental problems Increases healthcare costs for the state ERs cannot provide definitive dental treatment Leads to repeat ER visits rather than resolution Interferes with real-time clinical judgment Adds administrative burden without clear benefit Discourages dentist participation in Medicaid Reduces access to timely dental care Increases reliance on antibiotics instead of definitive treatment Creates a lower standard of care for Medicaid patients

Callum:

As a Medicaid dental provider, I strongly oppose the Oklahoma Healthcare Authority’s proposed rule requiring prior authorization for complex or “surgical” dental extractions. While intended to control costs, this policy will likely restrict access to medically necessary care and increase overall healthcare spending.

Complex extractions are often time-sensitive and commonly involve active infection, abscesses, or progressive dental disease. Delays caused by prior authorization can allow conditions to worsen rapidly, increasing the risk of facial cellulitis, systemic infection, hospitalization, or emergency room visits. What could be treated efficiently in a dental office may escalate into a medical emergency.

Additionally, whether an extraction becomes “surgical” is frequently determined during the procedure and cannot always be predicted in advance. Requiring prior authorization creates unnecessary administrative barriers, delays care, and interferes with clinical judgment.

This policy will disproportionately harm Medicaid patients, who already face access challenges. Dental extractions performed in-office are far less costly than ER visits, hospital admissions, or operating room procedures.

Please reconsider this change.

Garrett:

I urge the OHCA to withdraw the proposal requiring prior authorization for complex dental extractions. Every day, patients come in with severe pain, swelling, and infections that can worsen within hours. Delaying treatment while waiting for approval means unnecessary suffering and real medical danger—these infections can spread quickly and even become life-threatening. When care is delayed, patients end up in emergency rooms that can only offer pain meds and antibiotics, not the treatment they truly need. This rule would increase costs, prolong pain, and make patients feel forgotten by a system meant to protect them. Dentists need the ability to act immediately when someone is in distress. Please reconsider this policy and work with providers to protect timely, compassionate care for Oklahomans in pain.

Gregg:

Dental infections worsen when treatment is delayed. Prior authorization requirements increase emergency room visits, which are far more expensive than dental care and often fail to resolve the issue. The agency should reconsider this policy to avoid unnecessary harm and cost.

Kevin:

Emergency departments are not designed to manage dental disease. Authorization delays increase ER utilization and healthcare costs while leaving patients without definitive treatment. I urge the agency to allow dentists to provide necessary care without prior approval. This will delay treatment and cause suffering to a segment of society that is neglected already. Please don’t do this to the poor.

Jim:

I strongly oppose the proposed the OHCA prior authorization requirement for surgical dental extractions. It compromises patient safety by delaying care for patients in pain or with active infection, allowing infections to progress and worsening clinical outcomes. This action interferes with real-time clinical judgment and increases reliance on antibiotics instead of definitive treatment.

The administrative hurdle drives patients to emergency rooms for dental problems. Since ERs cannot provide definitive dental treatment, this policy increases healthcare costs for the state and leads to repeat ER visits rather than resolution.

Furthermore, it adds administrative burden without clear benefit, discourages dentist participation in Medicaid, and reduces access to timely dental care, thereby creating a lower standard of care for Medicaid patients.

Colwin:

I agree with the revision on the full mouth series because you would need more than just two bitewings and a pano to accurately diagnose caries on radiographs due to the lack of minute detail from a pano. As for the complex extractions, patients experiencing severe dental pain often have no choice but to seek emergency care when treatment is delayed. These visits increase costs and time without resolving the problem. Please consider removing this barrier to prompt dental treatment.

