CDT Code D2991 | 260 Practices | April 2026
Monday
Problem Mapping
Define the long-term goal for Curodont at SGA, map the problem across all stakeholders, identify where the system breaks, and select sprint targets.
Network Opportunity
$7.5M
Annual gross at 50% adoption (130 practices)
Margin Gap
2-3x
Hygienist margin vs. doctor margin per treatment
Provider Split
75/25
Doctor/Hygienist (should be inverted)
D2991 Denial Rate
~70-85%
CDT 2024 code — mirrors D4346 in 2017
Key Legal Finding
Colorado SB17-190 Protects Full UCR Collection
Colorado law (CRS 10-15-121.5, eff. 2017) prohibits dental plans from dictating fees for non-covered services. However: ERISA/self-funded plans (~65% of commercial) are exempt from state fee-capping laws. Protection only applies to fully insured plans. 44 states have similar laws (including AZ and KS where SGA operates).
Competitive Signal
Heartland: 125,000+ Teeth Treated
Heartland Dental (1,200+ practices) has a formal vVardis partnership with 125K+ teeth treated. Aspen Dental also adopted. vVardis: $85M funded, ~10% of US dental offices now offer Curodont, 1M+ teeth treated nationally since Jan 2024.
In 18 months, SGA will standardize Curodont delivery across 260+ practices with hygienist-led placement (75%+), a sustainable pricing model that maintains $80+ DSO net margin per treatment, and a billing strategy that protects cash flow during the 2-3 year D2991 insurance adoption window — generating $5M+ in annual DSO net revenue.
Goal Validation
Passed
  • Ambitious enough? $5M+ DSO net across 260 practices is transformational for a single product line
  • Specific enough? Provider split %, margin floor, revenue target, timeline for insurance adoption
  • Believable? $120 UCR with $28 cost = 76.7% margin (hygienist). Math works if placement shifts.
  • Inspires? Doesn't prescribe a single billing strategy; opens multiple pathways
The Core Insight

Curodont is a $92 net margin product when placed by a hygienist (3-5 min added chair time, $18-31/min revenue). When a doctor places it, the 30% commission drops net to $56, and it consumes 8-12 minutes of chair time worth $400-600/hour in restorative production. The pricing debate is a symptom — the real problem is who holds the applicator.

What Could Kill the Curodont Rollout?
Assume the rollout failed in 18 months. What went wrong?
SQ1 — Highest Risk
Can we shift Curodont placement from 75% doctor / 25% hygienist to 25/75 when doctors earn 30% commission on each placement and have no financial incentive to let go?
Risk: Very High Impact: $2.7M/year in DSO margin at stake
SQ2 — High Risk
Can we maintain $120 UCR and protect cash flow when D2991 has a 70-85% insurance denial rate and RCM is too small to chase claims — without resorting to non-compliant billing practices?
Risk: Very High Impact: Compliance + revenue — wrong move creates legal exposure
SQ3
Will doctors accept a standardized $120 fee without a sliding scale — or will frustration from clinical presidents undermine network-wide adoption?
Risk: High Impact: Political — clinical presidents are the adoption champions
SQ4
Can we build a reliable payer reimbursement database across 260 practices fast enough to inform pricing strategy before the clinical presidents lose patience?
Risk: Medium-High Impact: Data drives every downstream decision
SQ5
Can we standardize Curodont case presentation, morning huddle identification, and patient consent across 260 practices with no centralized hygiene leadership layer?
Risk: Medium Impact: Adoption rate determines revenue ceiling
The Curodont Treatment Journey
Left to right: actors, journey steps, and goal. Amber steps mark critical moments where the system breaks.
Patient
Arrive for Hygiene
Learn About Curodont
Hear Price ($120)
Accept / Decline
Pay at Checkout
Curodont
Standard of Care

75%+ Hygienist
$120 UCR

$5M+ DSO Net
Hygienist
Review Chart
ID Candidate
Present to Patient
Apply Curodont (3-5 min)
Document D2991
Doctor
Release to Hygiene?
-
-
Exam / Confirm Tx
30% Commission?
Front Desk
Collect $120 Upfront
Consent Form
Enter D2991 in PMS
-
-
RCM Team
Generate Claim
Submit D2991
ERA Processing
Paid / Denied?
Refund or Write-off
DSO Leadership
Set UCR / Policy
Train Network
Monitor Margins
Negotiate w/ Payers
Scale or Kill
Where the System Breaks
#MomentActorWhy It's Critical
★1Doctor Won't Release to HygieneDoctor30% commission = $36/placement. Releasing to hygienist = $0. No financial incentive to shift. This is the #1 blocker.
★2Insurance Denies D2991RCM70-85% denial rate. New CDT code (2023). Many payers don't have it in their fee schedule. Same trajectory as D4346 in 2017.
★3Balance Billing ComplianceRCM / LegalCollecting $120 upfront then submitting to insurance may violate PPO contracts. Non-covered waiver doesn't protect from billing obligation.
★4Price Objection at ChairPatient$120 feels high for a "gel application." Without insurance coverage certainty, case acceptance drops. Need strong value narrative.
★5Inconsistent PricingFront DeskBefore RCM standardized, practices charged wildly different amounts. Sliding scale requests reintroduce inconsistency.
★6Candidate IdentificationHygienistWithout morning huddle protocol and calibration, hygienists don't know which patients to present Curodont to.
★7No Payer DataDSO LeadershipRCM says D2991 is "too new" for reimbursement data. Can't make informed pricing decisions without building the database.
★8RCM CapacityRCMTeam too small to chase unpaid D2991 claims. Collect-upfront model essential but creates its own compliance questions.
★9Clinical President FrustrationDoctorsThe champions who drive adoption are frustrated by $120 price and lack of insurance clarity. Losing them = losing the rollout.
22 Opportunity Notes
Grouped by theme. Each HMW is an opportunity space, not a solution.
A. Provider Economics & Compensation 5
HMW restructure doctor compensation so they don't lose income when Curodont shifts to the hygiene chair?
HMW make hygienist-placed Curodont more attractive than doctor-placed Curodont without creating resentment?
HMW introduce a small hygienist incentive ($5-10/placement) that drives adoption without adding comp complexity?
HMW align doctor production targets to exclude Curodont revenue that shifts to hygiene?
HMW frame the conversation with doctors as "you gain restorative chair time" rather than "you lose $36/placement"?
B. Insurance Billing & Compliance 5
HMW collect full fee upfront without violating PPO contract balance billing restrictions?
HMW build a payer reimbursement database across 260 practices when RCM says the code is "too new"?
HMW use SGA's 260-practice claim volume to accelerate D2991 payer adoption (D4346 took 3 years)?
HMW create an appeal process for D2991 denials that doesn't overwhelm our small RCM team?
HMW treat D2991 billing like any other code instead of inventing special processes that create compliance risk?
C. Pricing Strategy 4
HMW maintain a $120 UCR that keeps insurance payers recognizing the procedure's value while doctors push for lower prices?
HMW design a sliding scale (if needed) that doesn't drop below the $80 hygienist / $90 doctor margin floor?
HMW position $120 as a value ("avoid a $300+ filling") rather than a cost?
HMW price Curodont competitively against alternatives (fluoride varnish $30-45, SDF $25-40, fillings $200-400)?
D. Clinical Workflow & Adoption 4
HMW integrate Curodont into the standard hygiene workflow when 3 of 5 application steps are already in the prophy protocol?
HMW add Curodont candidate identification to the morning huddle without adding huddle time?
HMW train hygienists on case presentation for Curodont when they already present fluoride and sealants?
HMW achieve 1-2 placements/day per practice (target) when 25-35% of hygiene patients are candidates?
E. Stakeholder Management 2
HMW keep clinical presidents engaged as Curodont champions when their pricing and insurance concerns haven't been resolved?
HMW present data-driven decisions to the clinical presidents fast enough to maintain their trust?
F. Vendor & Market Position 2
HMW leverage SGA's 260-practice scale to negotiate better Vivardis pricing if insurance reimbursement stays low?
HMW evaluate whether "the juice is worth the squeeze" if payers consistently reimburse at $45-50?
What the Evidence Says
Insurance & Coding Analysis
  • D2991 is CDT 2024: "Application of hydroxyapatite regeneration medicament, per tooth." Classified Restorative (D2000 series).
  • D4346 precedent: Added 2017, took 3 years for majority payer acceptance. D2991 is on the same ~2027-2028 trajectory.
  • Colorado SB17-190: Dentists CAN charge full UCR for non-covered services. Collecting $120 upfront is NOT balance billing.
  • Must still submit claims. Non-covered waiver does NOT eliminate billing obligation. Always submit D2991 to build payer data.
  • Option B is the compliant model: Collect $120 upfront, submit claim with K02.61 narrative, refund if insurance pays.
  • Known coverage: United Concordia (ages 1-6), Delta Dental MI (published criteria). Most major payers still building policies.
  • Never code as D9910 or D1208 — miscoding = False Claims Act exposure. D9999 is valid fallback if payer rejects D2991.
  • Appeal every denial. 260-practice claim volume accelerates payer adoption by 12-18 months vs. individual practices.
💰 Financial Model
  • At $120 UCR: Hygienist net = $92.00 (76.7%). Doctor net = $56.00 (46.7%) after 30% commission.
  • Break-even: Hygienist at $28 (just product cost). Doctor at $40 (product + commission).
  • Brittney's floors are too low: $40 hygienist / $55 doctor leave thin margins. Recommend $80 / $90 minimum.
  • Revenue per minute: $18-31/min in hygiene chair — highest of all hygiene add-ons (beats fluoride, sealants, SDF).
  • Network opportunity at 50% adoption: $7.5M gross, $4.7-5.8M DSO net depending on provider mix.
  • Provider shift impact: Moving from 75/25 doctor/hygienist to 25/75 adds ~$2.7M/year to DSO net margin.
👤 Practice Operations
  • Net new chair time: 3-5 min in hygiene (steps 1, 2, 5 already happen). 8-12 min in doctor chair (must duplicate).
  • Chair time economics: Doctor chair = $400-600/hr opportunity cost. Hygiene = $180-250/hr. 2-3x margin difference.
  • 25-35% of hygiene patients are Curodont candidates (moderate/high caries risk with incipient lesions).
  • Target: 1-2 placements/day per practice, building to 2-3. Monthly target: 20-40 placements/practice.
  • Case acceptance framework: "Treat the cavity without drilling" + "$120 vs. $300+ filling" value narrative.
  • Morning huddle: Flag patients with caries history, white spots, incipient lesions on BWX, high CRA scores.
Compensation & Behavior
  • The real blocker is money: Doctors earn $36/placement (30% of $120). Releasing to hygienist = $0. Price objections are a proxy.
  • Best fix: Adjust doctor production targets to exclude shifted Curodont + add small hygienist placement bonus ($5-10).
  • Doctor frustration is disingenuous (Brittney's word): They could solve the patient cost problem by letting hygienists place it.
  • NC Board precedent (Oct 2024): NC explicitly ruled hygienists can place Curodont under dentist supervision. Other states will follow.
  • Consider flat doctor fee: $15-20/application instead of 30% commission. Minimal chair time doesn't justify full commission.
💻 Technology & Systems
  • Dental Intel (95% adoption) is the fastest path to D2991 data — can pull production by code, provider, and practice TODAY.
  • NexHealth does NOT expose financial data. Appointments and procedure codes only. No fees, ERA results, or write-offs.
  • Automated narrative template: Push a standard D2991 clinical narrative into all PMS procedure code settings (same method RCM used for UCR).
  • Clearinghouse flagging: Configure rules to auto-flag D2991 ERAs and build the reimbursement database passively.
  • Phase A safe: D2991 reimbursement database is aggregate data (payer + practice + amount) with no patient identifiers.
  • Power BI dashboard: Dental Intel → ClickHouse → Power BI = D2991 executive visibility without building new infrastructure.
🏆 Competitive Landscape
  • Aspen Dental (1,000+ locations) partnered with vVardis Feb 2025 — Curodont is already being deployed at DSO scale.
  • Henry Schein exclusive distributor (Jan 2026, all US segments) — SGA's existing supply chain handles procurement.
  • Curodont competitors: CrystLCare (Greenmark) is the only direct D2991 competitor. MI Paste, Clinpro, SDF are different mechanisms.
  • DSO rollout failure rate: 60-70% due to training/workflow gaps, not product issues. Structured onboarding = 2-3x faster adoption.
  • Industry UCR norm: 4-6x material cost. $120 on $28 cost = 4.3x (reasonable). $120 on $38 cost = 3.2x (below norm).
Margin by Price Point & Provider
Product cost: $28.00/unit (per Brittney). Note: some distributors list $38/unit — verify with procurement. Doctor commission: 30%. Hygienist commission: $0.
UCR FeeHygienist NetHygienist %Doctor NetDoctor %Blended 75/25 Dr/HygBlended 25/75 Dr/Hyg
$40$12.0030.0%$0.000.0%$3.00$9.00
$55$27.0049.1%$10.5019.1%$14.63$22.88
$80$52.0065.0%$28.0035.0%$34.00$46.00
$90$62.0068.9%$35.0038.9%$41.75$55.25
$100$72.0072.0%$42.0042.0%$49.50$64.50
$120$92.0076.7%$56.0046.7%$65.00$83.00
$150$122.0081.3%$77.0051.3%$88.25$110.75
Sprint Focus: B + Pricing
After review, Brittney narrowed the sprint: insurance billing compliance and pricing strategy are the critical unknowns. Provider economics has been discussed enough with doctors. Clinical workflow is parked until SGA East rollout.
Target A: Provider Economics & Placement Shift
Discussed

