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As California dental offices are resuming preventive care amidst the COVID-19 pandemic, the obligation to implement new safety protocols and provide additional PPE to protect staff and patients has become a financial burden.
Updated July 1 to reflect new guidance from the Department of Health Care Services advising providers not to charge Medi-Cal dental patients an additional fee to cover PPE costs.
As California dental offices are resuming preventive care amidst the COVID-19 pandemic, the obligation to implement new safety protocols and provide additional PPE to protect staff and patients has become a financial burden. CDA is aware that members are searching for ways to offset the rising cost of maintaining a clean and safe environment, which may include charging patients a new infection control fee. While CDA continues to advocate for financial relief for members, the following guidance is recommended to help members navigate this growing issue.
While dentists have incurred additional PPE costs as the result of the COVID-19 crisis, it’s important to recognize that patients may also be incurring financial hardships due to job loss or reduction in hours, and potential loss of their dental benefits. Some dental practices have opted to alter their charged fees to account for the increased overhead costs due to PPE requirements, while others have opted to charge a flat fee.
Regardless of how a dentist decides to address the increased cost of care, we encourage educating patients about why this is occurring. For an overall increase in fees, it may be a brief statement to patients about the increasing cost of care. Charging a straight PPE charge may require more nuanced patient education and messaging to ensure patient retention.
Dentists who participate as contracted providers for dental plans will need to review the terms of their participation agreements as well as accompanying documents, such as their provider handbooks, or confirm if they are able to charge the plan or the patient a fee and how to obtain payment. Many plan contracts have limitations on charging additional administrative fees or costs that are to be presumed to be bundled in the existing cost of covered services.
Providers are advised to check the dental plan’s website and provider portal area for any plan communications that address how the plan may be assisting providers with PPE costs.
A dentist can submit a predetermination of the patient’s treatment plan and the PPE charges to the plan via the dental plan’s online portal to validate what the plan may pay for. Most dental plan contracts include the cost of PPE within the reimbursed amount to the dentist and may disallow participating providers from billing the patient for PPE in the event the plan denies the charge.
The Department of Health Care Services will not provide reimbursements for PPE and has advised providers not to charge Medi-Cal dental patients an additional fee to cover PPE costs.
CDA’s Practice Support can assist members with general interpretation of their dental plan contracts, but it is not a legal analysis.
The ADA Code of Ethics advises that it is unethical for providers to only charge uninsured patients or only seek reimbursement for insured patients to address the surge in PPE costs, with the exception of Medicaid enrollees due to federal and state restrictions. The fee a provider charges a patient without insurance is considered the dentist’s full fee and should be represented to all third-party payers.
The CDA Code of Ethics provides similar guidance, noting that dentists have the obligation to bill for services in a manner that is not fraudulent or misleading. PPE surcharges cannot be billed subjectively, but must be applied to all patient visits, regardless of whether the patient is uninsured or whether a commercial dental benefit plan reimburses for the charge.
If a PPE surcharge is appropriate for your practice, there are additional considerations when determining the amount you may charge patients. California anti-gouging law prohibits businesses, including dental practices, from raising the price of goods and services by more than 10% after an emergency is declared, including the COVID-19 pandemic. Due to the global PPE shortage, providers are exempt from charging pre-COVID prices for PPE but should not charge more than 10% of the current market rate amount of the PPE supplies needed during a typical patient visit.
Dental benefit plans, which have continued to collect millions in premiums from patients during the pandemic while dental offices were limited to emergency procedures, have a responsibility to share the high cost of additional PPE. CDA is advocating for state lawmakers to hold dental benefit plans accountable in sharing the new costs of extensive PPE without which dental care cannot be provided.
CDA is urging dentists to contact their dental plans to stress the need for financial relief that will help sustain dental practices in the new COVID-19 environment. Act now by sending a letter to your dental plan.