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A dentist is on payroll and not yet credentialed. Your options depend on the payer contract, plan, program, billing entity, rendering provider, location, date of service, and written effective-date rules; there is no universal interim-billing workaround. Before you render care based on expected reimbursement, ask the payer in writing whether it authorizes out-of-network billing, a retroactive effective date, held-claim submission, substitute-dentist billing, or another transition path. Also confirm patient disclosures, cost sharing, and timely filing.

First: diagnose the delay

Check the CAQH attestation early when an application stalls. An expired attestation can stop the payer’s review without producing an obvious error in your local tracker.

The legitimate options

1. Use out-of-network billing only when authorized

Out-of-network billing may be available when the plan covers it and the payer confirms the correct billing entity, rendering provider, identifiers, location, and disclosure treatment. It is not a universal default, and Medicaid generally does not provide a commercial-style out-of-network fallback.1 Know the consequences before relying on it:
  • Out-of-network benefits are thinner, and some plans send the payment to the patient, not to you
  • Do not routinely waive or reduce required cost sharing without checking the contract, plan, state law, and federal-program rules; HHS OIG identifies routine federal-program cost-sharing waivers as potential Anti-Kickback Statute and civil monetary penalty risk1
  • Predeterminations submitted during the gap price at out-of-network benefits. A predetermination is a non-binding estimate at the best of times; one issued while your status is in flux will mislead the patient about their share. Hold big-case predeterminations until the effective date, or caveat the estimate explicitly. See Get predeterminations.

2. Retro-effective dates

Ask for the effective date to be backdated to the application date or the start date.
  • Ask in writing at application time, not after
  • Some payers grant routinely; many do not
  • Use a documented follow-up log with dates, names, and the information provided

3. Hold claims and submit after the effective date

Hold a claim only if the payer confirms the later submission will be valid for that date of service and you can remain within timely filing. The constraint is timely filing. If a payer’s limit is 90 days and credentialing takes 150, holding doesn’t help. Check each payer’s limit before relying on this, and track held claims so none age out. See Beat timely filing limits.

4. Schedule around payer mix

Book the uncredentialed dentist with patients whose payers they are credentialed with, plus self-pay and membership-plan patients. Requires scheduling flexibility, but it is straightforwardly compliant.

5. Non-billable work

Training, chart review, treatment-plan calibration, and protocol work can be useful during a ramp. Confirm scope, supervision, employment, and whether any activity itself becomes a billable professional service.

6. Self-pay and membership patients

Compliant, provided you furnish a good faith estimate as required for uninsured and self-pay patients under the No Surprises Act. See The No Surprises Act.

The narrow option: locum tenens, dental edition

Dentistry does not have one industry-wide locum billing rule. The 2024 ADA Dental Claim Form includes fields for reporting a temporary substitute (locum tenens) dentist.2 Whether the payer allows that substitute to render under an absent dentist’s participation depends on the contract and payer policy. Ask each carrier in writing. Two things locum status is not:
  • A mechanism for a permanent new hire awaiting credentialing. The reporting fields address a substitute covering an absence.
  • A mechanism for a practice buyer to bill as the seller; see below

The things that create liability

Never make the claim identify a different rendering provider, billing entity, location, or participation status from the facts and the payer’s authorized rules.Billing a new associate’s services under a credentialed colleague’s NPI can misidentify the rendering provider; misattributed-provider claims appear in the MB2 and HQRC False Claims Act settlements.3 After an acquisition or ownership change, using seller identifiers without written payer or program authorization can likewise make claims false or contractually noncompliant. An equity deal may retain the same entity and TIN, and a payer-approved assignment, change-of-ownership, or transition process may produce a different answer.1A purchase agreement cannot bind the payer. Record the payer’s written answer, then audit the first claims against it.

When to escalate

Escalate when an application has been silent for 30+ days, when you’ve been told “pending” three times, or when an effective date is unreasonably delayed after approval. How:
  1. Provider relations representative for your group, if one is assigned
  2. Supervisor at the credentialing department, ask by name.
  3. A written escalation citing your follow-up log with dates and names.
  4. Your state dental society, which often has payer-relations staff and channels the carriers answer.
  5. State insurance department for fully-insured plans, where the state has credentialing timeliness requirements. Note this generally doesn’t reach self-funded plans. See Payers vs insurance companies.
  6. Contract discussions. If a payer asks the group to add locations or dentists, raise credentialing timelines during that conversation.

Prevention

  • Start the pipeline at offer acceptance and, for an acquisition, as early as the payer rules and transaction process permit
  • Submit to all payers in parallel
  • Keep CAQH attested and every payer authorized
  • Ask for retro-effective dates in writing, at application
  • Log every follow-up
  • Model the credentialing gap into the hiring or acquisition plan so it’s a known cost rather than a surprise

Verify it worked

  • Root cause of the delay identified
  • CAQH attestation and payer authorization confirmed first
  • Written payer or program answer obtained for interim billing, provider linkage, identifiers, location, and effective date
  • Cost-sharing posture checked against the contract, plan, state law, and any federal-program rules
  • Retro-effective date requested in writing
  • Held claims tracked against timely filing limits
  • No claim submitted under an entity, provider, location, identifier, or participation status the payer did not authorize for that date of service
  • Escalation path used where warranted
  • Follow-up log complete

Sources

  1. Aetna, provider education: demographic and TIN changes (PDF); Delta Dental, dentist FAQs; CMS, NPI FAQs; HHS OIG, Fraud & Abuse Laws (routine cost-sharing-waiver risk in federal programs). See Acquire a dental practice.
  2. ADA, 2024 Dental Claim Form completion instructions (PDF) (locum tenens reporting fields).
  3. DOJ, MB2 Dental Solutions settlement (2017; erroneous provider numbers misrepresenting which dentist performed procedures); DOJ, HQRC Management Services settlement (2022; admissions including inaccurate servicing-provider information).
Last modified on August 21, 2026