Virtual credit card claim payments: the 16 states where the ADA says a plan cannot make a fee-bearing card your only way to get paid

What it says#

The document is a five-page table from the ADA's dental insurance reform series, updated September 3, 2021, with contents the ADA says are current as of August 2021. Its introduction describes the laws in two sentences: "Virtual credit card laws generally prohibit dental plans from restricting claim payment modality in which the only acceptable payment method is a credit card payment. These laws generally require plans to alert dentists of a fee requirement to access the payment and to provide alternative, non-fee payment options." That is the whole of what the document says about the mechanism: a card payment can carry a fee to access it, and the laws exist so that a plan cannot make that the only way a dentist gets paid.

Sixteen states follow, each with a bill number and year. The largest group bars the card-only arrangement. Nebraska's law says a dental plan or provider contract "shall not include any restrictions on methods of claim payment for dental services in which the only acceptable payment method is a credit card payment." Georgia, Louisiana, North Carolina and Oklahoma are summarized to the same effect, and Arizona's entry extends it to an arrangement where "the only acceptable payment method is a credit card payment or an electronic funds transfer payment." Connecticut's entry bars certain carriers from requiring a dentist "to accept reimbursement for covered dental services by way of an electronic funds transfer or a virtual credit card." Indiana's "prohibits a health insurance plan from requiring a dental provider to accept virtual credit card payment methodology." The ADA writes several of these summaries in the conditional ("would prohibit"), for Arizona, Connecticut, Georgia, Louisiana, North Carolina and Oklahoma, so the enacted text should be checked before it is cited.

Several add a notice duty. In Georgia, Louisiana and Oklahoma, when a plan initiates or changes payment by electronic funds transfer, "including virtual credit card payments," it must notify the provider of any fees associated with a particular method, advise the provider of the available methods, and "provide clear instructions" on how to select an alternative. Indiana requires the same before the first electronic payment, for fees "other than the fees imposed by the dental provider's financial institution." Missouri bars a carrier from restricting payment to a method that requires the provider "to pay a fee, discount the amount of their claim for reimbursement, or remit any other form of remuneration in order to redeem the amount of their claim," requires notice and instructions when it changes methods, requires carriers to allow payment by ACH, and makes a violation an unfair trade practice.

Idaho and Texas set a floor instead of a prohibition: the plan must provide at least one method "that provides the dentist 100% of the contracted amount of the payment or reimbursement without the dentist incurring a fee to access the payment." Texas also requires the fees for each available method to be disclosed on the insurer's website and on a dentist's request. Utah and Vermont turn on the provider's election: Utah lets a provider "elect not to receive remittance through a credit card or other similar arrangement," requires the election to apply to the provider's entire practice rather than patient by patient, and bars insurers from requiring providers or insureds to accept card remittance; Vermont bars requiring a provider, "including a dentist or ambulance service provider," to accept card payment "unless the health care provider has affirmatively elected to receive payments in this manner," failing which the insurer pays another way.

Two states permit the fee-bearing card on conditions. Maryland and Oregon allow an insurer to pay by a card or EFT method that imposes a fee if the insurer notifies the provider in advance that a fee will apply, offers an alternative method with no fee, and the provider (or in Oregon a designee) elects to accept the fee-bearing method. Alabama is different again: its statute requires provider contracts to say that a request for payment by ACH electronic funds transfer "must be honored" and may not be used to delay or reject a transaction, but it "does not prohibit or adopt any standards for other methods" and expressly permits wire transfer and "payment by card or otherwise through a private card network."

Who it applies to#

A dental office in one of the 16 states that receives claim payments by virtual credit card from a plan, insurer or carrier the statute reaches, and wants a no-fee route to the money. The Connecticut, Idaho, Indiana, Louisiana, Nebraska, North Carolina, Texas and Vermont entries are written around dentists or dental claims; the others speak of health insurers and health care providers generally. The document does not say which plans each statute binds, and it does not address self-funded employer plans or any federal question; those belong with counsel.

An office in one of the 34 states and the District of Columbia not in the table has no statute in this document to cite. The ADA's introduction still describes the practical ask, a no-fee alternative and notice of fees, and nothing in the document says a plan may not be asked for one without a statute.

What changed#

First edition on this site. The ADA's table is a snapshot as of August 2021 and the ADA has not published a later version at this address; its dental insurance reform page lists 2025 and 2026 federal letters, including two 2024 letters on fees for electronic funds transfers, but no updated state table. The 16 entries run from 2015 (Alabama, Oregon) to 2021 (Idaho, Indiana, Vermont). A state that acted after August 2021 will not appear, and a bill number is a pointer to the enrolled act, not its current codified text.

Where the source is#

The document is the PDF at the ADA's dental insurance resources site, "Dental Insurance Reform: Virtual Credit Cards, Claim Payment Restrictions," copyright 2021 American Dental Association, updated September 3, 2021, 5 pages; it downloaded directly and its text was read in full. It carries the ADA's disclaimer that the materials are not legal advice and that links go to the states' own sites. The ADA's dental insurance resources page and its dental insurance reform advocacy page, both linked above, loaded and were checked for a newer edition; none was found. The companion ADA table on assignment of benefits laws has its own entry in this directory.