Already addressed in direct conversations with clinical presidents. Doctor compensation stays at 30% commission — no flat fee structure. The hygienist shift is happening (improved from 10% to 25%) but remains a background initiative, not a sprint-blocking unknown.

24/25
Target B: Insurance Billing Strategy & Compliance
Sprint Focus

Define compliant billing workflow, resolve balance billing question definitively, determine whether to use "election to self-pay" form or treat D2991 like any other new CDT code. Centralized payer tracking needed — internal RCM data may be unreliable.

23/25
Target B+: Pricing Strategy & Sliding Scale
Sprint Focus

Design a sliding scale that doctors will accept without dropping below DSO margin floor. Brittney's draft: $120/tooth (1), scaling to $75/site floor at 5+. Must account for both hygienist placement (no commission) and doctor placement (30% commission). Break-even analysis needed for Mitch by Friday.

22/25
Target C: Clinical Workflow & Network Adoption
Parked

Deprioritized per Brittney — current rollout is live and working. May 5th refresher training + Workday LMS module address immediate needs. Will become priority when SGA East rollout begins.

20/25
Meeting Takeaways

Brittney validated the sprint output and found the problem mapping useful, especially the Curodont treatment journey and the margin-by-provider analysis. Key feedback:

  • Provider economics already resolved in direct conversations — doctors keeping 30% commission, no flat fee structure
  • Sliding scale is a must — Brittney drafted one: $120/tooth (1) down to $75/site floor at 5+. Meeting with Julia in finance to validate.
  • Custom DOT codes (D2991.1, .2, .3) raised as concernResearch update: Suffixes ARE stripped on 837D electronic claims, but this is by design and the recommended approach. Open Dental, Dentrix (alias codes), and Eaglesoft all support this. Suffixes manage internal pricing; only D2991 transmits to insurance. This is how DSOs manage sliding scales.
  • External benchmarking contradicts internal RCM data — Aspen Dental and Heartland both report 80-90% UCR. Internal team reported 50% and $45-50 reimbursements in one day of research. Brittney does not trust the internal analysis was thorough.
  • UCCI confirmed problem child — paying $4/treatment, no balance billing. Peak Dental in Colorado confirms, says they "take the hit."
  • Delta Dental Kansas City paying $35 — Carrie's team called but didn't ask about balance billing (the real question).
  • New applicator training gap — Gen4/SGA West teams trained on old applicator. Dr. Shanahan pushing back on 1:1 ratio citing "biochem" without specifics. May 5th refresher + Workday LMS planned.
  • "Election to self-pay" form from legal — Mitch's recommendation. Question: is this necessary, or should we treat D2991 like any other new CDT code?
Tuesday — Phase 2
Solution Sketching
Five distinct approaches to the insurance billing compliance and pricing strategy challenge for Curodont D2991 across 260 practices.
Sprint Questions Being Solved
From Monday
  • SQ1: Can we maintain $120 UCR and protect cash flow when D2991 has a 70-85% denial rate and RCM is too small to chase claims?
  • SQ2: What sliding scale maintains the $80+ DSO margin floor while satisfying doctor demands?
  • SQ3 (New): Do we need special forms/processes, or should we treat D2991 like any other new CDT code?
Verified D2991 Reimbursement Data
Published fee schedules and documented payer policies — not self-reported estimates. These are facts, not opinions.
Confirmed Payer Rates for D2991
Verified Sources
PayerRatePlan TypeBalance Bill?Source
Delta Dental Oregon (PPO)$118.00Commercial PPOPer contractPublished fee schedule PDF
Colorado Medicaid (DentaQuest)$56.30Medicaid FFSN/ADentaQuest fee schedule, eff. 10/1/2025
Pennsylvania Medicaid$44.16MedicaidN/APA Medical Assistance fee schedule
Delta Dental MichiganPlan-dependentCommercialPer contractPublished clinical criteria — covered 2x/tooth/year
UCCI FEDVIPCoveredFederalN/AOPM brochure — ages 1-6: 2/tooth/12mo, 7+: 1/tooth/12mo
Arkansas BCBSNot coveredCommercialFull UCR (non-covered)AR BCBS CDT 2025 manual
Delta Dental KC$35.00UnknownNot askedCarrie Peterson's office called
UCCI TDP$4.42TRICARE DentalNoCarrie Peterson's office called
UCCI Advit$4.61CommercialNoCarrie Peterson's office called
Craig Packer's patient$19.00UnknownUnknownSingle EOB report, 4/10

Key insight: Delta Dental OR pays $118 — nearly full UCR. Payers benchmarking D2991 to D2140 (one-surface amalgam) typically allow $100-170 on commercial PPO. The $4 UCCI rate and $35 Delta KC rate are outliers, not the norm. SGA's internal RCM one-day analysis that reported "50% of billed" is likely wrong — verified published rates tell a different story.