James:

This proposed policy is counterproductive and harmful to both patients and the healthcare system. Delaying necessary dental treatment does not reduce costs; instead, it shifts them. When patients with severe oral disease or acute pain are forced to wait for authorization, their conditions worsen, leading them to seek relief in hospital emergency rooms. ERs are ill-equipped to provide definitive dental care, resulting in temporary treatments, repeat visits, and significantly higher costs to Medicaid than timely outpatient dental extractions. Emergency rooms across the country are already operating at or beyond capacity. Adding preventable dental emergencies further strains limited resources and diverts care from true medical emergencies. This approach undermines efficient healthcare delivery rather than improving it. Additionally, it creates administrative burdens that discourage dentist participation in Medicaid programs. Complex extractions already involve clinical judgment and risk; adding delays, paperwork, and uncertainty makes Medicaid participation less viable for many providers. As fewer dentists participate, access to care declines, worsening oral health disparities for vulnerable populations.

Theodore:

The increase in required PAs will lead to increased radiation dose for our patients because a pano will still be taken and now unnecessary PAs will be taken instead of only when the pano indicates the need for one. And requiring pre-auth for surgical extractions will make it not possible to remove painful wisdom teeth immediately leading to more pain for patients and more office visits increasing overall cost of treatment.

Joseph:

To the OHCA Board:

I am writing to address the critical barriers created by current dental prior authorization requirements. These mandates compromise patient safety and drive up state costs in the following ways:

Clinical Risk: Delays in care allow active infections to progress to systemic emergencies. Providers are forced to rely on repeat antibiotics rather than definitive treatment, fueling antibiotic resistance.

ER Strain: Patients in pain cannot wait for administrative approval and often seek help in ERs. Because ERs cannot provide definitive dental care, this creates a "revolving door" of palliative treatment and repeat visits, significantly increasing state healthcare expenditures.

Provider Obstacles: Burdensome paperwork and interference with real-time clinical judgment discourage dentist participation in Medicaid, further reducing access.

Standard of Care: These hurdles create a lower standard of care for SoonerCare members compared to private-pay patients.

I urge the OHCA to waive prior authorizations for acute pain and infection to allow for immediate, definitive care.

Ashton:

Huge concerns here!

these points: Key Concerns

Delays care for patients in pain or with active infection Worsens clinical outcomes by allowing infections to progress Drives patients to emergency rooms for dental problems Increases healthcare costs for the state ERs cannot provide definitive dental treatment Leads to repeat ER visits rather than resolution Interferes with real-time clinical judgment Adds administrative burden without clear benefit Discourages dentist participation in Medicaid Reduces access to timely dental care Increases reliance on antibiotics instead of definitive treatment Creates a lower standard of care for Medicaid patients

Amanda:

I am a Medicaid dental provider submitting this comment to express serious concerns about the proposed administrative rule. The rule will delay care for patients who present with pain or active infection, allowing disease to progress and worsening clinical outcomes. By restricting timely, definitive dental treatment, it will drive patients to hospital emergency rooms for conditions ERs are not equipped to treat. Emergency clinics cannot provide definitive dental care, which leads to temporary measures, repeat ER visits, and higher overall healthcare costs for the state. The rule interferes with real-time clinical judgment and replaces it with administrative barriers that add burden without clear benefit. It encourages reliance on antibiotics rather than definitive treatment, contributing to poorer outcomes and potential antibiotic overuse. These changes create a lower standard of care for Medicaid patients, discourage dentist participation in the Medicaid program, and ultimately reduce access to timely, appropriate dental care for vulnerable populations.

Shaun:

As a Medicare and Medicaid dental provider, I strongly oppose the Oklahoma Healthcare Authority’s proposed rule requiring prior authorization for complex dental extractions. This policy will delay care for patients who are often in severe pain or have active infections, allowing conditions to worsen and increasing the risk of serious complications. Prior authorization interferes with real-time clinical judgment and replaces it with administrative delays that provide no clear clinical benefit.

When definitive dental treatment is postponed, patients are pushed to emergency rooms—settings that cannot provide extractions—resulting in temporary measures, repeat visits, and higher overall costs to the state. This approach increases reliance on antibiotics instead of definitive care, contributing to poorer outcomes and avoidable antibiotic use.

The added administrative burden will discourage dentist participation in Medicaid, further reducing access to timely dental care and creating a lower standard of care for Medicaid patients compared to others. Oklahoma should prioritize prompt, clinician-directed treatment that resolves problems efficiently and humanely, not policies that delay care, increase costs, and harm patients.

