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Written by Shelley DeGroff, Founder & CEO of PPO Advisors

Last Updated: April 9, 2026

Billing during practice transition under a seller’s TIN, NPI, or contracted status is insurance fraud — there is no grace period and no exception. Not for six months. Not for six weeks. Not for six days. If a broker, attorney, or purchase agreement tells you otherwise, they are wrong.

This myth circulates constantly in dental practice sales, and PPO Advisors has seen it firsthand across 2,870+ dental practices and 12,000+ credentialing applications. Brokers write it into purchase agreements. Attorneys sign off on it. And office managers are left holding the bag when it blows up.

Here’s what the rules are for billing during practice transition, what the real consequences look like, and exactly what you should do instead.

 

 

Why Does the Grace Period Myth Keep Circulating?

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It was a Friday afternoon. A dental practice quietly changed hands. By Monday morning, the staff showed up and were told — for the first time — that they now worked for a new owner. New name, new dentist, new everything.

The office manager was then told by the buying provider that the purchase agreement, drafted by the buyer’s broker and the buyer’s attorney, included a clause stating the new owner could use the seller’s Tax Identification Number (TIN) and NPI numbers to submit insurance claims for up to six months.

A broker. An attorney. A written agreement. All pointing this office manager — and this new provider — toward committing insurance fraud during the billing during practice transition period.

Thankfully, this office manager knew better. She refused to participate. She told the buying provider clearly and directly: she would not falsely represent the treating provider on a claim form. She found resources to back her up and kept the practice from walking into a serious legal trap.

But here’s what should concern every practice owner: she was put in that position in the first place. And she won’t be the last one.

 

Is There a Grace Period for Billing During Practice Transition?

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Whether it comes from a broker trying to smooth over a deal, an attorney who doesn’t specialize in dental insurance law, or just a well-circulated rumor among dentists — the myth about billing during practice transition is the same:

The fact is well established across the dental insurance industry: once a practice changes title, a new owner cannot submit claims under the prior owner’s name, TIN, NPI number, or contracted status.

Not for six months. Not for six weeks. Not for six days.

In PPO Advisors’ experience managing 12,000+ credentialing applications, incorrect billing during practice transition is one of the most common compliance failures we encounter — and one of the most preventable.

 

Why Is Billing During Practice Transition Under a Seller’s NPI Insurance Fraud?

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This isn’t a gray area. Here’s exactly what happens when a new owner submits claims under a seller’s TIN or NPI after the sale:

• The claim falsely represents who rendered the care. The treating provider is the new owner, but the claim says otherwise.
• The claim misrepresents the contracted provider. The insurance company believes it’s paying someone who has an active contract. That person no longer owns the practice.
• The buyer collects reimbursement they’re not entitled to. If the seller had a better fee schedule or contract tier, the buyer is collecting higher payments under someone else’s negotiated rates.
• The insurance company is paying the wrong entity. They’re reimbursing someone who did not treat the patient, under a contract that no longer applies.

Billing under another provider’s NPI is a false claim. It violates the Federal False Claims Act. It violates your provider agreement with every insurance plan. And it exposes multiple people to serious consequences:

• The buying provider: audits, fines, loss of contracts, loss of licensure, and in serious cases, criminal prosecution.
• The office manager or biller who submits the claims: personal liability. You can be held individually responsible.
• The selling provider: their identity and credentials are being used without authorization, which constitutes identity fraud.
• The practice itself: repayment demands, investigations, and reputational damage that can follow you for years.

 

Real-World Penalties for Dental Billing Fraud During Practice Transitions

These aren’t hypothetical consequences. They’ve already happened:

The scale of the practice does not matter. Solo practice, group practice, DSO — the outcome is the same.

 

Does This Apply When Hiring a New Associate Dentist?

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Yes. The same billing during practice transition rules apply when adding an associate, and this scenario is just as common.

When a practice brings on a new associate, that associate must be credentialed before their claims can be submitted under the practice’s in-network status. That process typically takes four to six months. During that time, many practices are tempted — or outright advised — to submit the associate’s claims under the supervising dentist’s NPI.

That is NPI fraud. Full stop.

What you can do during this period: the associate can see patients, but their claims must be submitted out-of-network. Patients need to be informed. There may be higher copays. It’s inconvenient. But it’s legal. The alternative is not.

PPO Advisors has managed credentialing for thousands of associate hires through our Credentialing Access Point (CAP) system. Starting the process early is the single most important thing you can do to minimize the gap.