DSO Competitive Intelligence
Verified
  • Heartland Dental: Formal vVardis partnership. 125,323+ teeth treated. Uses VideaAI for caries detection + Curodont for treatment. 1,200+ practices, 34 states.
  • Aspen Dental: Per Brittney's contact, billing to insurance, 90-100% UCR enterprise-wide. Treating like any other code.
  • Peak Dental (CO): Collect upfront, submit to insurance, take the hit on UCCI. Practical, proven model.
  • vVardis market data: $85M total funding (OrbiMed). ~10% of US dental offices now offer Curodont. 1M+ teeth treated nationally since Jan 2024. 400K+ patients.
  • Material cost (open market): $35-38/applicator retail. SGA's $28 (via procurement negotiation) is significantly below market — this is a competitive advantage.
D4346 Adoption Curve (Precedent)
2017-2020 Data
  • CDT 2017: D4346 added. Initially treated by most payers as D1110 (prophy) equivalent.
  • 12-24 months: Before most commercial payers formally added D4346 to fee schedules.
  • Now (2026): Most plans cover, often at 1.5-2x prophy rate. Delta Dental OR: $80 (vs. $60-80 for prophy).
  • Revenue impact: Practices not billing D4346 for qualifying patients lose $150-200+ per patient.
  • Key lesson: Practices that submitted claims from day one drove payer adoption faster. Those that waited lost years of revenue and payer data.
  • D2991 projection: Expect similar 12-24 month window. SGA is 16 months into that window (CDT effective Jan 2024). Commercial coverage likely by mid-2026 to early 2027 for major payers.
D2991 Coverage by Major Carrier
Published coverage policies as of April 2026. Most carriers have not issued D2991-specific policies yet — the code is only 28 months old (CDT 2024, effective Jan 2024).
UnitedHealthcare Dental — Explicitly Denies D2991
Critical Finding

UHC published a clinical policy (effective Feb 2026, "Sealants and Hydroxyapatite Enamel Regeneration") that states: "Biomimetic products for the regeneration of tooth enamel are not indicated due to insufficient evidence of efficacy." D2991 is explicitly listed as a non-covered code. This is one of the largest dental carriers in the US. In states with NCS fee-capping laws, practices can charge full UCR on fully insured UHC plans. On ERISA/self-funded UHC plans, check PPO contract language.

Carrier Coverage Summary
CarrierD2991 StatusEst. AllowableKey Detail
Delta DentalCovered (plan-specific)$100–$140MI published clinical criteria: 2/tooth/benefit year. OR PPO confirmed $118. Gold-standard documentation template.
United Concordia (FEDVIP)Covered$100–$130 (est.)Ages 1-6: 2/tooth/12mo. Ages 7+: 1/tooth/12mo. Confirmed across 2024-2026 FEDVIP brochures.
MetLife (FEDVIP)Covered$90–$130 (est.)Listed in MetLife FEDVIP brochure. Specific allowance not published.
UnitedHealthcareNOT COVERED$0Explicit denial policy (Feb 2026): "insufficient evidence of efficacy." D2991 specifically named.
CignaUnknown / plan-specific$0–$120No published clinical policy for D2991. May deny or adjudicate by-report.
AetnaUnknown / plan-specific$0–$120No DCPB for D2991. Closest analogous policy: DCPB038 (resin infiltration).
BCBSUnknown / varies by state$0–$130No D2991-specific policy found. AR BCBS explicitly excludes. Other affiliates unknown.
GuardianUnknown / plan-specific$0–$120No published policy found.

What this means for SGA: Delta Dental, UCCI, and MetLife are the favorable payers. UHC is a hard no. Cigna, Aetna, BCBS, and Guardian are wildcards — SGA's own EOB data over the next 3-6 months will fill these gaps faster than any external research. This is why always submitting claims is non-negotiable: it generates the payer intelligence that doesn't exist publicly.

Medicaid Rates & D2140 Proxy by SGA State
D2991 is on almost no state Medicaid fee schedules yet. D2140 (one-surface amalgam) is the benchmark payers use when they do add D2991. Commercial PPO rates typically run 2-3x Medicaid.
StateSGA LocationsD2140 MedicaidD2991 MedicaidEst. Commercial PPONotes
AZ10~$72Not listed$115–$145AHCCCS. Delta AZ doesn't recognize D2991 as covered (per Shanahan).
CA19$39Not listed$100–$140Medi-Cal historically low. Commercial rates significantly higher.
IN2~$55–65Not listed$100–$130IHCP. Estimated from regional norms.
KS15~$55–65Not listed$95–$125KMAP. 20% increase to composite fillings eff. 7/1/2025. Delta KS called: $35 for D2991.
KY4$49.40Not listed$90–$120KY Medicaid 2025 fee schedule confirmed.
MI11$70.50Not listed$100–$140Delta MI published D2991 clinical criteria. $85M Medicaid redesign with fee increases.
MN5~$72Not listed$105–$135MHCP base + 98% add-on since 1/1/2022.
MO1~$72Not listed$95–$125MO HealthNet.
NM1$72Not listed$95–$125UHC manages NM Medicaid dental.
NV2$0 (amalgam)Not listed$100–$130NV Medicaid doesn't reimburse amalgam (composites only). D2991 status unknown.
OH8$78.60Not listed$110–$145ODM fee schedule eff. 1/1/2024. Fee increases from 2023 budget.
PA2$45$44.16$100–$135Only SGA state with D2991 on Medicaid. 1/tooth/lifetime. Eff. 5/28/2024.
TN1$66.62Not listed$95–$125TennCare adult dental benefit eff. 7/1/2025.
TX6$62.80Not listed$100–$140HHSC. $140M reallocation with increases to D2140-D2393 eff. 9/1/2025.
UT12$61.75Not listed$95–$13020% rural county enhancement available.
VA1$79.51Not listed$110–$145Cardinal Care Smiles (DentaQuest) fee schedule 7/1/2024.

Commercial PPO estimates are 2-3x Medicaid D2140 rates, consistent with the confirmed Delta Dental OR rate of $118. The D2140 proxy is relevant because payers benchmarking D2991 set initial allowable amounts comparable to a one-surface amalgam ($100-$170 commercial PPO nationally).

Non-Covered Services Fee-Capping Laws — SGA States
14 of 16 SGA states have laws preventing dental plans from dictating fees on non-covered services. Michigan and Utah do not. All laws apply only to fully insured plans — ERISA/self-funded plans (~65% of commercial) are exempt.
StateSGA LocationsNCS Law?YearImpact for D2991
AZ10Yes2011If payer doesn't cover D2991, charge full UCR on fully insured plans. Shanahan already does this.
CA19Yes2015Protected. Largest SGA footprint.
IN2Yes2015Protected.
KS15Yes2010Protected. Second-largest SGA footprint. Early adopter state.
KY4Yes2014Protected.
MI11NoNot protected. Bills introduced multiple sessions, never passed. Strong insurer lobby. PPO fee may cap D2991 even if non-covered.
MN5Yes2014Protected.
MO1Yes2014Protected.
NM1Yes2014Protected.
NV2Yes2013Protected.
OH8Yes2016Protected.
PA2Yes2014Protected. Also only SGA state with D2991 on Medicaid ($44.16).
TN1Yes2016Protected.
TX6Yes2013Protected.
UT12NoNot protected. Utah Dental Association actively advocating. Third-largest SGA footprint — 12 locations exposed.
VA1Yes2018Protected.

Watch states: Michigan (11 locations) and Utah (12 locations) have no NCS protection. Combined, that's 23 locations (23% of the 100 in the current system) where PPO contracts may cap D2991 fees even when payers don't cover it. These practices must collect upfront — they cannot rely on state law to protect full UCR collection.

The ERISA reality: Even in the 14 protected states, NCS laws only apply to fully insured plans. ~65% of commercially insured employees nationally are in self-funded ERISA plans exempt from state regulation. Practically, NCS protection covers roughly 30-35% of PPO patients. The collect-upfront strategy protects cash flow regardless of plan type or state law.

DPMS Custom Code Handling — Documented Behavior
Custom suffix codes (D2991.1, D2991.2, etc.) were initially raised as a concern. Research confirms they are the recommended approach for DSOs managing sliding scales.
The 837D Standard — How It Actually Works
Confirmed

The HIPAA 837D electronic dental claim format only accepts valid 5-character CDT codes (D + 4 digits). Custom suffixes are automatically stripped by every major DPMS before transmission. This is by design — it's how the industry manages internal pricing variants while maintaining clean claim submission.

