The Colorado Department of Regulatory Agencies (DORA) recently sent an email to all licensees about “Important New Laws Affect Your Profession” that has caused substantial confusion, worry and questions from dentists. The CDA would like to provide clarification 
on two noted bills and corresponding changes to Colorado law.
SB26-138: Reducing Administrative Burdens on Health Care
What you need to know:
- Top Line: There is no new requirement right now for continuing education on prescribing drugs and treatment from this bill.
(Please note: current Colorado Dental Board rulemaking unrelated to this bill is in response to the 2025 Dental Practice Act Sunset Bill. The CDA is providing detailed summaries of that rulemaking process separately.) - Existing Dental Rules and SB26-138 Impacts:
- For several years, Colorado law has mandated that the Colorado Dental Board require up to 4 hours of CE on opioid prescribing and best practices as a condition of licensure renewal/reinstatement.
- The Colorado Dental Board has a longstanding current rule in place that requires 1 hour of opioid prescribing and related CE for renewal/reinstatement of licensure for dental prescribers.
- SB26-138 removes the mandate that the Colorado Dental Board require opioid prescribing and related CE,
- Going forward, the Colorado Dental Board could respond to SB26-138 in one of the following ways:
- Maintain the current requirement of 1 hour of opioid prescribing and related CE for renewal/reinstatement of licensure. This is the current requirement.
- Require additional hours (up to 4 hours) of CE opioid prescribing and related CE as a condition of licensure renewal. This is not a new power or discretion of the Colorado Dental Board; it has had the ability to require up to 4 hours of opioid-related CE, but has only required 1 hour of CE for this topic.
- Remove the requirement for 1 hour of opioid prescribing and related CE as a condition of licensure renewal. This would be a new change from what has been the status quo. If the Colorado Dental Board decides to remove the requirement for opioid-related CE, up to 4 hours of optionally pursued opioid-related CE can count toward a licensee’s total CE requirement for licensure renewal.
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HB26-1431: Competency for Occupational Licensure Portability
What you need to know:
- Top Line:
- All requirements for licensure as a dentist or dental hygienist in Colorado, as laid out in the Colorado Dental Practice Act (the state laws governing dentistry), must be met for anyone being licensed in Colorado.
- CODA-accredited education will still be required of anyone applying for licensure as a dentist or dental hygienist in Colorado, no matter where they are from and no matter if they are applying through the standard licensure route or through the Occupational Credential Portability Program (OCPP).
- Existing Law and HB26-1431 Impacts:
- The Colorado Dental Practice Act requires that anyone applying for licensure as a dentist or dental hygienist in Colorado must have CODA-accredited dental education, among other licensure requirements.
- If someone is applying for licensure through the Occupational Credential Portability Program (OCPP), they still must meet all licensure requirements as set forth in the Dental Practice Act.
- The OCPP is a program that applies to most professions regulated in Colorado. It is intended to provide a streamlined licensure process for professionals who are licensed elsewhere, are moving to Colorado, and already meet all of the Colorado licensure requirements for their profession. Previously, OCPP law only allowed individuals from other U.S. states to apply for licensure.
- Due to lobbying efforts by the CDA, HB26-1431 makes only a minor change to licensure portability law (as opposed to the initial introduced bill, which sought to loosen licensure requirements for international applicants). HB26-1431 changed the OCPP laws to allow someone from another country to apply for streamlined licensure through the OCPP program only if they meet all licensure requirements for the profession.
- The CDA solidly stood its ground that any dentist practicing in Colorado is educated with the same safety standards and clinical competencies. All licensed dental professionals in Colorado should be held to uniform educational standards.
- Practical Impact to Dentistry:
- The impact to dentistry in Colorado will be fairly narrow. This change will only allow individuals from countries with CODA-accredited dental education to apply for dental licensure via the OCPP pathway (assuming they also meet all other licensure requirements).
- At this time, international dental education programs that are CODA-accredited are those in Canada (accredited by the Commission on Dental Accreditation of Canada), as well as one dental school in Turkey and one dental school in Saudi Arabia.
- More information about CODA-accredited dental schools, both national and international, can be found on
