The State counts prosthodontists. When a plan has none, it owes you one out-of-network.
California's own 2021 dental-network audit names prosthodontist as a specialty it counts — and says, in writing, that a plan must provide out-of-network access when a service isn't available in network. Here is the document, quoted.
The document
What this is — and who wrote it
This is not an advocacy paper. It is the State of California's own federal filing: the annual certification DHCS prepares for the federal government attesting that its Medi-Cal dental plans have an adequate network. The member's plan, Health Net, is Attachment B.
Source: DHCS, “Dental Managed Care — Network Adequacy Certification” (September 2021), pp. 1, 4. Health Net of California, Inc. is Attachment B (pp. 7–9).
Point 1 · It's on the list
Yes — the State expressly counts prosthodontists
The certification is explicit about which specialties make up the “specialist network” DHCS evaluates. A prosthodontist is named twice — once in the body of page 4, and again in the footnote that defines the specialist figure for every plan.
Page 4 — the body text
“To evaluate whether DMC plans meet the required ratio of one full-time equivalent network dentist to every 1,200 members, DHCS incorporated the following provider types into its calculations: endodontists, oral surgeons, orthodontists, pedodontists, and prosthodontists.”
Source: DHCS DMC Network Adequacy Certification (Sept 2021), p. 4.
Figure 4 footnote — the definition used for every plan
“Specialist network is comprised of: endodontists, oral surgeons, orthodontists, pedodontists, periodontists, and prosthodontists.”
Source: same certification — footnote to “Figure 4: Contracted Specialists,” which appears identically for each plan (e.g., Health Net, p. 9; Access Dental, p. 6).
So however you read it, “prosthodontist” is squarely one of the specialty types the State's auditors count as part of a Dental Managed Care plan's network. It is not an exotic or optional service — it is on the State's own list of what a compliant specialist network is made of.
(One small inconsistency in their document, for the record: the page-4 body lists five types and omits periodontists; the Figure 4 footnote lists six and includes them. Prosthodontists appear on both lists.)
Point 2 · The obligation when it's missing
No in-network specialist? The plan must provide one out-of-network.
In the very same paragraph, the certification states the rule that applies when the network falls short:
Page 4 — the out-of-network duty
“DHCS further reviewed DMC plans' policies and procedures to confirm that DMC plans have the ability, when required, to provide members with out-of-network access when services are not available within the network.”
Source: DHCS DMC Network Adequacy Certification (Sept 2021), p. 4.
In plain language: a plan is allowed to count specialists in aggregate — but if a member needs a covered specialty the plan doesn't actually have in network, the plan's certified obligation is to arrange and cover that care out-of-network. That mechanism is the — out-of-network care at no extra cost to the member when the can't deliver.
The catch
…but the audit never counts prosthodontists individually
Here is the part that matters for Sacramento County. The only specialist number the certification reports for Health Net is a single lumped total — never broken down by type, and self-reported by the plan.
“Figure 4: Contracted Specialists” lists one row — Specialists: Sacramento 58 · Los Angeles 185 — sourced to the “Plan Provider Network Report (May 2021).” There is no count of prosthodontists, and page 4 confirms there are “no established ratios for dental specialties delineated in either federal or state laws.”
Source: certification, p. 9 (Health Net Figure 4) and p. 4 (“no established ratios”). Specialist counts were not independently contract-sampled — per p. 2, fn. 3, the specialist population was too small to warrant the statistical sampling calculator DHCS applied to general dentists.
What it means here
Put the two halves together
The State's own 2021 filing establishes both halves of the member's position at once:
- A prosthodontist is a recognized, counted specialty — it's on DHCS's own list (page 4 and the Figure 4 footnote).
- When a plan has none in network, it must provide out-of-network access — page 4, in writing.
- And because the audit only reports a lumped, self-reported specialist total, it cannot be used to claim Health Net actually had a prosthodontist in Sacramento County. It never enumerates one.
So, in this case
Our directory investigation and the member's own search found no reachable in-network prosthodontist in Sacramento County. Under the State's certified framework, that doesn't end the obligation — it triggers it: the plan owes the member out-of-network access (a ). See how the methodology works.
Commentary is the editor's, clearly labeled; the quotations and figures above are verbatim from the DHCS certification (Sept 2021).
Read it yourself
We're quoting a public document — so here it is. 12 pages, dated September 2021.
Open the 2021 DMC Network Adequacy Certification (PDF)
Why this matters now
It's been 0 days and counting since Health Net began delaying this member's access to a prosthodontist in Sacramento County — the specialty the State's own audit says it counts, and must cover out-of-network when it's missing.