The Transparency in Coverage rule, implemented through CMS under the ACA, requires health insurers to publish machine-readable files listing negotiated rates for every covered service by provider and plan. It is one of the most consequential data disclosures in U.S. healthcare history — and dental is largely excluded from it. Dental benefits structured as standalone plans under ERISA employer arrangements are not required to comply. But the carriers that do publish — because their dental products are embedded in comprehensive plans or because they voluntarily disclose — have inadvertently created the most detailed picture of negotiated dental rate variation ever made publicly available. Here is what that data shows and how dental practices can use it.
The Transparency in Coverage final rule (85 FR 72158) took effect for plan years beginning January 1, 2022. It requires group health plans and health insurance issuers to publish three machine-readable files: in-network negotiated rates, out-of-network allowed amounts, and prescription drug data. The in-network file must include, for each covered item or service: the billing code, the negotiated rate, the provider NPI, the plan or issuer name, and the plan identifier.
The rule applies to non-grandfathered group health plans and health insurance issuers in the individual and group markets. It explicitly covers plans that provide "essential health benefits" under the ACA. Standalone dental plans — particularly those structured as excepted benefits under HIPAA — are not considered essential health benefit plans and are therefore largely exempt. This is why comprehensive dental rate data is not uniformly available through CMS channels.
However, dental benefits embedded in comprehensive medical plans (often called "embedded dental") must be included in the machine-readable files. Large self-funded employer plans that include dental as part of the comprehensive benefit package are also subject to the rule through their plan fiduciary obligations. The result is a patchwork: some dental rate data is public and machine-readable; most is not.
The data that has been extracted from CMS machine-readable files and carrier-published negotiated rate data reveals the full scope of variation that the dental billing community has suspected but could not previously quantify.
For D2740 (all-ceramic crown), Aetna's national average across 1,189 provider-rate data points is $255, with a range from $54 to $2,115. Delta Dental of Michigan's average is $727, ranging from $52 to $1,867 across 311 data points. The state-level D2740 data shows: New York $982, Washington $957, Florida $879, California $834, Texas $790, New Mexico $757, Missouri $739, North Carolina $691, New Jersey $684, Wyoming $90.
For D2750 (porcelain fused to high noble metal crown), Aetna averages $487 with a range of $10 to $1,659. For preventive codes under Delta Dental of Michigan: D0120 (periodic exam) averages $31 (range $20–$79), D1110 (adult prophy) averages $52 (range $42–$100). For restorative: D2160 (amalgam 3-surface) averages $153, D2391 (resin composite 1-surface posterior) averages $140. For periodontal and surgical: D4341 (scaling/root planing 4+ teeth) averages $226, D7140 (simple extraction) averages $85 with a range of $24 to $174.
These ranges — within a single carrier for a single code — show that negotiated rates are not uniform even within a single network. The Delta Dental of Michigan D7140 range of $24 to $174 on a single code means some providers have negotiated rates more than seven times higher than others for extracting the same tooth under the same plan. Transparency data makes that variation visible for the first time at scale.
The CMS dental exemption creates an information asymmetry that directly benefits carriers. Carriers know exactly what every provider in their network is contracted for on every CDT code. Providers, in most cases, know only their own contracted rate — and even that is often only available if they request a current fee schedule in writing. They have no view into what their neighboring practice is contracted for, what the carrier is paying on average across the network, or where their rates sit relative to the distribution.
This asymmetry is why the ADA's June 2026 letter to Congress specifically called for CDT-code-level rate transparency — the dental equivalent of what CMS transparency mandates for medical. Until that mandate exists for standalone dental plans, providers must rely on voluntarily published data, carrier-published machine-readable files that exceed the minimum mandate, and third-party data aggregation to understand the rate landscape.
The practical effect of the dental exemption on practice revenue is not abstract. A provider in Florida who does not know that the state average for D2740 is $879 cannot negotiate effectively toward that number. A provider who contracts with a carrier at $400 for D2740 and never discovers that other providers in the same network are contracted at $700 has no basis for a renegotiation request. Transparency creates leverage. The exemption eliminates it.
The information asymmetry in dental contracting is structural: Carriers have provider-level rate data on every practice in their network. Providers have only their own contracted rate, and only if they request it in writing. This is the core problem the ADA transparency push is designed to solve — and the reason practices need to use every available external data source to close that gap before their next contract renewal.
Even without a universal dental transparency mandate, practices can act on the data that does exist:
A practice operating without market rate intelligence effectively negotiates blind. Consider the cumulative cost: if your Aetna D2740 rate is $255 and the state average in your geography is $834 (California), the gap is $579 per crown. At 80 Aetna crowns per year, that is $46,320 in annual revenue gap attributable directly to information asymmetry. You did not know the market rate. You contracted at the low end. You have renewed without changing it.
Across all crown codes (D2740 and D2750) and assuming 120 annual crown claims with a $200 average rate gap, the annual impact is $24,000. Over a five-year contract cycle without renegotiation, that compounds to $120,000 in foregone revenue on crown codes alone. The CMS transparency rule for medical exists precisely because these gaps, at population scale, represent billions of dollars in information-driven market failure. Dental is not yet covered. The cost falls on providers.
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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