In America, more than 67 million1 people are enrolled in Medicare, a government healthcare program that provides coverage to individuals aged 65 and older, individuals with disabilities, and people with end-stage renal disease (ESRD). Traditional Medicare includes Parts A (hospital) and B (physician), and prescription drug coverage is available via Medicare Part D.
Part C, also called Medicare Advantage (MA), is a managed care alternative to traditional Medicare including all Part A and B benefits as well as additional supplemental coverages. For more information on the different parts of Medicare, please see medicare.gov.
Despite having been considered as a potential program addition over the years,2 most dental care is not covered as part of traditional Medicare. Most recently, proposed amendments in 2023 aimed to provide a dental benefit under Medicare Part B but have not moved past an introduction to the House.2 Only dental procedures considered medically necessary as an integral part of covered medical procedures have been covered through traditional Medicare. The 2023 and 2024 Medicare Physician Fee Schedule Final Rules slightly expanded on that, clarifying that such procedures could be in inpatient or outpatient settings and providing applicable clinical situations in which dental procedures would be covered.3 Most dental services for most beneficiaries, however, are still not covered by Medicare Parts A or B. Many MA plans offer supplemental dental coverage to help fill this gap. As of April 2024, more than 33.9 million1 Americans were enrolled in an MA plan representing more than half of Medicare enrollees, making MA dental benefits an important avenue of coverage for that population.
MA beneficiaries have two primary options for accessing dental benefits. MA plans can embed dental coverage as a mandatory supplemental benefit (MSB), which is provided as part of the MA plan at no additional cost to the beneficiary, or they can offer dental coverage as an optional supplemental benefit (OSB), which the beneficiary can choose for an additional separate premium. Plans can offer both mandatory and optional supplemental benefits for more flexibility so that members can opt to purchase greater coverage on top of the plan’s mandatory offerings if they desire. Dental services are among the most common MSB offerings4 and are also included in a majority of OSB packages.
Regardless of whether the dental coverage is offered as a mandatory or optional supplemental benefit, the coverage may include preventive services only or both preventive and comprehensive services. Preventive dental services generally help maintain good oral health via routine oral exams, cleanings, and x-rays. Comprehensive dental benefits include specialty dental services, such as prosthodontics, restorative services, extractions, endodontics, and other procedures. Plans may cover some categories of preventive or comprehensive dental services and not others, resulting in a wide variety of MA dental plan designs.
This whitepaper reviews the dental benefits provided within MA general enrollment plans using 2024 Centers for Medicare and Medicaid Services (CMS) data and explores how the overall MA dental landscape is changing. We examine recent trends in MA dental plan enrollment, scope of dental benefits offered, and dollar coverage limits. This paper includes analysis of general enrollment MA plans only and excludes Special Needs Plans (SNPs) and focuses more closely on mandatory supplemental dental benefits rather than optional. Optional supplemental benefits, including dental, are discussed in the Milliman article Trends in Medicare Advantage optional supplemental benefits.5
Medicare Advantage mandatory supplemental dental enrollment trends
MA general enrollment plans with mandatory dental benefits have grown steadily in popularity, with over 20 million out of 20.6 million total enrollees in general enrollment plans having dental benefits. MA plans offering mandatory supplemental dental benefits offer convenience to beneficiaries who only need to look for a single plan that provides both dental as well as medical coverages, rather than separately seeking dental insurance.
Figure 1: Enrollment in general enrollment MA plans with mandatory dental benefits
Preventive and comprehensive dental benefit trends
Medicare Advantage dental plan benefits are categorized into 11 service types:
- Preventive dental is comprised of oral exams, cleanings, x-rays, and fluoride.
- Comprehensive dental includes diagnostic services, endodontics, periodontics, extractions, oral surgery, prosthodontics (such as dentures), and restorations.
Since 2019, the covered services under MA dental plans have expanded tremendously. We reviewed 2024 covered services and compared with prior years to assess industry trends.
For preventive dental coverage, consistent with 2023, nearly 100% of enrollees have coverage for oral exams, cleanings, and x-rays. Coverage for fluoride has increased, with enrollment in plans with a fluoride benefit at 84% this year compared with 80% in 2023.
Coverage for comprehensive dental service categories started to level off in 2024 after a few years of increases, as indicated in Figure 2. This shift may indicate a few possible market changes:
- As shown in Figure 1, as of 2024, almost all general enrollment MA beneficiaries are in plans with mandatory supplemental dental coverage, so pushing for continually higher MA dental benefits may no longer be as much of a differentiator as it once was.