DPMSFeature NameHow It WorksWhat Transmits on Claim
Open Dental Custom suffix codes Codes can be up to 15 chars internally. "All codes starting with D are shortened to 5 characters before being included on an insurance claim." D2991 only
Dentrix Alias codes "An alias code is a procedure code followed by a period and then a custom alphanumeric value up to 5 characters." Each alias has its own fee in every fee schedule. D2991 only (base ADA code)
Eaglesoft Service codes Separate "service code" (internal, patient-facing) and "ADA code" (claims). Create CURO1, CURO2, CURO3 service codes, all mapped to ADA code D2991. D2991 only

Bottom line: D2991.1 (1 tooth at $120), D2991.2 (2 teeth at $105/ea), D2991.3 (3 teeth at $95/ea), etc. are the correct implementation of a sliding scale in a multi-DPMS environment. Each variant has its own fee, staff selects by tooth count, the suffix handles internal tracking and reporting, and only D2991 goes to insurance. This is standard DSO practice.

"Won't the Suffix Stripping Collapse 5 Teeth Into 1 Line?"
No — Here's Why

This will come up. The concern: if D2991.5 gets stripped to D2991, does a 5-tooth case become one claim line at $75 instead of five lines at $75 each? No. The suffix controls the fee; the chart entries control the claim lines.

Example: D2991.5 charted on teeth #3, #5, #12, #14, #18

Claim LineCode on ClaimTooth #Fee
1D2991#3$75
2D2991#5$75
3D2991#12$75
4D2991#14$75
5D2991#18$75
Total billed$375

Why collapse cannot happen:

  • X12 RFI #1304 (the governing standard for 837D claims) explicitly rules: "It is only appropriate to submit quantity greater than one when there is no tooth number or oral cavity involved." Per-tooth codes must be separate lines.
  • The reason: The 835 remittance (ERA) has no tooth designation field. If 5 teeth were collapsed into one line and the payer denied one tooth, there would be no way to indicate which one was denied. Separate lines are required for A/R reconciliation.
  • How the DPMS works: When you chart D2991.5 on 5 teeth, the system creates 5 separate procedure entries in the patient chart, each with its own tooth number and $75 fee. The suffix tells the system which fee to pull. The claim generator then creates one service line per procedure entry. Stripping ".5" from the code string has zero effect on the number of rows.
  • This is standard for all per-tooth codes. Five D2150 fillings on five teeth = five claim lines. Five D2991 applications on five teeth = five claim lines. Same mechanism, same result.

Bottom line for Mitch: The suffix code is a fee lookup mechanism only. It tells the DPMS "this is a 5-tooth case, use $75/tooth." The claim structure is driven by how many teeth were charted — those are independent data structures. The payer sees five standard D2991 lines, each with a tooth number, each at $75. Total billed: $375. This is exactly how every other per-tooth code in dentistry works.

Balance Billing Decision Tree for D2991
The balance billing question has a specific, state-dependent answer. This is not ambiguous.
Decision Tree
Legal Review Needed
  • Step 1: Is D2991 a covered benefit under the patient's specific plan?
    • YES (covered, regardless of actual payment) → PPO fee applies, cannot balance bill the write-off
    • NO (explicitly excluded / not a covered benefit) → Proceed to Step 2
  • Step 2: Is the plan fully insured or self-funded (ERISA)?
    • Fully insured → State non-covered services law applies (CO/AZ/KS all have them). Charge full UCR.
    • Self-funded / ERISA (~65% of commercial plans) → State law does NOT apply. Check PPO contract language for catch-all provisions.
  • Step 3: What does the PPO contract say about codes not in the fee schedule?
    • Some contracts treat unlisted codes as non-covered (charge UCR)
    • Some assign a "closest comparable" fee (likely D2140 at $100-170)
    • Some have a catch-all capping all services

Critical finding: The ERISA exemption means ~65% of commercial plans are NOT protected by state fee-capping laws. The "44 states protect non-covered services" narrative is true but only covers ~35% of patients. This is why the collect-upfront strategy matters even more.

What Clinical Presidents Are Actually Saying
Direct quotes from the clinical president chat (April 8-14). These are the people who make or break the rollout.
Dr. Craig Packer (Rock Hotel Dental)
Threatening to Stop
  • "Patient needs 13 sites. They refused treatment because it's too much money." — At $120/tooth, that's $1,560.
  • "At this price our office will stop doing this procedure. Only two of us are doing it right now."
  • "I asked my OM to call all insurances... She said nobody has time. RCM told her they won't do it either."
  • "We haven't sent any off to insurance yet. Comparing it to SDF rates, they could be really low."
  • Heritage comparison: charges $44/surface, treats adjacent teeth for free with one applicator.
Dr. Bryan Shanahan (Peak AZ)
Halted at Peak
  • "I have been told RCM will NOT allow us to change curodont fees. Therefore Peak will NOT be doing any curodont."
  • "In 35 years of doing this I have many times come across what the company says and it does not align with reality."
  • "I personally am not 100% convinced in this product... being mandated on there is no wiggle room has me feeling like I am being told what treatment to give my patients."
  • Biochem objection on 1:1 ratio — no specifics provided despite being asked.
  • Delta AZ: doesn't recognize as covered → "we can charge what we want."
Dr. Carrie Peterson (Topeka Dentistry)
Paused
  • "We are going to hold off at Topeka Dentistry for a harder push until we have an idea on the math of reimbursement."
  • Had her insurance coordinator call payers directly: Delta KS $35, UCCI TDP $4.42, UCCI Advit $4.61.
  • "We are running out of 'grace' to implement things with our team only to have it be bumpy, messy, and back pedal at the end."
  • Did NOT ask about balance billing — the critical missing question.
Trish Takacs
Confused
  • "My concern is the 1:1 ratio. Which equates to one site and not 'up to 3 teeth' that can be treated?"
  • Teams were trained on V1 applicator — V2 has different 1:1 protocol.
  • Refresher not on her calendar, hygiene team unaware.
  • This is exactly the training gap May 5th needs to fix.
The Pattern

Three clinical presidents have either stopped or paused Curodont. The common thread is not the product — it's uncertainty about economics. They don't have clear answers on: (1) what insurance actually pays, (2) whether they can balance bill, (3) what a multi-site case should cost the patient. The sprint must deliver these answers or adoption dies.

"Election to Self-Pay" Form — Assessment
Mitch's legal team produced this form. Brittney shared it. Here's the analysis.
What the Form Says

References HITECH Act (42 U.S.C. § 17935). Patient acknowledges:

  • They ARE covered by a dental insurance plan
  • They do NOT want the office to submit the claim to insurance
  • They understand they'll pay the full amount out-of-pocket
  • Payments will NOT count toward their deductible
  • They have "freely chosen" to self-pay after considering options
Why This Form Is Problematic for D2991
Risk
  • Contradicts D4346 lesson: The form instructs the practice NOT to submit to insurance. But building claims volume is exactly how you drive payer adoption.
  • Patient perception: Brittney: "it might feel slimy." Asking patients to waive insurance triggers suspicion.
  • PPO contract risk: Many PPO contracts require submission of claims for services rendered. Actively NOT submitting could be a contract violation.
  • Unnecessary if collecting upfront: You can collect full fee AND submit to insurance. No form needed to do that — just inform the patient their insurance may not cover it.
  • Recommendation: Do NOT use this form. Use a simple, one-paragraph acknowledgment that says "insurance coverage is uncertain, you're paying today, we'll refund if insurance covers it."
Brittney's Direct Contacts
First-hand intelligence from Brittney's conversations with other DSO leaders, supplementing the published data above.
Aspen Dental
Benchmark

1,000+ locations. Billing D2991 to insurance. Seeing 90-100% UCR. Charging ~$120/tooth. Treating it like any other code.

Heartland Dental
Benchmark

1,200+ practices. 80-90% UCR enterprise-wide. Some payers "not playing nice" but not earth-shattering. Formal vVardis partnership with 125K+ teeth treated.

Peak Dental (CO)
Cautionary

Colorado DSO. Collect upfront, submit to insurance, refund if paid. UCCI pays $4 — "we take the hit." This is the model SGA should follow.

The "Just Another Code" Model
Treat D2991 exactly like every other CDT code. No special forms, no upfront collection, no custom processes. Submit to insurance, collect patient responsibility normally.
How It Works
Simple
  • Step 1: Place Curodont, enter D2991 into DPMS with standard UCR ($120)
  • Step 2: Submit claim to insurance with diagnosis code K02.61 (arrested dental caries)
  • Step 3: Insurance pays or denies. If denied, patient responsibility per normal collections
  • Step 4: Balance bill where PPO contract allows. Write off where it doesn't.
  • Sliding scale: Custom suffix codes in DPMS (D2991.1 = $120, D2991.2 = $105/ea, D2991.3 = $95/ea, D2991.4 = $85/ea, D2991.5 = $75/ea). Suffixes stripped on claims — standard DPMS behavior per Open Dental/Dentrix/Eaglesoft documentation.
Cross-Industry Inspiration

D4346 (gingivitis scaling) in 2017. When this code launched, practices that treated it like any other code and kept submitting claims drove payer adoption faster than those who avoided billing. Volume of claims forces payer recognition. Same playbook that Aspen and Heartland are running.

