On June 9, 2026, the ADA submitted a formal letter to the House Energy and Commerce Committee asking Congress to require dental payers to disclose CDT-code-level negotiated rates in real time. The ask is reasonable. The problem it addresses is severe: the average Aetna-contracted practice billing a D2740 crown collects $255. The same practice, in the same zip code, billing Delta Dental of Michigan collects $727. That $472 gap — 185% difference on a single code — exists because payers control rate data entirely, share almost none of it, and route claims through leasing chains that providers never agreed to explicitly. The ADA letter is significant. But dental practices cannot afford to wait for Congress to act.
The June 2026 letter, signed by ADA President Richard Rosato, D.M.D., and Executive Director Nader Nadershahi, makes three core demands: first, that payers publish fee schedules at the CDT-code level, by geography, before a provider signs any participation agreement; second, that carriers disclose all downstream network leasing arrangements — specifically which plans are authorized to reprice claims under a given provider's contract; and third, that payers provide at least 90 days written notice before adding new leasing partners.
These demands are not radical. The Transparency in Coverage rule already mandates machine-readable files for medical plans under the ACA. Dental is largely excluded. The ADA's position is that dental payers should face equivalent disclosure requirements — so that a dentist in Albuquerque can look up what a Cigna DenteMax claim will actually pay for a D4341 before agreeing to participate in the network, not after 90 days of repriced EOBs arrive.
The political path is uncertain. But the commercial logic is already being forced by data aggregators. Carriers publishing negotiated rates through CMS machine-readable file requirements have inadvertently surfaced the full scope of the problem. That data — 100 million-plus negotiated dental rate records — now exists outside carrier walls. What Congress cannot yet mandate, the market is starting to expose.
To understand why the ADA's transparency push matters operationally, you need to understand how carrier-to-carrier leasing actually works. When a provider signs a participation agreement with, say, DenteMax, they are not contracting with a single payer. DenteMax leases its network access to Cigna, multiple Blue Cross Blue Shield affiliates, Humana, and more than 30 other regional plans. Each of those downstream plans can use the provider's contracted rate to reprice claims — without the provider's active agreement to each downstream arrangement.
MetLife PDP Plus operates similarly, licensing to 14 or more carriers including Guardian, United Concordia, and regional blues. Aetna Dental Access leases to 30-plus downstream plans. Connection Dental leases broadly to small commercial and employer-sponsored plans. The result is a typical PPO agreement involving three to five tiers of leasing depth that the provider never mapped out and was never shown at signing.
When those downstream plans reprice a claim, the provider collects a rate negotiated by the original contracting entity — often 15 to 40 percent below what the provider would receive from the plan they actually thought they were dealing with. An industry estimate puts 8 to 15 percent of all dental claims as running through a leased network at the time of adjudication. At a practice billing 1,200 claims annually, that is 96 to 180 claims per year being paid at rates the provider never explicitly accepted.
The negotiated rate data that has surfaced publicly makes the stakes concrete. For D2740 (all-ceramic crown), Aetna's average negotiated rate across 1,189 provider-rate data points is $255, with a range from $54 to $2,115. Delta Dental of Michigan averages $727 on the same code, ranging from $52 to $1,867 across 311 data points.
State-level variation is equally striking. Average D2740 rates by state: New York $982, Washington $957, Florida $879, California $834, Texas $790, New Mexico $757, Missouri $739, North Carolina $691, New Jersey $684, Wyoming $90. A provider practicing on the Wyoming-Utah border who accepts a leased DenteMax rate sourced from a low-reimbursement state tier may collect far less than a provider two counties over who negotiated directly with the same end insurer. Transparency at the CDT-code-by-geography level would make that spread visible before the contract is signed.
For preventive and restorative codes, the gaps are smaller in absolute dollars but compound faster at volume. Delta Dental of Michigan's average for D0120 (periodic exam) is $31, D1110 (adult prophylaxis) $52, D2160 (amalgam 3-surface) $153, D2391 (resin composite 1-surface posterior) $140, and D7140 (simple extraction) $85 with a range of $24 to $174. The extraction range alone — $24 to $174 on the same CDT code under the same carrier — illustrates why providers need pre-contract visibility, not post-payment reconciliation.
The transparency gap in numbers: Aetna averages $255 for D2740. Delta Dental of Michigan averages $727. That is a $472 difference on a single crown code. Both rates are disclosed in machine-readable carrier files. Neither is disclosed to providers at the time of contract signing. The ADA is asking Congress to change that. Until it does, the only protection is provider-side rate intelligence.
Most practices are not sitting on a clean picture of which downstream plans are repricing their claims. The signs are in the EOBs, but reading them correctly takes deliberate audit work. You are likely affected if you see any of the following on your remittances:
If any of these appear in 30 days of remittances, you are almost certainly running into active leasing repricing. The ADA transparency push would require carriers to disclose this upfront. Until that happens, you find it by auditing.
Start with crowns. A practice placing 100 crowns per year at an Aetna average of $255 collects $25,500. If a leased network routes 15 percent of those claims — 15 crowns — through a repricing tier that shaves another 20 percent off the Aetna rate, the effective rate on those 15 claims drops to $204. That is a $51 loss per crown, $765 annually, just on crown leakage from a single code under a single carrier. Scale that across 5 carriers with leasing exposure, 10 high-dollar codes, and 150 crown claims per year and the number moves above $10,000 in annual erosion from this mechanism alone.
The ADA's ask for transparency is also an ask for this math to happen before contract signing, not after. A provider who could look up the DenteMax-to-Cigna repricing differential by CDT code before agreeing to participate would have real negotiating leverage. Without that visibility, they are signing a contract with incomplete terms.
PayorMap Pro gives you real negotiated rates, network leasing maps, and provider-level benchmarks — the data dental practices need to negotiate smarter.
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