Are Dental Practices Overpaying for Membership Plan Compliance?
Compliance is essential for structuring legal, transparent dental membership plans and safeguarding practices. Practices & groups in non-regulated states spend thousands annually contracting with Discount Plan Organization (DPOs) when DPO compliance is not required in every state.
Practices in non-regulated states spend thousands annually contracting with Discount Plan Organization (DPO’s) who lead practices to believe that DPO compliance is required in every state.
The truth is that many states do not require a DPO license and some states do not regulate discount plans at all. The consequence of overcompliance is unprofitable plans or expensive plans that do not serve patients who need to access oral care.
The Root of Compliance Confusion

Payer Networks

Discount Plan Organizations (DPOs)
Companies obtaining state DPO licenses to administer membership plans. Practices & groups agree to 15-30% discount off UCR and pay commissions to DPOs, but unlike with payer networks, no new patients are guaranteed. Many practices & groups mistakenly believe DPO administration is mandatory in every state for compliance.
Outcome: Practices & groups offer deep discounts and pay DPO commissions for compliance, often without added benefits.

Membership Plan Companies
Companies that combine software and services to enable practices & groups to market membership directly to their patients. Practices have the freedom to set their own fee schedules, price their own plans and market them directly to their patients, without having to pay a DPO administrator.
Outcome: Enabling practices to set their own fee schedules & plans that have the power to drive a meaningful increase in practice production.
Members are your very best patients, they visit regularly, fill your hygiene funnel and accept more treatment than uninsured patients. When making a decision on the vendor-partner who will help you grow these patients, consider these other factors:
- Alignment with your goals: does the vendor understand your strategic objectives, and are they committed to helping you achieve those?
- Is the vendor responsive, proactive & accountable? Are they invested in your long-term success?
- Are they honest & transparent in the sales process about their limitations (and about the needs for compliance)?
- Do they have deep industry knowledge, and are they committed to innovation?
Great partners don’t just sell a platform — they bring insights and best practices from across the industry.
Steps to Avoid Overpaying
By understanding state-specific requirements and critically evaluating vendor services, dental practices can ensure compliance without overpaying, keeping membership plans affordable and competitive.
- Research State Requirements
Visit your state’s insurance department website or contact them to verify if a DPO license is required. Many states have direct primary care agreement (DPC) legislation, which allows you to implement an in-office dental plan without having to register as an insurance company. - Scrutinize Vendors
Request detailed service breakdowns and evidence of necessity. Avoid long-term contracts without clear justification. - Consider Self-Administering
Apply for your own DPO license if needed (we can help!), or explore platforms like Plan Forward, which enable practices to manage plans directly without third-party involvement. - Leverage Professional Resources
The American Dental Association (ADA) and state dental associations can provide guidance.
Note : This guide pertains specifically to Plan Forward, not general membership plan software. Plan Forward empowers dental practices to administer plans independently and own their fee schedule, handling patient enrollment, plan selection, contracting, and fee collection without third-party intermediaries.