Virginia Enacts DDH Compact

As of March 8, 2024, five states have enacted the Dentist and Dental Hygienist Compact into law. Virginia Governor Glenn Youngkin signed SB 22, the Dentist and Dental Hygienist Compact, into law making Virginia the fifth state to enact the compact joining Iowa, Washington, Tennessee and Wisconsin.

Twelve additional states have introduced the compact as of March 2024 including:

  • Alabama
  • Colorado
  • Illinois
  • Indiana
  • Kansas
  • Maine
  • Minnesota
  • Missouri
  • Nebraska
  • New Jersey
  • Ohio
  • Pennsylvania

Stay up to date on legislative activity by accessing the compact map.

The compact will be operationalized following the enactment by seven states. Once seven states join, a commission consisting of one representative from each state will be formed and will create the rules and application process. Any state that joins after the initial seven will also have representation on the commission. The representative will be a designee from each state’s licensing authority.

DDH Compact Legislative Update

On January 31, 2024, Wisconsin Governor Tony Evers signed The Dentist and Dental Hygienist Compact (SB 692), one of five bills signed in Wisconsin to improve access to dental healthcare. Wisconsin becomes the fourth state to enact the DDH Compact. Twelve additional states have introduced the compact during the 2024 legislative sessions.

“The health and well-being of our state and our economy depend on the health and well-being of our communities, including ensuring that all Wisconsinites have access to quality, affordable healthcare. I am proud to sign these five bipartisan bills that will move us forward in our work to address shortages and bolster our dental healthcare workforce while also closing gaps in access across the state,” Gov. Evers said in a statement.

States join the compact by passing it through their state legislature and signing it into law by the state governor. Iowa became the first state to sign the compact into law on April 27, 2023. Since then, three other states, Tennessee, Washington and Wisconsin, have enacted the compact. View all legislative activity by accessing the compact map.

The compact is operationalized following the enactment by seven states. At that point, a commission consisting of one representative from each state will be formed and will create the rules and the application process.


Response to “AADB Compact”

This memo was drafted to describe critical issues that have been identified in the AADB Dental and Dental Hygiene Compact as proposed by the American Association of Dental Boards (hereinafter, the “AADB Compact”). This Compact is styled as proposed legislation and was reviewed in light of the legal principles governing the creation and operation of interstate compacts and their commissions, and the standards historically applied during judicial review of interstate compact statutes.

This review revealed significant legal concerns, ranging from state constitutionality concerns to possible violations of federal antitrust laws. Moreover, the language, style, and overall drafting of the compact fails to enact many best practices in compact drafting that have been identified over the years, yielding a structure that will likely have significant administrative challenges even if adopted.

In short, this Compact, if enacted in its current state, would be materially insufficient to establish an effective interstate compact commission, and it would almost certainly give rise to potentially fatal legal challenges.

It is imperative to ensure that a compact is legally and mechanically sound before it is circulated to potential member states. The AADB Compact simply does not meet this standard.

Download the entire memo below.

DDH Compact: Section by Section Summary

Section 1: Title and Purpose

The purposes of this Compact are to facilitate the interstate practice of dentistry and dental hygiene and improve public access to dentistry and dental hygiene services by providing dentists and dental hygienists licensed in a participating state the ability to practice in participating states in which they are not licensed.

This Compact is designed to achieve the following objectives:

  • Enhance states’ abilities to protect the public’s health and safety
  • Facilitate the exchange of licensure, investigative and disciplinary information among member states
  • Requires practitioners to practice within the scope of practice authorized by the state in which they are practicing
  • Support active-duty military personnel and their spouses
  • Encourage the cooperation of member states in regulating multistate practice for licensed dentists and dental hygienists
  • Create a streamlined pathway for licensees to practice in participating states increasing the mobility of duly licensed dentists and dental hygienists
  • Increase public access to dentistry services

Section 2: Definitions

This section establishes the definitions of key terms and concepts as used throughout the compact. Defined terms are capitalized throughout the document. The Dentist and Dental Hygienist Compact uses the term “Compact Privilege” to describe a licensee’s permission to work in a remote state.

Section 3: State Participation in the Compact

This section establishes the requirements for states to be eligible to participate in the compact, and what is required of participating states to continue to maintain eligibility.

To be eligible to participate in the compact a participating state must:

  • Accept the National Board Examinations of the Joint Commission on National Dental Examinations
  • Accept for licensure that applicants for a dentist license graduate from a predoctoral dental education program accredited by the Commission on Dental Accreditation and that applicants for a dental hygienist license graduate from a dental hygiene education program accredited by the Commission on Dental Accreditation
  • Require for licensure that applicants successfully complete a clinical assessment
  • Have continuing professional development requirements
  • Have a mechanism to receive and investigate complaints about Licensees practicing in that state
  • Enact a compact that is not materially different from the model compact
  • Participate fully in the compact data system
  • Notify the compact commission of any adverse action or the availability of significant investigative information regarding a licensee or applicant
  • Implement procedures for requiring the background check of applicants for a privilege to practice
  • Comply with the rules of the commission, the governing body of the compact
  • Accept licensees from other participating states as established by the compact

Section 4: Compact Privilege

This section describes the requirements for a dentist or dental hygienist to obtain a compact privilege to practice in remote states.

