Comment on AN28-Proposed Rule-Greiner, Nic D.

Though the new regulations give better guidelines to the Hospitals as to who is eligible for dental care, I am concerned that for certain classes of eligible veterans.Class 5 veterans, who are enrolled in Vocational Rehabilitation and are determined to be eligible in order to complete their training, are listed in the new guidelines as no longer needing verification from the VBA.This makes perfect sense when it is the VBA counselor who is working with the veteran and who must request the dental appointment.But if that information is not indicated in some way on the veteran’s medical file or even attached provisionally to the appointment rolls, the hospital must still contact the VBA to determine eligibility.The VBA then only responds with the veteran’s disability rating and overall dental eligibility. The Hospital, as designated in the rules, notifies the veteran by way of a letter canceling the appointment. Since the wait time for appointments is several months, having an authorized appointment canceled at that stage requires the veteran to go back to their counselor again for resubmission. Veterans in this program may only be in short term training institutions, and setbacks like this may prevent them from getting the care they need in the time they are eligible. The second class I would like to address in Class 6, those who are receiving other medical care. The phrasing, “reasonably necessary to the provision of such care and services..” , is vague and open to broader interpretation than the examples provided. I commend the proactive treatment of people before surgery to prevent subsequent infection, but there are many less immediate medical conditions that are exacerbated by poor oral health such as heart disease, something that I am sure is a drain on the medical side. Reducing redundancy is a great start, but in addition to removing unnecessary steps, we must be sure the ones that remain are as clear and as effectively applied as possible.