PROS
  • Zero process overhead — nothing new for front desk or RCM to learn
  • No compliance risk from special forms
  • Builds claims volume that drives payer adoption (D4346 lesson)
  • Consistent with how Aspen and Heartland operate
  • Doctors stop feeling like this is "different"
CONS
  • Cash flow risk — RCM must chase payments on denied claims
  • RCM says their team is too small for the volume
  • Unknown balance billing rights for many payers
  • May need to write off UCCI cases entirely ($4 + $28 cost = $24 loss per treatment)
  • Doctors frustrated by uncertainty may slow adoption
RISK PROFILE
  • Compliance: Low (standard billing)
  • Cash flow: Medium-High (delayed collections)
  • Complexity: Very Low
  • Doctor buy-in: High (familiar process)
  • DSO margin at risk: 15-25% of treatments during adoption window
Collect Upfront, Submit & Refund
Patient pays full fee at time of service. Claim still submitted to insurance. If insurance pays, patient gets a refund. Protects cash flow during the D2991 adoption window.
How It Works
Moderate
  • Step 1: Patient signs consent acknowledging insurance may not cover D2991, agrees to pay full fee upfront
  • Step 2: Collect $120 (or sliding scale amount) at chair
  • Step 3: Submit D2991 claim to insurance with K02.61 narrative
  • Step 4: If insurance reimburses, refund patient the insurance portion
  • Form options: Mitch's "Election to Self-Pay" form from legal, OR a simpler "Insurance May Not Cover" acknowledgment (not a waiver from billing)
  • Sliding scale: Same quantity tiers. D2991.1=$120, D2991.2=$105/ea, D2991.3=$95/ea, D2991.4=$85/ea, D2991.5=$75/ea
Cross-Industry Inspiration

Peak Dental Services (Colorado). This is exactly what Peak runs for Curodont. They told Brittney directly: "It makes more sense to have them pay upfront and then let them know insurance will pay or it won't. We'll reimburse if it does. That way you're not chasing money, you're refunding money." This is also similar to how elective medical procedures (LASIK, cosmetic) handle insurance uncertainty.

PROS
  • Cash flow protected — money in hand before claim processes
  • RCM workload reduced (refunding is easier than chasing)
  • Still builds claims volume for payer adoption
  • Patient gets a pleasant surprise if insurance pays
  • Peak Dental validates this works in the real world
CONS
  • Extra form = extra step at chairside (doctor frustration point)
  • Patient may hesitate signing — Brittney: "it might feel slimy"
  • Refund process adds admin work (though less than collections)
  • Different from every other procedure — "why is this one special?"
  • Compliance question: does "election to self-pay" create balance billing exposure?
RISK PROFILE
  • Compliance: Medium (form language matters)
  • Cash flow: Very Low (collected upfront)
  • Complexity: Medium (form + refund workflow)
  • Doctor buy-in: Medium (extra step frustrates some)
  • DSO margin at risk: <5% (only UCCI-type outliers)
Payer-Tiered Smart Routing
Categorize every payer into tiers based on known D2991 behavior. Route each patient through the optimal billing workflow automatically based on their insurance.
How It Works
Complex
  • Tier 1 — Pays Well (≥80% UCR): Submit claim normally. Collect copay at chair. Standard dental billing. (Target: most major payers within 12-18 months)
  • Tier 2 — Pays Poorly (20-79% UCR): Collect upfront, submit claim, refund insurance portion. Balance bill where contractually allowed.
  • Tier 3 — Doesn't Recognize / Hostile: Collect full fee upfront. Still submit claim to build volume. No expectation of payment. (UCCI lives here)
  • Implementation: Build a payer lookup table in the DPMS or a shared spreadsheet. Front desk checks insurance before appointment, knows which workflow to follow.
  • Sliding scale: Same across all tiers. Payer tier affects billing workflow, not patient pricing.
Cross-Industry Inspiration

Pharmacy Benefit Manager (PBM) routing. When pharmacies dispense medications, the system automatically checks the patient's PBM, knows the copay tier, and routes the transaction accordingly. Some drugs are covered, some need prior auth, some are cash-pay. The pharmacist doesn't decide — the system routes. Same principle: don't make front desk guess, give them a lookup.

PROS
  • Optimizes revenue per payer — never leaves money on the table
  • Adapts as payers add D2991 to fee schedules (just move them to Tier 1)
  • Front desk gets clear instructions per patient
  • Can be automated into SGA platform eventually
  • Best long-term architecture as payer landscape evolves
CONS
  • Requires building and maintaining payer database across 260 practices
  • Different DPMS systems complicate lookup (Brittney flagged this)
  • Training burden — 3 workflows instead of 1
  • Initial data collection is manual and incomplete (RCM couldn't even answer basic questions)
  • Overkill for current scale of Curodont placements
RISK PROFILE
  • Compliance: Low (each tier is compliant on its own)
  • Cash flow: Low (protected in Tier 2/3)
  • Complexity: High (multi-workflow, payer DB)
  • Doctor buy-in: Medium (smart but they don't want complexity)
  • DSO margin at risk: <10% (optimized per payer)
Non-Covered Service Strategy (State-by-State)
In states where legally permissible, classify D2991 as a non-covered service and collect full UCR without submitting to insurance. Maintain parallel billing track where required.
How It Works
Legal Complexity
  • Colorado (SB17-190): Dental plans cannot dictate fees for non-covered services. If a payer doesn't cover D2991, the practice CAN charge full UCR. This is not balance billing.
  • Arizona (per Dr. Shanahan): Delta Dental AZ doesn't recognize D2991 as covered. "We can charge what we want."
  • 44 states have similar protections per Monday's legal analysis
  • Catch: You must still submit the claim. The non-covered classification is the payer's decision, not the practice's. The "non-covered services acknowledgment form" doesn't give permission to skip billing.
  • Sliding scale: Same quantity tiers. Patient always pays the practice price. Insurance is irrelevant in non-covered states.
Cross-Industry Inspiration

Cosmetic dermatology. Botox for cosmetic purposes is never submitted to insurance. The provider charges their fee, patient pays, done. But when the same Botox is used for migraines (medical necessity), it goes through insurance. The same product has two billing pathways depending on classification. Curodont could follow this — where payers classify it as non-covered, it's a cash service; where they recognize it, it's a billable procedure.

PROS
  • Maximum revenue protection in non-covered states
  • No insurance games — clean cash transaction
  • Dr. Shanahan already operates this way in AZ
  • Colorado law explicitly supports this model
  • Zero RCM overhead for non-covered payers
CONS
  • Must still submit claims — can't just skip billing even with non-covered classification
  • Fails the D4346 lesson: not submitting claims delays payer adoption
  • State-by-state legal variation creates compliance patchwork
  • SGA operates in multiple states — can't have one universal policy
  • Brittney explicitly rejected the original non-covered form approach
RISK PROFILE
  • Compliance: Medium-High (state law research required per state)
  • Cash flow: Very Low (full collection)
  • Complexity: High (multi-state compliance)
  • Doctor buy-in: Mixed (AZ doctors love it, others uncertain)
  • DSO margin at risk: <5% but slows industry-wide payer adoption
Hybrid: Upfront Collection + Volume Billing + Sliding Scale
Combine the best elements: collect upfront for cash flow protection, always submit claims for payer adoption, use Brittney's sliding scale with margin floors, and build the payer intelligence database passively.
How It Works
Recommended
  • Step 1 — Sliding scale in DPMS: Custom suffix codes per Brittney's pricing strategy. D2991.1 (1 tooth=$120), D2991.2 (2=$105/ea), D2991.3 (3=$95/ea), D2991.4 (4=$85/ea), D2991.5 (5+=$75/ea). Suffixes stripped on 837D claims — confirmed by Open Dental, Dentrix, and Eaglesoft documentation. Each suffix has its own fee in the fee schedule.
  • Step 2 — Collect at chair: Patient informed insurance may not cover. Full sliding-scale amount collected at time of service. Use a simple, one-paragraph acknowledgment (NOT the complex "election to self-pay" form).
  • Step 3 — Always submit D2991: Every single placement gets billed to insurance with K02.61 narrative. This builds the claims volume that forces payer adoption. No exceptions.
  • Step 4 — Refund when insurance pays: If payer reimburses, refund patient the insurance portion. Pleasant surprise for patient, builds loyalty.
  • Step 5 — Passive payer intelligence: Track every EOB result in a shared spreadsheet or database. Over 3-6 months, SGA will have the most complete D2991 payer database in the DSO industry. This becomes the data that feeds Solution 3's smart routing later.
  • Step 6 — UCCI exception: For known hostile payers (UCCI at $4), flag in morning huddle. Doctor/hygienist makes clinical decision knowing margin is thin. Don't stop treatment — the clinical value is real — but practice is informed.
Why This Combines the Best of 1-4
  • From Solution 1: Always submit claims (D4346 lesson, Aspen/Heartland validated)
  • From Solution 2: Collect upfront (Peak Dental validated, protects cash flow)
  • From Solution 3: Build payer database passively (smart routing comes later when data is mature)
  • From Solution 4: In states where D2991 is non-covered, full UCR collection is legally protected anyway
  • Addresses Brittney's concern: No complex forms. Simple acknowledgment. Treat like a new code with one reasonable protection (upfront collection).
  • Addresses doctor frustration: Sliding scale gives them the pricing flexibility they demanded. Quantity-based, not DOT codes.
  • Addresses RCM capacity: They refund, not chase. The hard work is done at chairside.