To obtain and exercise a compact privilege under the compact a licensed dentist or dental hygienist must:

  • Hold a qualifying license1 in a participating state
  • Have passed a National Board Examination of the Joint Commission on National Dental Examinations
  • Have graduated from a predoctoral dental education program accredited by CODA, leading to a D.D.S. or D.M.D. degree (for dentists)
  • Have graduated from a dental hygiene education program accredited by CODA (for dental hygienists)
  • Have successfully completed a clinical assessment
  • Have not been convicted or found guilty, or have entered into an agreed disposition, of a felony offense under applicable state or federal criminal law, within five (5) years prior to the date of their application;
  • Apply to the commission through the participating state where the licensee holds a qualifying license
  • Pay any applicable fees
  • Meet any jurisprudence requirements established by the remote state in which the licensee is seeking a compact privilege
  • Report to the commission any adverse action taken by any non-participating state
  • Report to the commission the licensee’s primary address and any change in address
CODA and Clinical Assessment additional information.

The compact states that a dentist or dental hygienist must graduate from a CODA accredited program or “another accrediting agency recognized by the United States Department of Education for the accreditation of dentistry and dental hygiene education programs.” This is intentional. If, in the future, the U.S. Department of Education approves another accrediting agency, the compact will not be obsolete. It can continue to exist long into the future without states having to go back and amend the compact through their legislative process in every state. CODA accredited programs are the only programs that qualify under this definition.

The compact states that a dentist or dental hygienist must take a clinical assessment. This is defined as an “examination or process, required for licensure as a Dentist or Dental Hygienist as applicable, that provides evidence of clinical competence in dentistry or dental hygiene.” States retain the power to choose which clinical assessment they use for licensure.

Section 5: Active Military Member or their Spouse

This section specifies that active-duty military members and their spouse shall not be required to pay the commission fee for a compact privilege. If a remote state chooses to charge a fee for a compact privilege, it may choose to charge a reduced fee or no fee to active-duty military and their spouses.

Section 6: Adverse Actions

This section establishes a disciplinary framework between the compact participating states. Remote states may take adverse action against a licensee’s compact privilege in that state and may issue enforceable subpoenas for witnesses and evidence from other participating states.


Participating states must report any adverse action and the existence of significant investigative information to the compact data system, which then promptly alerts the other participating states of this information. Any participating state may take adverse action based on the factual findings of a remote state. This section also directs the compact participating states to work together on joint investigative activities related to licensees using the compact.

Section 7: Establishment and Operation of the Commission

This section outlines the composition and powers of the compact commission.

  • Each participating state is entitled to one delegate
  • The Commissioner will be a member or designee of the State Licensing Authority
  • Each delegate has one vote on commission rules and bylaws
  • The commission may establish a term of office, code of ethics, bylaws, rules, a budget and financial records in order to carry out the compact
  • The commission cannot take action against a practitioner. It can not dictate policy to the member states. States retain control of the scope of practice and their licensure process.

Section 8: Data System

This section establishes the commission’s shared information system. Participating states are required to share licensing information on practitioners with compact privileges. Participating states will submit a uniform dataset to the data system on all practitioners to whom this compact is applicable as required by the rules of the commission. This database will allow for the expedited sharing of disciplinary and investigative information.
Adverse action information pertaining to a licensee in any participating state will only be available to other participating states. A participating state may designate information submitted to the data system that may not be shared with the public without the express permission of that participating state.

Section 9: Rulemaking

This section establishes the rulemaking authority of the commission to carry out the provisions of the compact.

  • Rules carry the force of law in all participating states.
  • A simple majority of participating state legislatures may veto a rule of the commission.
  • Changes to rules require a 30-day notice of proposed rulemaking, with an opportunity for a public hearing.
  • If the commission takes an action that is beyond the scope of the compact, the action is invalid and has no force and effect.

Section 10: Oversight, Dispute Resolution and Enforcement

This section ensures compliance with the compact by member states and details the procedures to be followed in the event a participating state fails to comply with the compact.

  • A period of technical assistance in remedying the situation.
  • Dispute resolution, including mediation and binding processes.
  • Termination from the compact if no other means of compliance is successful.
  • The commission shall attempt to resolve any compact-related disputes that may arise between states.

Section 11: Effective Date, Withdrawal and Amendment

This section establishes the effective date of the compact and includes provisions for states withdrawing from the compact and the member states collectively amending the compact.

  • The compact takes effect on the date of enactment by the seventh state.
  • States that join after this date are subject to the rules of the commission as they exist on the date when the compact becomes law in that state.
  • Participating states may enact a law to repeal their membership in the compact. A state’s withdrawal takes effect 180 days after enactment of such law.

