Dentist and Dental Hygienist Compact

The Dentist and Dental Hygienist Compact is a legally binding agreement among states that provides a pathway through which dentists and dental hygienists can obtain compact privileges which authorize practice in states where they are not licensed. A state must enact the compact model legislation via a state’s legislative process to join.

The compact:

• Facilitates multistate practice.
• Enhances license portability when changing state of residence.
• Expands employment opportunities into new markets.
• Improves continuity of care when patients or providers relocate.
• Expands consumer access to highly qualified practitioners.
• Supports relocating military spouses.
• Reduces burden of maintaining multiple licenses.

States can participate in the compact by passing the compact model legislation through the state’s legislature and becoming state law through the governor’s signing. 

The Dentist and Dental Hygienist Compact is a mutual recognition model compact similar in form and function to professional licensure compacts for nurses, physical therapists and psychologists. Dentists and dental hygienists who are licensed in one compact member state can practice in another participating state by obtaining a compact privilege.

A compact privilege is the legal authorization for a dentist or dental hygienist to practice in a remote state where they are not licensed. A dentist or dental hygienist must hold an active and unencumbered license in a compact participating state and meet additional eligibility criteria to be eligible for a compact privilege. A dentist or dental hygienist applies for a compact privilege and may begin legally working in the new state when eligibility is verified, jurisprudence requirements are met and all fees are paid.

A qualifying license is an unrestricted license to practice dentistry or dental hygiene that has been issued by a state participating in the compact. The license must be currently active and unencumbered. 

To be eligible to obtain a compact privilege in a remote state, a dentist or dental hygienist must have:

• An unencumbered license in a state that has joined the compact.
• Graduated from a predoctoral dental education program accredited by the Commission on Dental Accreditation; or a dental hygiene education program accredited by the Commission on Dental Accreditation.
• Passed the National Board Examination.
• Completed a clinical assessment for licensure.
• No disqualifying criminal history.
• Passed any jurisprudence requirements established by the remote state.
• Pay all required fees.

The compact specifies that dentists who use the compact must have completed a CODA accredited predoctoral program leading to a Doctor of Dental Surgery or Doctor of Dental Medicine degree. Dentists who are not able to satisfy this requirement, such as foreign trained dentists, are not eligible to apply for compact privileges.

A licensee providing dentistry or dental hygiene services in a remote state under a compact privilege will function within the scope of practice as individuals who are licensed in that state. If a remote state requires a specialty license in order to limit practice to that specialty, the practitioner would also be required to obtain that specialty license in order to limit practice to the specialty in that remote state.

The compact intends to include the general dentistry and dental hygiene licenses. Anyone who holds a general dentistry or dental hygiene license is eligible to use the compact if the other criteria outlined in the compact are met. The compact would authorize a practitioner to perform the functions outlined in the state’s practice act as a general dentist or dental hygienist.

If a state requires additional testing, training, or permits/certifications to perform certain procedures (e.g., sedation/anesthesia permits for dentists, or administration of local anesthesia for dental hygienists), practitioners would be required to complete those requirements.

Section 4 of the compact requires that practitioners successfully complete a clinical assessment for licensure in order to obtain a compact privilege. As defined in the compact, the clinical assessment can be an examination or process that provides evidence of clinical competence in dentistry or dental hygiene. This includes all pathways accepted by a participating state such hands-based skills assessments, the DLOSCE, and dental residency programs.  

Yes. States can join the compact regardless of what clinical assessment their statute requires. This allows states to retain their sovereignty over licensure requirements. The compact defines clinical assessment broadly to encompass all valid measures of clinical competence allowed by states for licensure. In joining the compact, participating states are agreeing to accept practitioners from other states who may not have the identical clinical assessment requirements.

The commission is a government agency established by the compact. The commission will be comprised of one delegate from each participating state. The commission writes rules and bylaws to administer and implement the compact. As stated in section 7 of the compact, commissioners will be a designee from each participating state’s licensing authority. The commission is not a dental board. It cannot affect state licensing requirements or take action against a licensee.

Practitioners must complete the continuing education requirements in the state where they hold a qualifying license in order to maintain their qualifying license. They do not complete continuing education in remote states where they hold compact privileges.

Practitioners will need to complete a jurisprudence assessment if it’s required by the remote state where they are seeking a compact privilege.

Because dentists and dental hygienists need to obtain individual compact privileges in each state where they want to practice, regulators will know who has compact privileges in their state. They will see this information via the commission’s data system that the participating states have access to. Just as a regulator can currently see who has a license in their state, regulators will be able to know who has compact privileges to practice in their state.

The compact does not require licensees to be licensed in their state of residence.  Although there is some concern that new license seekers will apply for a license in the state with the “least rigorous” requirements, there is significant uniformity among the states in regard to licensing requirements. All states have a pathway to licensure which requires CODA accredited education. All states require the National Dental Board Examination. All states require a clinical assessment for licensure. Because there is no variation in the states around these standard requirements, it is unlikely that license seekers will be incentivized to “shop” for which state to obtain their license.

As specified in sections 3 and 4 of the compact, all practitioners must meet these standard requirements to use the compact.

The Dentist and Dental Hygienist Compact is the result of a partnership between The Council of State Governments, the American Dental Association and American Dental Hygienist Association, and Department of Defense.

Reach out directly to CSG email: dentalcompact@csg.org

Reach out directly to ADA email:  CDEL@ada.org

Reach out directly to ADHA email: Gov-affairs@adha.net