John:

Thank you for the opportunity to comment on the proposed rule requiring prior authorization for D7210 extractions. While cost control and program integrity are important, this policy risks delaying medically necessary dental care. Dental infections and acute oral conditions can worsen rapidly, and authorization delays may increase pain, swelling, and risk of infection. When patients cannot access timely dental treatment, they often seek care in hospital emergency departments, which are not equipped to provide definitive dental services and typically offer only temporary relief. These delays can escalate routine outpatient dental care into hospital-based treatment requiring IV antibiotics, surgery, or inpatient admission—substantially increasing overall healthcare costs. Rural and underserved populations, who already face limited access to dental providers, will be disproportionately affected. We respectfully urge reconsideration of this proposal in favor of alternatives that preserve timely access to necessary dental care.

Yousef:

I appreciate the opportunity to submit comments on the proposed requirement for prior authorization of D7210 extractions. While managing costs is a valid goal, delays in dental care can have serious consequences. Dental infections often progress quickly, leading to increased pain and risk of systemic complications. When treatment is delayed, patients frequently turn to emergency departments that cannot provide definitive dental care, resulting in repeated visits and higher costs. Authorization delays may also transform outpatient dental procedures into hospital admissions requiring surgical intervention or IV antibiotics. These outcomes undermine the proposal’s intended cost savings. The burden of these delays will fall most heavily on rural and low-income patients who already face access barriers. I respectfully recommend reevaluating this proposal.

Jay:

Thank you for allowing public comment on the proposed dental policy changes. Requiring prior authorization for D7210 extractions is likely to delay necessary care and negatively affect patient outcomes. Dental infections can deteriorate rapidly without prompt treatment, increasing the likelihood of emergency department visits. Emergency rooms are not designed to provide definitive dental care and typically offer only temporary relief, leading to inefficient use of healthcare resources. Delays can also result in more serious medical complications that require hospitalization, increasing overall costs. Rural and underserved populations will be disproportionately impacted by additional administrative barriers. I urge the agency to reconsider this proposal and explore alternatives that ensure timely access to essential dental services.

Casey:

The proposed requirement for prior authorization of D7210 extractions introduces significant legal and liability risk by knowingly delaying time-sensitive treatment for active dental infections. When a policy predictably causes delays that allow infections to worsen, resulting complications such as hospitalization, airway compromise, or sepsis are foreseeable outcomes. Emergency departments cannot provide definitive dental treatment, yet delayed patients would be routinely redirected there, increasing the risk of adverse events without resolving the underlying condition. Policies that create systemic barriers to medically necessary care expose the state to avoidable legal scrutiny, particularly when harm results from administrative delay rather than clinical judgment. These risks are amplified for rural and underserved populations who already face limited access and longer wait times. A policy that increases the likelihood of preventable harm while offering no clear clinical benefit should be reconsidered before exposing the state to unnecessary liability.

Khalid:

Requiring prior authorization for D7210 extractions is likely to increase, not reduce, total program spending. Dental infections requiring extraction do not pause while authorization is pending, and delayed treatment predictably drives patients into emergency departments that cannot provide definitive care. These encounters generate costs for diagnostics, medications, and repeat visits without resolving the problem. As infections progress, patients are more likely to require inpatient admission, surgical intervention, or intravenous antibiotics, all of which carry substantially higher costs than timely outpatient dental care. These downstream expenses will be borne by the state and taxpayers and will quickly exceed any theoretical savings from utilization controls. A policy that shifts care from low-cost dental settings to high-cost medical settings represents a clear fiscal risk and undermines the stated goal of cost containment.

Joseph:

The proposed prior authorization requirement for D7210 extractions poses a clear public health risk by delaying treatment for active dental infections. Dental infections can spread rapidly, increasing the risk of systemic involvement, emergency department utilization, and hospitalization. Emergency departments are not equipped to treat dental disease and typically provide only temporary symptom relief, allowing infections to persist and worsen. Delayed care also increases reliance on antibiotics without source control, contributing to repeat visits and avoidable complications. These outcomes are not rare or speculative; they are predictable consequences of delayed access to dental treatment. Policies that impede timely infection management increase morbidity, strain emergency services, and compromise patient safety. The impact will fall disproportionately on populations already experiencing access barriers. From a public health standpoint, this proposal introduces unnecessary risk and should be reconsidered.

