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In re Doe
No. 000-40-0610 (SSA Office of Hearings & App. Jan. 30, 1992). ; Clearinghouse Number: 51572
Description
Charges for Endodontic and Presurgical Endodontic Treatment Found Reasonable
Abstract
The administrative law judge (ALJ) has held that charges for
endodontic care submitted by beneficiary’s physicians were
"reasonable charges" as defined by 42 C.F.R. §
405.509 and did not exceed the inflation-index charge defined in 20
C.F.R. § 405.509; these charges should be covered by Medicare.
The ALJ also held that charges for presurgical endodontic treatment
did not fall within the dental service exclusion of §
1862(a)(12) of the Social Security Act and should be reimbursed in
full by Medicare. Beneficiary suffered severe injuries to her face,
mouth, and jaw in a car accident and had to undergo extensive
reconstructive and rehabilitative oral surgery. Considering only
the "prevailing charge" of physicians in the region when
determining "reasonable charges" and not taking into
account the customary charges of physicians offering similar
services, carrier paid the lowest of the prevailing, customary, or
actual charges. Medicare also refused to reimburse a physician for
endodontic services; they were excluded from Medicare’s
dental service coverage. The ALJ held that the physicians’
submitted charges were their customary charges, did not exceed the
inflation-index charge, and were "reasonable charges"
entitled to full reimbursement. Also, payment should be made for
the endodontic services because they were secondary to
beneficiary’s underlying medical condition and integral to
the dental procedures she needed; the services should be allowed
pursuant to 42 C.F.R. § 405.310(i).