- After a few years of rapid increases in benefit richness, the MA dental market is experiencing greater induced utilization and may be managing the increased costs by adjusting benefits.
- Similarly, as dental plan richness increased at a rapid pace, so has the price point of that dental coverage. MA plans may be experiencing diminishing returns with further increases in covered services.
- Plans may be right-sizing their dental coverage to make room for other non-dental supplemental benefits.
- Some dental services could be shifting from mandatory to optional supplemental coverage in order to manage the cost of the mandatory supplemental dental plan.
Some MA plans are offered at no premium while others require a premium. Out of all the MA general enrollment plans that include a mandatory supplemental dental benefit in 2024, approximately 76% of members are enrolled in zero-premium plans while the remaining 24% have a non-zero premium. Upon reviewing the proportion of plan enrollment within each type of comprehensive dental service, zero premium MA plans’ mandatory supplemental dental benefits are generally more likely to include each type of comprehensive dental service than non-zero premium plans. This is likely because every additional covered service type in a non-zero premium plan would explicitly increase the premium at which the MA plan could be offered (assuming margin is to be held steady).
Figure 2: Percentage of MA with mandatory preventive and comprehensive dental enrollment, in plans with various covered services: 2021 – 2024
| Comprehensive Dental Service Category | Zero Premium Plans | Nonzero Premium Plans | ||||||
|---|---|---|---|---|---|---|---|---|
| 2021 | 2022 | 2023 | 2024 | 2021 | 2022 | 2023 | 2024 | |
| Prosthodontics | 77% | 78% | 88% | 86% | 67% | 67% | 79% | 76% |
| Nonroutine Services | 54% | 62% | 80% | 79% | 56% | 56% | 67% | 62% |
| Diagnostic Services | 59% | 70% | 92% | 89% | 56% | 66% | 84% | 76% |
| Restorative Services | 95% | 93% | 93% | 89% | 89% | 84% | 87% | 79% |
| Endodontics | 58% | 63% | 86% | 84% | 59% | 61% | 80% | 75% |
| Periodontics | 71% | 78% | 94% | 92% | 72% | 80% | 90% | 84% |
| Extractions | 79% | 82% | 95% | 91% | 75% | 81% | 89% | 82% |
Trends in mandatory supplemental dental benefit limits and shared limits
Benefit limits define the maximum total claim cost that a plan will cover within a given time period. For MA mandatory dental coverage, benefit limits can be set separately for preventive and comprehensive dental coverage. Alternatively, plans can offer a shared limit applying to both preventive and comprehensive dental. Shared limits can also apply to a broader set of supplemental benefits including not only dental but also vision, hearing, or other benefits that might be offered under a plan. A shared limit falls under the definition of a “combo benefit package,” which is discussed more in the Milliman article 2024 Combined Benefits in Medicare Advantage – Tracking benefit strategy and options.
Limits can apply over a variety of periods, typically every year but also every three months, every six months, every two years, or other time periods. It is also possible for a plan to have no limit, which is common for mandatory supplemental dental benefits that cover only preventive services. In our analysis, limits for each plan were annualized to compare limits on a similar basis.
Approximately 71% of enrollees in plans with mandatory dental benefits have a shared preventive/comprehensive dental limit, compared with 65% in 2023. Shared limits are commonly $1,000 or greater. For non-shared limit plans, enrollees most commonly have an unlimited preventive dental benefit, which is often coupled with a comprehensive dental benefit with a separate limit.
We see variation among mandatory supplemental dental benefit limits at the state level. For instance, Texas has almost 80% of its mandatory dental enrollees in a plan with a shared limit, while more than half of New York enrollees have unlimited preventive coverage (regardless of existence of, or limits on, comprehensive dental). Some of these state-level differences in benefit limits may be indicative of broader differences in dental benefit richness by state, or on MA plans’ particular benefit strategies in a state.