Cross-Industry Inspiration

Subscription SaaS pricing tiers + insurance. When Salesforce sells to enterprises, they collect the full contract value upfront (annual billing), even though the customer's procurement team may negotiate credits or chargebacks later. The vendor is never in a position of chasing payment. They start with the money and adjust. Same principle: collect first, adjust later. The power position is always having the cash.

PROS
  • Cash flow protected from day one
  • Claims volume drives payer adoption (long game)
  • Sliding scale satisfies doctor demands
  • Simple acknowledgment, not a complex legal form
  • Builds proprietary payer intelligence database
  • Consistent with external benchmarks (Aspen, Heartland, Peak)
  • Evolves naturally into smart routing (Solution 3) as data matures
CONS
  • Still requires upfront collection (one extra step vs. Solution 1)
  • Refund processing adds some admin overhead
  • UCCI cases still lose money ($4 reimbursement vs. $28 cost)
  • Payer database requires someone to maintain the spreadsheet
  • Need legal review of acknowledgment language per state
RISK PROFILE
  • Compliance: Low-Medium (simple form, always submit claims)
  • Cash flow: Very Low (collected upfront)
  • Complexity: Low-Medium (one workflow, one form)
  • Doctor buy-in: High (sliding scale + familiar billing)
  • DSO margin at risk: <8% (UCCI outliers only)
Sliding Scale Economics
Brittney's draft sliding scale validated against DSO margin floors. All solutions use the same pricing — the difference is how insurance is handled.
Proposed Sliding Scale — Quantity-Based (Per Tooth)
Validated
Teeth DPMS Code Price/Tooth Total Fee Material Cost Hygienist Net Patient Savings Doctor Net*
1D2991.1$120$120$28$92$56
2D2991.2$105$210$56$154$30$91
3D2991.3$95$285$84$201$75$117
4D2991.4$85$340$112$228$140$126
5+D2991.5$75$375+$140+$235+$225+$123+

*Doctor net = price/tooth minus 30% commission minus $28 material. Source: Brittney's Curodont Pricing Strategy PowerPoint.

Key insight: Even at the $75 floor with doctor placement (worst case), DSO net is $24.60/tooth — well above Brittney's $10.50 break-even. The sliding scale works at every tier for both provider types. Dr. Packer's 13-site case: At $75/tooth (D2991.5 tier) = $975 total vs. $1,560 at flat $120. Patient saves $585 (37%). This is exactly the sliding scale that would have prevented that lost family.

Custom Suffix Codes — The Implementation
Recommended
  • D2991.1 = 1 tooth @ $120 | D2991.2 = 2 teeth @ $105/ea | D2991.3 = 3 teeth @ $95/ea | D2991.4 = 4 teeth @ $85/ea | D2991.5 = 5+ teeth @ $75/ea
  • Suffixes are stripped on 837D claims — this is by design. Only D2991 reaches the payer. The suffix manages internal pricing, reporting, and auditing.
  • Works in all 3 DPMS: Open Dental (truncates to 5 chars), Dentrix (alias codes), Eaglesoft (service code → ADA code mapping)
  • Why this beats manual fee override: Self-documenting, auditable across 260 practices, trainable ("how many teeth? pick the matching code"), consistent.
  • Per-tooth claim lines: Each tooth is a separate claim line with tooth number. 3 teeth = 3 lines of D2991, each with the D2991.3 internal fee ($95).
Break-Even Reference
For Mitch
  • Material cost per treatment: $28.00 ($279.99 / 10)
  • Hygienist floor (cost only): $28 — any fee above this is margin
  • Doctor floor (cost + 30% commission): $40 fee = $0 DSO net. $55 = $10.50 net.
  • Brittney's recommended doctor floor: $55
  • Brittney's recommended hygienist floor: $40
  • Proposed sliding scale floor ($75): Covers both provider types with margin to spare
Solution Scoring Matrix
Scored against the three sprint questions. Scale: 1 (poor) to 5 (excellent).
Criteria S1: Just Another Code S2: Upfront + Refund S3: Payer Tiered S4: Non-Covered S5: Hybrid
SQ1: Maintain $120 UCR + protect cash flow 25445
SQ2: Sliding scale with margin floor 44445
SQ3: Minimal special processes 53124
Cash flow protection 25455
Compliance safety 53424
Doctor buy-in 43234
RCM workload 14354
Drives payer adoption (long game) 55515
TOTAL 2832272636

Solution 5 (Hybrid) leads at 36/40 — it's the only approach that scores 4+ on every dimension.

Wednesday's decision session will stress-test Solution 5 against edge cases (UCCI, multi-DPMS, state compliance) and determine if it needs elements from other solutions blended in.

UCR Recommendation & Fully-Loaded Break-Even
Material cost alone doesn't tell the story. A Curodont placement consumes chair time, hygienist labor, and facility overhead. This analysis includes all costs.
What the Market Charges for D2991
Research-Backed
SourceUCR / ToothConfidence
Independent practices (multiple sources)$140–$175Confirmed (practice websites, dental billing sites)
Aspen Dental (1,000+ locations)~$120Per Brittney's direct contact
Heartland Dental (1,200+ practices)~$120Per Brittney's direct contact
vVardis marketing position$67–$167"Approximately 1/3 the cost of a filling" ($200-$500)
Industry UCR norm (4-6x material cost)$112–$168At SGA's $28 material cost
Delta Dental OR PPO allowable$118Confirmed (published fee schedule)
D2140 commercial PPO range (benchmark)$100–$170Confirmed (multiple state fee schedules)

SGA's $120 is on the low end of the market. Independent practices charge $140-$175. The DSO benchmarks (Aspen, Heartland) are at $120. The case for $120 is competitive alignment and stability — not that it's expensive. It is not expensive. This is critical messaging for the clinical presidents.

Fully-Loaded Break-Even Analysis
For Mitch

The previous break-even ($28 material cost) only captures product cost. A real break-even must include hygienist labor, overhead allocation, and doctor commission where applicable.

Assumptions (conservative)

Cost ComponentValueSource
Material cost$28.00 / applicatorSGA procurement ($279.99 / 10). Market rate $35-38.
Hygienist labor (5 min)$3.00Avg ~$36/hr across SGA states (BLS 2025). 5 min = $3.00.
Hygienist benefits/taxes (30%)$0.90Employer FICA, workers comp, benefits. ~30% of wage.
Office overhead allocation$6.00Industry average 62% overhead on collections. For a 5-min procedure generating $120: $120 × 0.10 overhead share ≈ $12. Conservative: $6 for incremental overhead (facility, utilities, supplies, sterilization).
Doctor commission (30%)$0 (hyg) / $36 (doc)Only applies when doctor places. $120 × 30% = $36.
Fully-loaded cost (HYGIENIST)$37.90$28 + $3 + $0.90 + $6
Fully-loaded cost (DOCTOR)$73.90$28 + $3 + $0.90 + $6 + $36

Margin by Price Point (Fully Loaded)

UCR FeeHyg CostHyg NetHyg MarginDoc CostDoc NetDoc Margin
$40$37.90$2.105.3%$49.90*-$9.90-24.8%
$55$37.90$17.1031.1%$54.40*$0.601.1%
$75$37.90$37.1049.5%$60.40*$14.6019.5%
$85$37.90$47.1055.4%$63.40*$21.6025.4%
$95$37.90$57.1060.1%$66.40*$28.6030.1%
$105$37.90$67.1063.9%$69.40*$35.6033.9%
$120$37.90$82.1068.4%$73.90*$46.1038.4%
$150$37.90$112.1074.7%$82.90*$67.1044.7%

*Doctor fully-loaded cost includes 30% commission on the UCR fee, which scales with price. Hygienist cost is fixed regardless of price point.