Omar:

From a Medicaid program integrity perspective, requiring prior authorization for D7210 extractions sends a troubling signal. Delaying necessary dental care drives beneficiaries into emergency departments for conditions that should be managed in outpatient dental settings. These visits are costly, inefficient, and inconsistent with value-based care principles. Beneficiaries experience prolonged pain and unresolved infections, while the program absorbs higher medical costs and poorer outcomes. For rural and underserved populations, the added administrative barrier compounds existing access challenges and undermines confidence in the program’s ability to deliver timely care. A policy that predictably increases emergency utilization and hospital admissions weakens the credibility of cost-control efforts and exposes the program to criticism for prioritizing administrative process over patient outcomes. This proposal risks damaging Medicaid’s public standing and should be reconsidered.

David:

The proposed prior authorization process for D7210 extractions reflects a disconnect between administrative policy and clinical reality. Dental extractions for infection are often time-sensitive, yet the authorization process introduces delays that disrupt appropriate care pathways. This administrative friction predictably redirects patients to emergency departments that cannot provide definitive dental treatment, increasing workload without resolution. The result is repeated encounters, duplicated costs, and inefficient use of healthcare resources. Rather than improving oversight, the policy creates operational bottlenecks that shift care into higher-cost settings and generate preventable escalation. Administrative controls that obstruct clinically appropriate treatment represent a system failure. Implementing a policy that increases complexity while degrading outcomes signals poor alignment between program design and real-world delivery and warrants reevaluation.

Joshua:

The proposed prior authorization requirement for D7210 extractions would create delays in the treatment of dental infections that often require timely intervention. When care is postponed, symptoms frequently worsen, increasing pain and medical risk. Patients who are unable to obtain prompt dental treatment often seek relief in emergency departments, where definitive dental services are unavailable. These encounters typically result in temporary symptom management, repeat visits, and escalating costs without resolution of the underlying infection. As conditions progress, patients may require inpatient admission, surgical intervention, or intravenous antibiotics, all of which are significantly more expensive than timely outpatient dental care. These outcomes are foreseeable and largely preventable. Rural and underserved populations face disproportionate impact due to limited access and longer wait times. A policy that increases cost and worsens outcomes should be reconsidered.

Naresh:

Requiring prior authorization for D7210 extractions introduces administrative delays that conflict with the clinical realities of dental disease. Infections requiring extraction can deteriorate rapidly when treatment is postponed. Authorization delays increase the likelihood that patients will turn to emergency departments, which cannot provide definitive dental care. These visits result in temporary relief, unresolved infection, and repeated utilization. As dental conditions worsen, patients may require hospitalization, dramatically increasing healthcare costs. These downstream consequences undermine the stated goal of cost containment and strain limited resources. The impact will be most severe for rural and underserved populations who already experience barriers to access. A policy that shifts care from low-cost dental settings to high-cost medical settings represents an inefficient use of public funds and warrants reconsideration.

Narayan:

I respectfully oppose the proposed prior authorization requirement for D7210 extractions due to its predictable impact on patient care and system costs. Dental infections requiring extraction are time-sensitive and often worsen quickly without treatment. When care is delayed, patients frequently seek assistance in emergency departments that lack dental capabilities, resulting in temporary treatment and repeat visits. These delays increase the likelihood of medical escalation, including inpatient admission, surgery, or intravenous antibiotics. Such outcomes significantly exceed the cost of timely outpatient dental care and are largely preventable. A policy that increases complexity while worsening outcomes does not support effective patient care.