Figure 3: Shared limit percentages for MA plans with mandatory dental benefits by state enrollment*
| Shared Limit Percentages | |||||||
|---|---|---|---|---|---|---|---|
| State | $0-1000 | $1000-2000 | $2000+ | State | $0-1000 | $1000-2000 | $2000+ |
| Alabama | 1% | 70% | 27% | Nebraska | 6% | 65% | 24% |
| Arizona | 10% | 27% | 48% | Nevada | 1% | 14% | 71% |
| Arkansas | 0% | 31% | 61% | New Hampshire | 29% | 35% | 10% |
| California | 4% | 18% | 3% | New Jersey | 1% | 39% | 6% |
| Colorado | 23% | 37% | 34% | New Mexico | 12% | 29% | 17% |
| Connecticut | 24% | 40% | 4% | New York | 4% | 20% | 19% |
| Delaware | 2% | 50% | 45% | North Carolina | 7% | 23% | 61% |
| District of Columbia | 0% | 32% | 18% | North Dakota | 15% | 13% | 17% |
| Florida | 2% | 28% | 40% | Ohio | 3% | 46% | 38% |
| Georgia | 5% | 46% | 29% | Oklahoma | 0% | 39% | 38% |
| Hawaii | 15% | 12% | 16% | Oregon | 5% | 62% | 9% |
| Idaho | 1% | 43% | 16% | Pennsylvania | 3% | 11% | 47% |
| Illinois | 0% | 32% | 52% | Rhode Island | 0% | 62% | 36% |
| Indiana | 1% | 68% | 28% | South Carolina | 6% | 32% | 42% |
| Iowa | 4% | 66% | 14% | South Dakota | 8% | 17% | 23% |
| Kansas | 1% | 31% | 53% | Tennessee | 0% | 13% | 83% |
| Kentucky | 0% | 32% | 57% | Texas | 8% | 19% | 52% |
| Louisiana | 1% | 39% | 58% | Utah | 0% | 71% | 27% |
| Maine | 19% | 60% | 6% | Vermont | 0% | 2% | 13% |
| Maryland | 0% | 20% | 14% | Virginia | 2% | 30% | 48% |
| Massachusetts | 4% | 66% | 11% | Washington | 15% | 47% | 9% |
| Michigan | 0% | 38% | 27% | West Virginia | 2% | 40% | 54% |
| Minnesota | 3% | 27% | 64% | Wisconsin | 13% | 56% | 15% |
| Mississippi | 1% | 43% | 29% | Wyoming | 43% | 43% | 9% |
| Missouri | 4% | 37% | 50% | Puerto Rico | 0% | 0% | 0% |
| Montana | 1% | 36% | 37% | ||||
* Alaska is excluded as there is no MA dental plan data available in this state.
Figure 4: Trends in enrollment in plans with shared dental limits, by state, 2023 – 2024
Trends in covered dental services by benefit limit
For each general enrollment MA plan offering mandatory supplemental dental, we counted the number of service categories covered as a general way to assess benefit richness, and we compared that against the plan’s benefit limits. We observed the following key results:
- Generally, plans with shared limits cover more dental service categories than non-shared limit plans.
- For plans specifying a separate limit on preventive services, the total number of dental service categories covered largely depends on the comprehensive limit.
- Plans with no limit on comprehensive coverage tend to cover fewer service categories on average than those with a comprehensive dental limit, helping to mitigate the risk of offering an unlimited benefit maximum.
- Plans with separate comprehensive limits are less likely to cover all eleven comprehensive service categories compared to plans with shared limits. Nearly 19% of enrollees are in plans with preventive dental benefits with a specified limit and no mandatory comprehensive dental coverage, an increase from 17% in 2023.
What’s next
The MA dental landscape continues to evolve rapidly. Enrollment in MA plans with mandatory supplemental dental benefits continues to increase, while the scope of covered dental services in those plans may finally be leveling off. This evolution of covered services over time has been driven by competition; the more services a plan covers, the more attractive the plan may appear to members, especially if there is no premium change associated with the additional coverage. On the other hand, richer benefits cost more to the MA plan which must balance that cost against maintaining overall competitiveness in the market. Competition includes not only that among MA plans but also for consumers that may be choosing between an MA plan and traditional Medicare.
Competitive decisions regarding dental benefit limits also hold trade-offs. Plans with high or no coverage limits may be more enticing to members but come at the cost of greater expense for the plan as well as potential adverse selection and induced utilization. The claims trends seen in 2024 may be, in part, due to fruition of adverse selection and induced utilization in prior years. MA dental utilization trends are discussed more in the Milliman article Medicare Advantage dental utilization: A changing landscape.
As members become more aware and seek to make the most use of their supplemental benefits, right-sizing benefits may become even more important. The 2025 Medicare Advantage and Part D Final Rule includes a new requirement beginning in 2026 for plans to notify enrollees of unused supplemental benefits between June 30 and July 31 of the plan year, which will further increase benefit awareness and increase the percentage of people utilizing their dental benefits.6 Having benefit designs that offer robust coverage while also controlling for potential unnecessary utilization will become even more critical.
Broader MA and traditional Medicare developments may also affect dental offerings in the Medicare space, including any MA financing changes, Star rating program changes7, and any further expansions of Medicare covered dental procedures under future Physician Fee Schedule Final Rules. As companies monitor and adapt to industry changes, we will continue to see new strategies for Medicare dental benefits offerings emerge.