Fully-Loaded Break-Even Points

  • Hygienist placement: $37.90 — any fee above $38 is profitable. Even the $75 sliding-scale floor yields $37.10 net (49.5% margin).
  • Doctor placement: $73.90 — the $75 floor barely clears ($1.10 net). At $85 tier: $21.60 net. At $120: $46.10 net.
  • Brittney's previous floor of $40 (hygienist): Only $2.10 net when fully loaded. Too thin. $75 minimum is correct.
  • Brittney's previous floor of $55 (doctor): Only $0.60 net when fully loaded. Barely above break-even. $85 minimum for doctor placement is safer.
Pricing Recommendation
For Friday
  • Keep $120 UCR as the base fee (1 tooth). It matches Aspen/Heartland, aligns with Delta PPO allowable ($118), and is already communicated. Changing it again creates more doctor frustration.
  • $120 is NOT expensive. Independent practices charge $140-$175. SGA is below market. The clinical presidents need to hear this — their perception is wrong because they don't have the market data.
  • The sliding scale solves the real problem. Packer's 13-site patient: $975 at D2991.5 tier vs. $1,560 at flat $120. That's a $585 savings (37%). The patient stays. The family stays.
  • SGA's $28 material cost is a competitive advantage. At market rate ($35-38), the hygienist fully-loaded break-even would be $45-48 instead of $37.90. SGA's procurement negotiation gives them ~$10/treatment more margin than competitors. This needs to be celebrated, not taken for granted.
  • Karen's insight holds: Keeping UCR at $120 tells payers "this procedure has value." If SGA drops to $90, payers will benchmark lower, and the entire industry's reimbursement ceiling comes down. SGA's 260-practice claim volume sets the market price.
  • Hygienist-first routing is the margin play. At $120, hygienist net is $82.10 (68.4%). Doctor net is $46.10 (38.4%). The $36 difference per treatment × thousands of placements = millions in DSO margin. This is the number that should make the provider shift argument for SGA leadership.
Concrete Next Steps
These are the specific deliverables and actions needed to move from analysis to implementation.
Immediate (Before Friday Meeting with Mitch)
This Week
  • 1. Finalize sliding scale with Julia (Finance): Validate Brittney's pricing strategy PowerPoint numbers: $120/$105/$95/$85/$75 tiers. Confirm DSO margin stays positive at every tier for both provider types. Produce a one-page break-even summary for Mitch.
  • 2. Draft the simple acknowledgment form: Replace the "Election to Self-Pay" form with a one-paragraph acknowledgment: "Insurance coverage for this procedure is uncertain. You are paying [$amount] today. If your insurance reimburses us, we will refund you that amount." Get legal review.
  • 3. Build the payer intelligence one-pager: Compile the verified reimbursement data from this sprint (Delta Dental OR $118, CO Medicaid $56.30, UCCI $4, etc.) into a shareable reference document for the Friday meeting. Show doctors that $118 Delta PPO rate — it changes the conversation.
  • 4. Answer the clinical presidents: Respond to Packer, Shanahan, Peterson, and Takacs with specific answers from this research. They need to hear: sliding scale IS coming, custom codes work in all DPMS, Aspen and Heartland are doing exactly what we're proposing.
Short-Term (Next 2 Weeks)
Implementation
  • 5. Configure custom suffix codes in each DPMS: RCM or practice managers create D2991.1 through D2991.5 with the sliding-scale fees. Each suffix maps to D2991 on claims. Specific setup steps differ by system (Open Dental: procedure code editor; Dentrix: alias codes; Eaglesoft: service codes).
  • 6. Submit claims for EVERY placement: No exceptions. Even when expecting denial. Every claim builds payer data and accelerates D2991 adoption. This is the D4346 lesson.
  • 7. Start tracking EOBs in a shared spreadsheet: Payer name, plan type (fully insured vs. self-funded), D2991 allowed amount, balance billing allowed (Y/N), date. Over 3-6 months this becomes the most complete D2991 payer database any DSO has.
  • 8. May 5th refresher training: V2 applicator protocol, 1:1 ratio education, address Shanahan's biochem objection with vVardis white papers, deploy Workday LMS module.
Medium-Term (60-90 Days)
Evolution
  • 9. Analyze EOB data and build payer tiers: Once 100+ EOBs are collected, categorize payers into Tier 1 (pays well), Tier 2 (pays poorly), Tier 3 (hostile). This is Solution 3 activated by real data.
  • 10. Review ERISA vs. fully insured split: For SGA's specific patient population, determine actual exposure. If most patients are on fully insured plans, state fee-capping laws protect UCR collection. If heavily ERISA, adjust strategy.
  • 11. vVardis negotiation leverage: With 260 practices submitting claims and 3 months of data, SGA has leverage to negotiate pricing if insurance reimbursement consistently underperforms.
  • 12. Power BI dashboard: Build D2991 executive visibility via Dental Intel → ClickHouse → Power BI. Production by code, provider, practice, payer reimbursement rates. No new infrastructure needed.
Wednesday Sprint: Decision & Storyboard
  • Finalize the billing workflow — step-by-step from morning huddle identification through EOB processing
  • Produce the draft acknowledgment form — simple, one paragraph, not the Election to Self-Pay
  • Build the DPMS configuration guide — specific instructions for Open Dental, Dentrix, and Eaglesoft suffix code setup
  • Create the payer intelligence tracker template — the spreadsheet every practice uses to log EOBs
  • Draft the clinical president communication — the email/message that responds to their specific concerns with data
Wednesday — Phase 3
Decision
Solution 5 (Hybrid) selected. Passive payer intelligence (Step 5) removed. Implementation storyboard and billing workflow mapped.
Decision: Solution 5 — Hybrid Approach (Modified)
Selected

Collect upfront + always submit claims + sliding scale via custom suffix codes. This approach scored 36/40 in the comparison matrix — the only solution scoring 4+ on every dimension.

  • Step 1: Configure D2991.1 through D2991.5 suffix codes in each DPMS with sliding-scale fees
  • Step 2: Collect full sliding-scale amount at time of service with simple acknowledgment
  • Step 3: Always submit D2991 to insurance (every placement, no exceptions)
  • Step 4: Refund patient if insurance reimburses
  • Step 5: Passive payer intelligence database Removed
  • Step 6: Morning huddle flag for known hostile payers (UCCI)
Why Step 5 (Passive Payer Intelligence) Was Removed
  • Too cumbersome: Tracking every EOB result in a shared spreadsheet across 260 practices requires data entry discipline that doesn't exist at the practice level today.
  • Not needed for the decision at hand: The billing workflow (collect upfront, submit, refund) works identically regardless of payer. The payer intelligence is a "nice to have," not a requirement.
  • Existing tools cover it: Dental Intel already captures production by code. If SGA needs payer-level D2991 data later, it can be pulled from Dental Intel or the clearinghouse — not manual spreadsheets.
  • Still available as a future enhancement if leadership wants to build payer tiers (Solution 3) later. The door isn't closed — it's just not part of the initial rollout.
The Billing Workflow — Step by Step
What actually happens from the moment a candidate is identified to the moment the ERA posts.
#StepWhoWhat HappensDPMS Action
1Morning HuddleHygienist + DoctorFlag patients with caries history, white spots, incipient lesions on BWX, high CRA scores. Note any known hostile payers (UCCI).Review schedule in Dental Intel or DPMS.
2Patient IdentificationHygienistDuring prophy/exam, identify specific teeth with incipient non-cavitated lesions suitable for Curodont. Count teeth.Note tooth numbers.
3Case PresentationHygienist or Doctor"We can treat these early cavities without drilling for [$amount]. Your insurance may or may not cover this — if they do, we'll refund you." Use sliding scale: 1 tooth = $120, 5+ = $75/ea.
4Patient ConsentFront DeskPatient signs simple acknowledgment (one paragraph — NOT the Election to Self-Pay form). Collect full fee.Enter payment in DPMS.
5TreatmentHygienist (preferred) or DoctorPlace Curodont per V2 applicator protocol. 1 applicator = 1 tooth (1:1 ratio). 3-5 min added chair time.
6ChartingHygienist / DoctorChart D2991.[1-5] on each treated tooth. System assigns the correct sliding-scale fee per suffix code.Enter D2991.X on each tooth number. Fee auto-populates from fee schedule.
7Claim GenerationRCM / AutoDPMS generates claim. Suffix stripped → each tooth becomes a separate D2991 line with tooth number and fee.Attach K02.61 diagnosis code. Include clinical narrative.
8Claim SubmissionRCMSubmit to insurance. Every placement, every time, no exceptions. Even when expecting denial.Batch submit via clearinghouse.
9ERA ProcessingRCMInsurance pays, partially pays, or denies. Post payment to patient account.Post ERA. Flag if payer paid.
10Patient RefundFront Desk / RCMIf insurance paid, refund patient the insurance portion. "Good news — your insurance covered part of your Curodont treatment."Process refund in DPMS. Patient gets pleasant surprise.
What Actually Changes vs. Today
Most of the workflow is already in place. The changes are small and specific.
WHAT CHANGES
  • Sliding scale replaces flat $120: 5 suffix codes in the DPMS fee schedule. One-time setup.
  • New acknowledgment form: One paragraph. Replaces the Election to Self-Pay form AND the old non-covered services form.
  • Always submit to insurance: Some practices weren't submitting. Now every placement gets a claim. No exceptions.
  • Refund workflow: If insurance pays, refund the patient. This is new but simple.
WHAT STAYS THE SAME
  • $120 UCR (1 tooth): No change to the base price.
  • Doctor 30% commission: No change to compensation structure.
  • Hygienist-first placement: Continue driving toward hygiene chair.
  • Morning huddle identification: Already happening.
  • Clinical workflow: Same V2 applicator protocol. May 5th refresher addresses training gaps.
Thursday — Phase 4
Prototype
Operational artifacts: acknowledgment form, DPMS configuration, clinical president executive summary, and Friday call script.
Patient Acknowledgment Form
Replaces both the "Non-Covered Services Acknowledgment" and the "Election to Self-Pay" form. One paragraph. No legal complexity. Does NOT instruct the practice to skip billing.