 

5 Rules for Billing During Practice Transition the Right Way

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If you’re buying a practice — or if you’re a broker or attorney advising on a transaction — here’s how billing during practice transition should actually work:

• Rule 1: Start credentialing long before the sale closes. Contact the insurance plans you intend to participate with months before the title transfers — typically two to three months in advance. Learn each plan’s credentialing timeline. Some take two weeks. Others take three months or more. Work backward from those timelines to set your closing date. Based on PPO Advisors’ experience with 12,000+ credentialing applications, starting early is the single biggest factor in avoiding a compliance gap.
• Rule 2: Defer the title transfer if necessary. The seller and buyer can agree to delay the transfer of title until credentialing is closer to complete. This is a legitimate and smart strategy. It protects the buyer from being in limbo, and it protects everyone from the compliance risks of the alternative.
• Rule 3: Communicate transparently with patients. If there’s a gap between when the title transfers and when credentialing is complete, patients deserve to know. They may have a period of out-of-network treatment with the new provider. Let them know what that means for their copays and benefits. Full disclosure is always the right move.
• Rule 4: Bill out-of-network during the gap. If credentialing isn’t yet complete when the sale closes, the new owner’s claims must be submitted out-of-network. Some buyers choose to honor in-network rates out of pocket during this transition period to limit patient impact. That’s a business decision — and a generous one — but the claims must still be submitted correctly.
• Rule 5: Never submit under the seller’s credentials. There is no version of this that is acceptable. It doesn’t matter what a purchase agreement says. It doesn’t matter what a broker told you. A contract between two private parties cannot override federal law or your provider agreement with an insurance plan.

 

What Should Office Managers Do If Asked to Bill Incorrectly?

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This isn’t just about protecting the practice. Office managers and billers who submit fraudulent claims during a practice transition carry personal liability. “I was told to do it” is not a legal defense. If a claim falsely represents who provided the care, the person who submitted it can be held responsible.

If you’re in this situation and aren’t sure what to do, contact PPO Advisors. We’ve helped hundreds of practices work through exactly this kind of compliance gap.

 

The Bottom Line on Billing During Practice Transition

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Practice transitions are complicated. Credentialing timelines are frustrating. The temptation to find a shortcut is real — especially when brokers or attorneys seem to offer one in writing.

But there is no shortcut for billing during practice transition. There is no grace period. There is no exception carved out for practice sales, associate hires, or any other transition scenario.

Plans pay based on who rendered care and who is contracted — not who used to own the practice. And they enforce that rule.

At PPO Advisors, we’ve helped hundreds of dentists handle credentialing the right way — through startups, acquisitions, and associate hires. We know the timelines, we know the plans, and we know how to keep your practice compliant while protecting your revenue.

If you’re preparing for a practice transition — or if you’ve already closed and are now realizing you may be in a compliance gap — don’t wait. The sooner you start credentialing correctly, the smaller the revenue gap.

 

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Frequently Asked Questions About Billing During Practice Transition

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Can a purchase agreement override insurance credentialing rules during a practice transition?

No. A purchase agreement is a contract between two private parties. It cannot override federal law, the False Claims Act, or your provider agreements with insurance plans. If a purchase agreement includes a clause allowing the buyer to bill under the seller’s NPI or TIN, that clause is directing you to commit fraud — regardless of who drafted it.

 

How long does credentialing take when buying a dental practice?

It depends on the plan. Some carriers complete credentialing in two to three weeks. Others take three months or more. Based on PPO Advisors’ experience with 12,000+ credentialing applications, starting the process two to three months before the closing date is the safest approach. The earlier you start, the shorter the out-of-network gap after the sale closes.

 

What happens if I’ve already been billing under the seller’s NPI after a practice transition?

Stop immediately and contact a compliance advisor. The longer incorrect billing during practice transition continues, the greater the exposure — for the buyer, the seller, and the team members submitting claims. In some cases, voluntary disclosure and corrective action can reduce penalties. But the first step is stopping now. PPO Advisors can help you assess the situation and build a compliant path forward.

 

Can I bill out-of-network during the credentialing gap after buying a practice?

Yes — and you should. When credentialing isn’t complete at the time of the sale, the new owner’s claims must be submitted out-of-network. Some buyers choose to honor in-network rates out of pocket during this period to retain patients. That’s a legitimate business decision. But the claims themselves must accurately reflect the treating provider and their current credentialing status.

 

Can PPO Advisors handle credentialing before my practice acquisition closes?

Yes. This is one of the most common scenarios we manage. PPO Advisors’ Complete Acquisition Program starts credentialing as soon as you’ve signed a letter of intent — months before the sale closes. We handle every carrier, every application, and every timeline so you’re in-network as quickly as possible. On average, dentists who work with PPO Advisors during acquisitions see a 20-30% increase in contracted fees compared to the seller’s original agreements.

 

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✍️ Shelley DeGroff
Founder, PPO Advisors