Methodology
The Milliman Medicare Advantage Competitive Value Added Tool (Milliman MACVAT®) was used to compare 2024 MA dental enrollment and trends to those of the past few years. Special Needs Plans (SNPs), Medicare-Medicaid plans (MMPs), employer group waiver plans (EGWPs), Program of All-Inclusive Care for the Elderly (PACE) plans, Part B-only plans, cost plans, and Medicare Medical Savings Account (MSA) plans were excluded. For this paper, the plans with mandatory dental benefits include all plans with dental cost sharing and plans offering preventive benefits, as well as plans that offer both mandatory preventive and comprehensive benefits. Plans classified as having preventive and comprehensive benefits offer at least one of the following benefits: prosthodontic, nonroutine, diagnostic, restorative, endodontic, periodontic, and extraction services. The following benefits are considered to be preventive: x-ray, oral exam, prophylaxis, and fluoride. All of these benefits in aggregate are considered to be the possible dental service categories for the purposes of this study.
Comparisons to the 2019-2023 period were made based on values from our articles and analyses from prior years.8
For our analysis of benefit limits, we converted non-annual limits for each plan to an annual basis to allow for consistent comparisons of limits. We then identified enrollment in plans with a preventive limit, comprehensive limit, or shared limit, and further divided the data into four categories:
- Limits of less than $1,000
- Limits of $1,000 to $1,999
- Limits of $2,000 or greater
- No annual limit
1 CMS (April 2024). Medicare Monthly Enrollment. Retrieved August 16, 2024, from https://data.cms.gov/summary-statistics-on-beneficiary-enrollment/medicare-and-medicaid-reports/medicare-monthly-enrollment/data.
2 See https://www.congress.gov/bill/116th-congress/house-bill/4146, https://www.congress.gov/bill/118th-congress/senate-bill/2012, and https://www.congress.gov/bill/118th-congress/house-bill/831.
3 See https://www.federalregister.gov/documents/2022/11/18/2022-23873/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other and https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other.
4 Laktas, J., Yeh, M., Friedman, J.M. (March 2023). Prevalence of supplemental benefits in the general enrollment Medicare Advantage marketplace: 2019 to 2023. https://www.milliman.com/en/insight/prevalence-supplemental-benefits-general-enrollment-ma-marketplace-2023.
5 Friedman, J.M., Yeh, M. (September 2021). Trends in Medicare Advantage optional supplemental benefits. https://www.milliman.com/en/insight/trends-in-medicare-advantage-optional-supplemental-benefits.
6 See https://www.cms.gov/newsroom/fact-sheets/contract-year-2025-medicare-advantage-and-part-d-final-rule-cms-4205-f.
7 See https://www.milliman.com/en/insight/the-future-is-now-2024-star-ratings-release and https://www.milliman.com/en/insight/recalculating-medicare-advantage-scan-elevance-ruling-implications.
8
For the 2018 article, see Fontana, J.E. (November 2018). Dental coverage in Medicare Advantage plans: Nationwide market landscape. Available at: https://www.milliman.com/en/insight/dental-coverage-in-medicare-advantage-plans-nationwide-market-landscape.
For the 2019 article, see Fontana, J.E., and Bryniarski, J. (November 2019). Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2019 update. Available at: https://www.milliman.com/en/insight/dental-coverage-in-medicare-advantage-plans-nationwide-market-landscape-2019-update.
For the 2020 article, see Fontana, J.E., Bryniarski, J. & Tang, C. (January 2021). Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2020 update. Available at: https://www.milliman.com/en/insight/Dental-coverage-in-Medicare-Advantage-plans-Nationwide-market-landscape-2020-update.
For the 2021 article, see Fontana, J.E. and Tang, C. (September 2021). Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2021 update. Available at: https://www.milliman.com/en/insight/Dental-Coverage-in-Medicare-Advantage-Plans-Nationwide-Market-Landscape-2021-Update.
For the 2022 article, see Fontana, J.E., Tang, C.. & Youngblood, G. (August 2022). Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2022 update. Available at: https://www.milliman.com/en/insight/dental-coverage-in-medicare-advantage-plans-nationwide-market-landscape-2022-update.
For the 2023 article, see Fontana, J.E. & Youngblood, G. (October 2023). Dental coverage in Medicare Advantage plans: Nationwide market landscape, 2023 update. Available at: https://www.milliman.com/en/insight/dental-coverage-medicare-advantage-plans-nationwide-market-landscape-2023-update.