Medicare pays for some dental care now: the inextricably linked rule in 42 CFR 411.15(i), and how a dentist bills it

What it says#

Section 1862(a)(12) of the Social Security Act has excluded dental services from Medicare since the program began: no payment for items and services "in connection with the care, treatment, filling, removal, or replacement of teeth or structures directly supporting the teeth," with an exception for inpatient hospital services when the patient's medical condition or the severity of the procedure requires hospitalization. The regulation that carries the exclusion is 42 CFR 411.15(i).

In the Calendar Year 2023 Physician Fee Schedule final rule, announced November 1, 2022 and published November 18, 2022 at 87 FR 69404, CMS clarified its reading of that exclusion and rewrote 411.15(i). Paragraph (i)(3) now says that dental services "inextricably linked to, and substantially related and integral to the clinical success of, a certain covered medical service are not excluded," and that payment may be made under Parts A and B in the inpatient or outpatient setting. The rule then lists examples, "including, but not limited to": a dental or oral examination as part of a comprehensive workup before, and medically necessary diagnostic and treatment services to eliminate an oral or dental infection before or contemporaneously with, organ transplant, hematopoietic stem cell transplant, bone marrow transplant, cardiac valve replacement, valvuloplasty, chemotherapy for cancer, CAR T-cell therapy for cancer, and high-dose bone-modifying agents for cancer; reconstruction of a dental ridge done because of and at the same time as surgical removal of a tumor; stabilization or immobilization of teeth with reduction of a jaw fracture, and splints used with covered treatment of a condition such as dislocated jaw joints; extraction of teeth to prepare the jaw for radiation treatment of neoplastic disease; and, for head and neck cancer treated with radiation, chemotherapy or surgery, the exam before, infection treatment before or alongside, and treatment of dental or oral complications after. A 2025 paragraph adds the exam before and infection treatment before or alongside Medicare-covered dialysis for end-stage renal disease. Ancillary services incident to covered dental services, "including, but not limited to the administration of anesthesia, diagnostic x-rays, use of operating room," are paid too.

The CY 2023 rule also set up an annual process: CMS accepts public submissions of other clinical scenarios where dental care may be inextricably linked to a covered service and considers them in the next fee schedule rule. The CY 2024 rule used it to add head and neck cancer and the cancer drug therapies, and the CY 2025 rule to add dialysis. The CY 2025 fact sheet says CMS also sought comment on diabetes, autoimmune diseases requiring immunosuppressive therapy, sickle cell disease and hemophilia, and "remains committed to exploring" those links. The CY 2026 final rule fact sheet, dated October 31, 2025, has no dental section.

CMS's Medicare Dental Coverage page adds the operating conditions. "For dental services to be inextricably linked to other Medicare-covered services, different providers (like a doctor and a dentist) must coordinate care," and "if there's no documented evidence to support the exchange of information, or integration, between the health care providers furnishing the medical services and the dental services, Medicare won't cover and pay for dental services." A referral or an exchange of information between the physician and the dentist is the example given, and it must be documented in the medical record. Multiple visits are paid when clinically necessary, for instance several appointments to clear infection before a transplant.

Who it applies to#

Patients with Medicare Part A or Part B whose medical treatment is on the list, and the dentists who see them. CMS's page says Medicare covers these dental services provided by physicians, "including a dentist or dental surgeon," by non-physician practitioners, and by auxiliary personnel such as a hygienist under direct supervision as incident-to services. The work can be done in the dentist's office; in that setting the professional fee is paid under the Physician Fee Schedule at rates the Medicare Administrative Contractor sets. In a hospital outpatient department or ambulatory surgical center the facility fee is paid separately.

To bill, the dentist must be enrolled in Medicare: a DDS or DMD, licensed in the state where the services are furnished, acting within scope. Enrollment goes through PECOS or the paper CMS-855I, with the MAC taking about 45 days to review. A dentist who is not enrolled can furnish the services only incident to an enrolled practitioner's services, with that practitioner billing. Claims go on the dental 837D or 2024 ADA form, the professional 837P or CMS-1500, or the institutional form, with CDT or CPT codes; submitting the claim certifies that the service is inextricably linked. Since July 1, 2025 the KX modifier is required to identify linked services and an ICD-10 code is required on the dental form. For a denial to hand to a secondary payer such as Medicaid, the GY modifier goes on the excluded line. CMS says not to send attachments; the MAC will ask.

Medicare Advantage plans may cover routine dental as a supplemental benefit, and some state Medicaid programs cover dental for dual-eligible patients; both run outside this rule.

What changed#

Before 2023 Medicare paid for dental work in a short list of situations that CMS had recognized in manuals, mainly jaw fracture, tumor surgery and extractions before radiation, and only where the dental work was incident to the medical procedure. The 2023 rule wrote a standard into the regulation, added transplant and cardiac valve cases to it, and created a door for more. Head and neck cancer, chemotherapy, CAR T-cell therapy and bone-modifying agents came through that door for 2024, and end-stage renal disease dialysis for 2025. The 2026 rule added nothing, so the list as of this entry is the 2025 list.

The billing side changed in 2025: the KX modifier moved from encouraged on January 1 to required on July 1, and the dental claim form now needs a diagnosis code. That is the mechanism by which a MAC tells a linked exam from a routine one.

Where the source is#

CMS's Medicare Dental Coverage page for providers, last modified March 10, 2026, carries the covered and non-covered lists, the coordination requirement, enrollment steps and claim instructions, with links to the three change requests and the collaborative-care MLN document. The regulation is 42 CFR 411.15 on eCFR. The three fee schedule fact sheets on cms.gov are the year-by-year record; the final rules themselves are on govinfo at 87 FR 69404, 88 FR 78818 and 89 FR 97710, each over a thousand pages. All public domain.