An:

The proposed policy requiring prior authorization for D7210 extractions is likely to produce unintended and costly consequences. Delays in dental treatment allow infections to progress, increasing pain, medical risk, and emergency department utilization. Emergency departments are not equipped to provide dental extractions and typically offer only temporary symptom relief, resulting in unresolved infection, repeat visits, and escalating costs. These outcomes are foreseeable and largely preventable through timely access to dental care. Rural populations will experience the greatest harm due to already limited provider availability. In our practice, patients routinely travel more than one hour each way because no providers in their local area accept Medicaid or are accepting new Medicaid patients. Implementing policies that further restrict access will worsen these challenges. A policy that predictably increases costs while degrading care quality should not be implemented.

Scott:

The proposed requirement for prior authorization of D7210 extractions introduces delays that are inconsistent with effective infection management. Dental infections can progress rapidly when care is postponed. Patients unable to access timely dental treatment often seek care in emergency departments that cannot resolve dental disease. This pattern results in temporary relief, repeat visits, and increased utilization without addressing the underlying condition. As infections worsen, inpatient admission become necessary, significantly increasing costs. These outcomes are predictable and preventable through timely outpatient dental care. Rural and underserved populations will face the greatest impact due to existing access limitations. A policy that increases cost while worsening outcomes should be reconsidered

Landon:

I am concerned that requiring prior authorization for D7210 extractions will delay necessary dental care and increase downstream costs. Dental infections requiring extraction are time-sensitive and often worsen without prompt treatment. Authorization delays increase reliance on emergency departments, which lack the ability to provide definitive dental services. These encounters result in temporary symptom management, unresolved infection, and repeated utilization. As conditions progress, patients may require hospitalization, driving costs significantly higher. These outcomes undermine cost-containment goals and strain healthcare resources. Rural and underserved populations will experience disproportionate harm due to limited access. Reconsideration of this proposal is warranted.

Kellie:

The proposed prior authorization requirement for D7210 extractions poses risks to both patient outcomes and system efficiency. Delays in dental treatment allow infections to worsen, increasing pain and medical risk. Patients frequently seek care in emergency departments when dental services are delayed, despite the lack of definitive treatment options. This leads to repeat visits and escalating costs without resolution. These outcomes are preventable through timely outpatient dental treatment. This policy should be reconsidered.

Tara:

I respectfully submit concern regarding the proposed prior authorization requirement for D7210 extractions. Dental infections requiring extraction often deteriorate when treatment is delayed. Authorization requirements interrupt appropriate care and increase emergency department utilization. Because emergency departments do not provide dental extractions, patients receive only temporary relief and frequently return with worsening symptoms. These delays increase the likelihood of hospitalization or surgical intervention, significantly increasing healthcare costs. These consequences undermine the stated goal of cost containment and disproportionately affect rural and underserved populations with limited access. A policy that shifts care into higher-cost settings through administrative delay should be reconsidered.

Jeromy:

Requiring prior authorization for D7210 extractions introduces delays that are incompatible with the clinical realities of dental infections. These conditions do not improve while authorization requests are pending and often worsen rapidly. When timely dental care is unavailable, patients commonly seek treatment in emergency departments that lack the ability to perform extractions, resulting in temporary symptom management and unresolved infection. This pattern leads to repeat visits, increased medication use, and higher overall healthcare costs. In advanced cases, delayed dental care results in hospitalization or surgical intervention that could have been avoided with prompt treatment. These outcomes are foreseeable and preventable. Implementing this policy would cause unnecessary harm and should not move forward

Karl:

I strongly oppose this and many of the other restrictions that occur with OCHA.  This puts rules and restrictions in front of treating the patient.   As we all know, sometimes things change once we get in there.  By putting restrictions on dentists to adjust as needed, patient care is compromised.

The reimbursement is the lowest around.  Kansas, Texas, Arkansas and Missouri all have better reimbursements.  It is hard to retain and hire dentists when they can go a couple hours away and make more.  Cost of labor, materials and living has all gone up exponentially and yet rates are the same or even being cut.  Its not sustainable and people are suffering.  There are less and less providers willing to take Medicaid and it needs to be more attractive and easier to work with or that is only going to get worse.