Rulemaking Underway for the Dental Practice Act: Some Rules Effective June 30

In 2025, the CDA successfully passed the Dental Practice Act Sunset bill (SB25-194) reflecting priorities and policies that support our member dentists. While a huge victory, that was only half of the process — now the Colorado Dental Board is required to adopt rules to implement the bill.

Over the last year, the Colorado Dental Board has held stakeholder meetings to identify what specific rules to adopt in regulation.  

The CDA has been actively involved in the process to advocate and fight for regulations that reflect the actual practice of dentists and to minimize unnecessary burdens to dentists.

The Colorado Dental Board split their rulemaking adoption into two separate meetings, one of which occurred on April 30. The second will occur on July 8.

Below is a synopsis of the rules adopted at the April 30 rulemaking meeting of the Colorado Dental Board. After the July 8 rulemaking hearing, we will provide a comprehensive synopsis of all the rule changes in our Fall Journal.

April 30 Adopted Rules – Effective June 30, 2026

• Definitions (1.4)
  • Added definitions of a license “In good standing” and “Patient representative”
• Licensure requirements (1.6)
  • Preserved the requirement of a CODA-accredited advance standing program or clinical residency for internationally trained dentist licensure
  • Continuing Education:
    • Added an initial licensure requirement of jurisprudence education (1 hour)
    • Expanded the list of CE approved organizations
    • Require CE hours on OSHA bloodborne pathogen training
  • Temporary Licensure during disaster:
    • Mirrored statute requirements for licensure during emergency declaration
  • Permissible Ownership Practices (1.7)
    • Reenforced that a Practice Ownership Form (as provided by the Board) shall be available if requested at a dental practice, during business hours, and the dental professional’s license must be available upon request
    • Reenforced that only a Colorado-licensed dentist may own a dental practice (pursuant to existing statute) and only a Colorado-licensed dentist or dental hygienist may own a dental hygiene practice
      • A Dental Service Organization (DSO) may not serve as a proprietor of a dental practice
      • A dentist who works at a DSO that is a proprietor of a dental practice may be subject to disciplinary action
    • An entity that owns the physical space where a dental office is located and leases the space to the office is not considered a proprietor of the dental practice
  • Record Keeping Requirements (1.9)
    • Reenforced that patient records cannot be abandoned; a licensee must develop an agreement to transfer patient records to another licensed professional in the event of a cessation of practice
  • Dental Prosthesis Construction (1.12)
    • Requires lab techs to maintain copy of dental lab work orders for at least 2 years
    • Allows for multiple dental prostheses to be incorporated into one lab work order for a patient
  • Anesthesia (1.14)
    • Changed the supervision level for local anesthesia administered by dental hygienists to unsupervised
    • Changed the supervision level for administration of nitrous oxide by dental hygienists to indirect supervision, and dental assistants to supervision
    • Required anesthesia inspectors to complete an anesthesia inspector calibration program every five years
    • Expedited the Anesthesia Permit process – applicants who are within six months of completing accredited residency in general anesthesia or post-doctoral training may be granted a full anesthesia permit without first completing an inspection, with an inspection required to be completed within six months permit issuance
    • Removed the requirement that a dentist who uses contracted anesthesia providers have an office inspection. Instead, dentists utilizing contracted anesthesia providers are required to verify the credentials of the contracted provider to administer anesthesia and to create a written contract that sets expectations of the dentist and the contracted anesthesia provider regarding responsibilities and liabilities. This contract should be made available for inspection by the Board.
  • Confidential Agreements to Limit Practice for Physical Illness/Condition or Behavioral Health Disorder (1.27)
    • Clarified that self-referral to the Peer Health Assistance Program and voluntary submission to a mental or physical exam and completion of requirements given by the qualified professional designated by the Board for Peer Health Assistance satisfies requirements of notification to the Board
  • Administration of Immunizations (1.33) – NEW regulatory section
    • Established, in accordance with statute, that dental professionals are authorized to administer immunizations with the following parameters:
      • Administer only to individuals age 6 and older
      • Appropriate training required—at least 20 hours for dentists working in private practice, or four hours for dentists working in integrated public health settings
        • Two hours of CE required every two years
      • At least four hours of training for dental hygienists administering vaccines, which must be done under direct supervision of a dentist or delegation of another licensed healthcare professional who is authorized to administer vaccines
      • Only administer respiratory and oral health vaccines, including but not limited to flu, HPV and COVID vaccines
      • Enter all vaccine administration information into the Colorado Immunization Information System (CIIS)
      • Not provide any exemptions for required vaccines