On 14 September 2026 we searched each of the three Sacramento directories for a prosthodontist and checked every name against the federal provider registry. The full scoreboard is on the Dental Awards page. In short: Health Net's directory does not offer prosthodontics as a specialty, and the nearest option returned ten endodontists, who do root canals. Liberty's search returned three names, each labeled a general dentist first. California Dental Network (DentaQuest) publishes its whole directory as a data file; the file has 2,556 Sacramento-area listings and not one prosthodontist, and all 71 of its prosthodontist rows in the entire state sit in Southern California ZIP codes. Zero verified specialists for 551,922 people. We do not use the phrase ghost network loosely. We use it for a directory that is full on paper and empty on the phone, and this is what we found.
The rules are not vague about this. State law says a directory “shall not list or include information on a provider that is not currently under contract with the plan,” and when someone reports an error the plan has 30 business days to verify or fix it. If a member relied on a directory that was “materially inaccurate, incomplete, or misleading,” the regulator “may require the health plan to provide coverage for all covered health care services provided to the enrollee” at in-network cost.
The contract with the State goes further. Members “must be offered appointments” with a specialist “within thirty (30) business days from authorized request for adult Members.” When the network cannot provide a service, the plan must cover it out of network at no greater cost to the member, a duty that sits in federal Medicaid rules too. And where the State has excused a plan from its distance standard for a specialty, the plan must “make its best effort to establish a Member-specific case agreement with an Out-Of-Network core Specialist at the Medi-Cal Fee-For-Service rate or a mutually agreed upon rate.” In other words: no prosthodontist in the network is not the end of the plan's duty. It is the start of a different one.
One gap is worth knowing. The Department of Managed Health Care's timely access rule gives medical plans 15 business days for a specialist appointment, but that paragraph does not apply to dental plans. For them the operative standard is the general one: “Nonurgent appointments shall be offered within 36 business days of the request for appointment.” So the State's contract clock, 30 business days, is the tighter of the two, and it starts only once the referral is authorized, which is a clock of its own.
How does a network with no verified prosthodontist pass the State's adequacy test? The State's certifications to the federal government say that “there are no established ratios for dental specialties delineated in either federal or state laws,” and the last published count of Sacramento specialists, by plan, is from 2021. The record is on the awards page.
The State noticed too
On 9 September 2026 the Department of Health Care Services, which holds the Medi-Cal contract and pays the plans, sent warning letters to Health Net and to California Dental Network (DentaQuest), the two plans DentaQuest runs. Same problem, almost the same words. Since the new contract began in July 2025, both plans have filed the one report that tells the State whether members get specialist appointments on time, and they have filed it late, wrong, or both.
Health Net's letter is the fuller of the two. The plan filed its report for the third quarter of 2025 on 28 January 2026, and “DHCS immediately identified numerous deficiencies, including incorrect calculations and missing data fields.” Then: “Between February 3 and August 7, 2026, DHCS issued multiple requests for corrections, but HN's resubmissions continued to contain errors and/or were submitted late.” The State held three help calls with the plan. In the end, “DHCS has determined that HN has not met their reporting contractual requirements.” DentaQuest's own plan was told that its resubmissions “continued to contain inaccurate data” and that “As of the date of this letter, CDN has not submitted a sufficient submission.”
The second report in the letters is the one meant to show each plan checking its own dentists' work. For the second quarter of 2026 Health Net “self-reported that there was ‘No data available.’” DentaQuest's plan told the State that “a chart audit will be initiated once sufficient activity is available to support a comprehensive review.” A year into the contract, the State had a sufficient version of that report from neither plan.
Read that beside the section above. The report the State uses to check the specialist clock is the report the State says it cannot rely on; the letters cite the rule that requires it “to demonstrate their compliance with the updated requirements for network adequacy.” Each plan now owes a corrective action plan within 30 days. If the problem is not fixed within six months, the State says it “will exercise its right to retain withheld funds, pursue Liquidated Damages and/or Sanctions.”
This is the second round. In December 2025 the same office sent both plans a notice of deficiency about their directories. Whenever a dentist left the wheelchair access question blank, the plans' systems filled in No. Health Net “identified 165 occurrences.” DentaQuest's plan reported that “their current records show 213 GMC offices and 306 PHP offices were marked as ‘No’ for handicap access.” Both plans sent the State the same written answers, word for word; we checked by machine. DentaQuest's plan closed its case effective 17 March 2026. Health Net's last public reply from the State, on 3 March 2026, says “All CAP findings remain Open.”
One more thing the letters do not say. The State may fine a dental plan “up to $25,000 per violation for the first violation” and “up to $50,000 for the second violation, and up to $100,000 for each subsequent violation.” We looked for a fine the Department of Health Care Services has actually posted against a dental plan and found none. Every letter ends with a threat. The fines that exist come from the other regulator, the Department of Managed Health Care, and they sit in the library: $293,000 across 24 years for the two dental-only plans. The money that has moved against Health Net's parent company, including a $40 million settlement over its medical directories, is on the same shelf.