Short answer is yes IF you are not grandfathered in and you bought your plan outside of the state/federal marketplace.  However, both ADA and ISDS feel there will be no penalty for the failure to do so.  Technically the federal government could declare that your plan is non-compliant and hit you with a 2% household income tax for 2015.

I called ADA, AGD, and ISDS today (June 2013).  In Illinois if you buy a health plan outside of the marketplace then you MUST buy pediatric dental insurance.  If you buy a plan within the marketplace it is optional.  There may just be a fee (ISDS opinion)  for not having pediatric dental insurance.  The Washington ADA office felt you would not be penalized for not having the pediatric insurance even though it is “required”.

Spoke with Dion @ ISDS – Mandatory outside marketplace.  Optional inside marketplace.  May just be a fee (unsure on that)

Spoke with Janis @ ADA – Washington -Confirmed but believes you will not be penalized for not having the pediatric  insurance even though it is “required”.  Recommended calling BCBS because other members have called and were told that they would not be penalized for not having.

Not within exchanges run by the federal government. A federal agency interpretation of the ACA has determined that within the exchange, the dental EHB need only be offered. However, in the individual and small group markets outside the exchange, the dental EHB must be purchased. The ADA strongly disagrees with this interpretation, but at this time it appears that all exchanges run by the federal government will be operating within these parameters. On the other hand, states have the authority to mandate the purchase of the dental EHB. Few states have chosen to mandate purchase or are considering doing so.

http://practicemanagement.dentalproductsreport.com/affordable-care-act-what-you-need-know-about-how-it-will-affect-pediatric-dental-patients    Article by Kevin Henry no longer able to access.

For example, while the ACA requires every state to offer children’s dental services, the package of services can vary. In Illinois, the exchange will offer orthodontia but it is likely that this benefit would be strictly controlled. The U.S. Department of Health and Human Services (HHS) has ruled that children’s dental insurance is “a mandated offering but not a mandated purchase” but states can set their own rules.

Pediatric dental benefits are a mandated offer but optional purchase on the Marketplace, but are a mandated offer and mandated purchase outside of the Marketplace.  Pediatric dental plans will not have an annual or lifetime benefit maximum for covered services.  There will be an out-of-pocket limit of $700 per child and $1,400 per family.  As a dental provider, you will most likely not know the difference between dental plans purchased on the Marketplace versus outside the Marketplace.  Adult dental benefits are not covered in the ACA.   ISDS

http://www.ada.org/sections/advocacy/pdfs/August_8_2013_–_Effects_of_ACA_on_Dentistry.pdf