[PRACTICE NAME]

Curodont Treatment — Insurance Coverage Notice

I understand that Curodont (procedure code D2991) is a newer dental treatment and that my dental insurance plan may not yet cover this procedure. I am choosing to proceed with treatment today and am paying $________ for treatment of ____ tooth/teeth at the time of service.

My dental office will submit a claim to my insurance company on my behalf. If my insurance company reimburses any portion of this treatment, the office will refund me that amount.

I have had the opportunity to ask questions about this treatment and its cost, and I am satisfied with the information provided.

Patient Name: ____________________________

Patient Signature: ____________________________

Date: ____________________________

Provider: ____________________________

WHY THIS FORM WORKS
  • Patient knows they're paying today — no surprise
  • Patient knows a claim WILL be submitted — we're not hiding anything
  • Patient knows they get a refund if insurance pays — pleasant surprise
  • No waiver of insurance rights — no compliance risk
  • No instruction to skip billing — no PPO contract violation
  • One paragraph — takes 30 seconds to explain, 10 seconds to sign
WHY THE OLD FORMS DON'T WORK
  • Non-Covered Services Acknowledgment: Implied insurance wouldn't be billed. Created confusion about whether practices should submit claims.
  • Election to Self-Pay (Mitch's form): Patient directs practice NOT to submit to insurance. Contradicts D4346 strategy (always submit). PPO contract risk. "Feels slimy" (Brittney's words).
  • Both forms are more complex, longer, and create more questions than they answer.
DPMS Suffix Code Configuration
One-time setup per practice. Create these 5 codes in the DPMS fee schedule. Suffix is stripped on 837D claims — only D2991 transmits to insurance.
Internal CodeDescriptionFeeTransmits AsWhen to Use
D2991.1Curodont — 1 tooth$120D2991Single-tooth treatment
D2991.2Curodont — 2 teeth$105 / toothD29912-tooth same-visit treatment
D2991.3Curodont — 3 teeth$95 / toothD29913-tooth same-visit treatment
D2991.4Curodont — 4 teeth$85 / toothD29914-tooth same-visit treatment
D2991.5Curodont — 5+ teeth$75 / toothD29915 or more teeth same-visit

Setup by DPMS:

Open Dental

Lists → Procedure Codes → Add. Enter code as "D29911" through "D29915" (no period). Set fee in each fee schedule. System truncates to D2991 on claims automatically.

Dentrix

Office Manager → Procedure Code Setup → find D2991 → Create Alias. Enter "D2991.1" through "D2991.5". Set fee per alias per fee schedule. Base ADA code (D2991) transmits on claims.

Eaglesoft

Lists → Service Codes → Add. Create service codes "CURO1" through "CURO5". Map each to ADA code D2991. Set fee per service code. ADA code transmits on claims.

Clinical President Executive Summary — Friday Call
Designed for Dr. Packer, Dr. Shanahan, Dr. Peterson, and Trish Takacs. Addresses their specific concerns with data.

Curodont D2991 — Pricing & Billing Update

Prepared for Friday Clinical Presidents Call — April 2026

1. We Heard You — Sliding Scale Is Here

Based on your feedback, we've developed a volume-based sliding scale that reduces the per-tooth price for multi-site cases:

TeethPrice / ToothTotal (Example)Savings vs. Flat $120
1$120$120
2$105$210$30
3$95$285$75
4$85$340$140
5+$755 = $375 / 13 = $9755 = $225 / 13 = $585

Dr. Packer — your 13-site patient goes from $1,560 to $975. That's a 37% reduction. We believe this addresses the sticker shock without sacrificing margin.

2. $120 Is Below Market — Not Above It

We researched what other practices and DSOs charge for Curodont:

  • Independent practices: $140–$175 per tooth (national average)
  • Aspen Dental (1,000+ locations): ~$120 per tooth
  • Heartland Dental (1,200+ practices): ~$120 per tooth, 125,000+ teeth treated
  • SGA's material cost ($28): Below market rate of $35-38. Our procurement team negotiated this advantage.

At $120, SGA is at the low end of the market. We are not overcharging patients. We are aligned with the two largest DSOs in the country.

3. Insurance: What We Actually Know

We went beyond our internal RCM data and pulled published fee schedules:

  • Delta Dental (Oregon PPO): Pays $118 — nearly our full UCR
  • Delta Dental (Michigan): Published clinical criteria, covers D2991 2x/tooth/year
  • UCCI (FEDVIP): Covered with frequency limits
  • UnitedHealthcare: Explicitly does not cover D2991 (Feb 2026 policy)
  • UCCI TDP/Advit: $4 — confirmed outlier. Represents a small percentage of our payer mix.
  • Aspen and Heartland: Both report 80-90% UCR collection enterprise-wide

The D2991 code is following the exact same adoption curve as D4346 (gingivitis scaling) did in 2017. That code took 12-24 months for major payer adoption. We are 16 months in. Commercial coverage is coming. Every claim we submit accelerates that timeline.

4. What We're Changing

  • Sliding scale: Implemented via DPMS suffix codes (D2991.1 through D2991.5). One-time setup per practice. No manual fee overrides.
  • Always bill insurance: Every Curodont placement gets a claim submitted. We collect upfront, submit to insurance, and refund the patient if insurance pays. This is what Aspen and Heartland do.
  • New form: Simple one-paragraph acknowledgment replaces the old forms. Patient knows they're paying today, knows we're billing insurance, knows they'll get a refund if insurance covers it.
  • May 5th refresher: V2 applicator training for all Gen4 teams. Workday LMS module deploying.

5. What We're NOT Changing

  • $120 base fee (1 tooth): Stays. Below market. Aligned with Aspen/Heartland.
  • Doctor compensation: 30% commission. No change.
  • Clinical autonomy: Doctors and hygienists decide whether treatment is appropriate for each patient. This is a pricing and billing update, not a clinical mandate.

6. Specific Responses

  • Dr. Packer (13-site patient): At the 5+ tier, that patient pays $975 instead of $1,560. We hear you — multi-site pricing was the gap. Sliding scale fills it.
  • Dr. Shanahan (biochem objection on 1:1 ratio): We've asked vVardis to address this directly at the May 5th refresher with published data. The V2 applicator protocol is different from V1 — the peptides are in the sponge, not the liquid.
  • Dr. Peterson (halted at Topeka): The insurance data above shows that $19 and $4 reimbursements are outliers, not the norm. Delta pays $118. We need your practices submitting claims to build the payer data that resolves this uncertainty.
  • Trish Takacs (1:1 ratio confusion): May 5th refresher is the answer. V1 training said "up to 3 teeth" — V2 protocol is 1 applicator = 1 tooth. We'll address this directly.
D2991 Clinical Narrative Template
Attach this narrative to every D2991 claim. Consistent documentation reduces denials and supports appeals.

Patient presents with incipient non-cavitated carious lesion(s) on tooth/teeth [#]. Radiographic and clinical examination confirms early-stage demineralization amenable to regenerative therapy. Curodont Repair Fluoride Plus (vVardis), a self-assembling peptide (P11-4) hydroxyapatite regeneration medicament, was applied per manufacturer protocol using the Version 2 single-use applicator system (1:1 applicator-to-tooth ratio). Procedure performed under [direct/general] supervision of [Dr. Name]. Diagnosis: K02.61 (Dental caries on smooth surface, limited to enamel). This treatment is a conservative alternative to restorative intervention, preserving natural tooth structure.

Morning Huddle — Curodont Quick Check
30 seconds per patient. Add to existing huddle, don't replace it.

For each hygiene patient on today's schedule, check:

  • Caries risk: Moderate or high CRA? Previous caries history?
  • Radiographs: Incipient lesions on BWX? White spots noted in chart?
  • Insurance flag: Is patient on UCCI? (If yes, note: treatment is still clinically appropriate but margin is thin. Clinician decides.)
  • If candidate: Note in schedule "Curodont candidate — [X] teeth." Hygienist prepares applicators and fee discussion.
Operatory Quick Reference Card
Print-ready. Post in each operatory for hygienist reference during case presentation.

Curodont Pricing Guide

Treat the cavity without drilling — at a fraction of the cost of a filling

TeethPer ToothDPMS CodeYou Save
1$120D2991.1
2$105D2991.2$30
3$95D2991.3$75
4$85D2991.4$140
5+$75D2991.5$225+

Your insurance may cover this — we'll bill them and refund you if they do.

A typical filling costs $200–$500. Curodont preserves your natural tooth.

Friday
Test & Validate
Pilot program design, KPI tracking framework, and executive summary.
🔍

Pending Thursday Prototype

Friday will design the pilot program (10-15 practices), define success metrics, build the risk register, and produce the executive summary for leadership presentation.