Section 12: Construction and Severability

The compact is to be liberally construed to effectuate its purposes.
The compact’s provisions are severable, meaning that:

  • If a provision is declared to conflict with the United States Constitution, all other provisions remain valid for all participating states.
  • If a provision is held contrary to a participating state’s constitution, the compact retains its full force in all other states, and all other provisions remain valid in the affected state.

Section 13: Consistent Effect and Conflict with Other State Laws

Participating states retain sovereignty over all laws, and nothing shall inhibit or prohibit enforcement of laws that are not in conflict with the compact. Any laws, statutes, regulations or other legal requirements in a member state that conflict with the compact are superseded to the extent of the conflict.

Download the Section by Section PDF below.

DDH Compact Basics

What is the DDH Compact?

The Dentist and Dental Hygienist Compact is an interstate occupational licensure compact. Interstate compacts are constitutionally authorized, legally binding, legislatively enacted contracts among states. This compact enables licensed dentists and dental hygienists to practice in all states participating in the compact, as opposed to them obtaining an individual license in every state they want to practice.

Who can use the DDH Compact?

A dentist or dental hygienist is eligible to participate in the compact if they have:

  • An active, unencumbered license in any state participating in the compact.
  • Passed the National Board Examination or other exam accepted by the compact commission.
  • Completed a clinical assessment.
  • Graduated from an education program accredited by the Commission on Dental Accreditation.
  • No disqualifying criminal history.

What’s next?

The Council of State Governments (CSG) has facilitated the development of the Dentist and Dental Hygienist Compact model legislation. This legislation has been finalized for introduction during 2023 legislative sessions. Each state must enact the model legislation to join the compact. Supporters of the compact can contact the state chapter or national office of their professional membership association and state legislature to advocate for the interstate compact.

Download this information as a PDF below.


Dentist and Dental Hygienist Compact Model Legislation

CSG and a diverse group of stakeholders including ADA, ADHA, state regulators, and others wrote the Dentist and Dental Hygienist Compact model legislation over the course of two years. After an extensive public review process it was finalized in January 2023.

To introduce the legislation in your state, please use the model legislation linked below.

This project is funded by the Department of Defense.
The following language must be enacted into law by a state to officially join the Dentist and Dental Hygienist Compact.
No substantive changes should be made to the model language. Any substantive changes may jeopardize the enacting state’s participation in the Compact.


The Council of State Governments National Center for Interstate Compacts reviews state compact legislation to ensure consistency with the model language. Please direct inquiries to Jessica Thomas at JThomas@csg.org.

CSG Hosts Compact Overview Webinar – Copy

On October 18, CSG hosted a webinar on the Dentist and Dental Hygienist Compact. The webinar showcased the compact and its value for dentists, dental hygienists and states. Attendees learned about the benefits of interstate compacts, the features of the Dentist and Dental Hygienist Compact, answers to FAQs, and current status of compact legislation in states.

Access the recording here: https://www.youtube.com/watch?v=6uu0XVwe8G

CSG Hosts Compact Overview Webinar

On October 18, CSG hosted a webinar on the Dentist and Dental Hygienist Compact. The webinar showcased the compact and its value for dentists, dental hygienists and states. Attendees learned about the benefits of interstate compacts, the features of the Dentist and Dental Hygienist Compact, answers to FAQs, and current status of compact legislation in states.

Access the recording here: https://www.youtube.com/watch?v=6uu0XVwe8G

Washington Enacts the Dentist and Dental Hygienist Compact

On May 4, 2023, Governor Jay Inslee signed House Bill 1576 making Washington the second state to enact the Dentist and Dental Hygienist Compact.

HB 1576 was sponsored by Rep. Michelle Caldier who is a licensed Dentist.

During the signing ceremony, Governor Inslee describes the bill as beneficial “for those relocating to Washington such as military or other migratory families. Participating in the compact will reduce barriers to joining the workforce.”

Governor Inslee highlights this benefit by saying, “I’m hopeful this is going to help these military families particularly.”

The compact will become active once enacted by seven states.

Iowa Becomes First State to Enact Dentist and Dental Hygienist Compact

On April 27, 2023, Iowa Governor Kim Reynolds signed into law HF 656, making Iowa the first state to enact the Dentist and Dental Hygienist Compact. HF 656 was sponsored by Representative Taylor Collins.

The Dentist and Dental Hygienist Compact will allow licensed dentists and dental hygienists to practice in any other member state by via a ‘compact privilege’. The compact reduces barriers to multistate practice and license portability.

Jill Stuecker, Division Director of Division of Professional Licensing and Regulation for Iowa Department of Health and Human Services, who was on the project team that developed the compact in Iowa, says:

“Iowa is proud to be the first in the nation to enact the Dentist and Dental Hygienist Licensure Compact.

By creating shared licensing standards that uphold public protection, licensure compacts strengthen our workforce.  This is especially important in professions like dentistry, where workforce shortages exist.  Compacts reduce barriers that licensed professionals face when trying to become licensed in multiple states, and create a streamlined process for sharing needed skills and expertise across state lines.  We are excited to be a part of this important work.”

The compact will become active once enacted by seven states. For more information please contact dentalcompact@csg.org