Colorado’s Dental Practice Act Overhaul

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Categories: Practice Management, HR and Accounting;
Posted: July 10, 2026
By Howard Farran, DDS, MBA

Colorado’s Dental Practice Act Overhaul: What SB25-194 Really Changes for Practice Ownership, DSOs, and Clinical Control

Colorado did something very targeted, and important. It clarified who may own a dental practice, strengthened the line between business support and clinical control, and gave the Colorado Dental Board more authority to discipline dentists who allow that line to be crossed.

The changes come from Senate Bill 25-194, Colorado’s 2025 modernization of the Dental Practice Act. The first wave of implementing rules took effect June 30, 2026. Only a Colorado licensed dentist may own a dental practice. DSOs may still provide payroll, billing, marketing, human resources, purchasing, information technology, and office management. What they may not do is practice dentistry through a management contract.

That sounds simple until the paperwork meets the operatory.

Most sophisticated DSOs already use a familiar structure. A dentist owns the professional entity. A separate management company owns or controls the lease, equipment, brand, administrative staff, and support systems through a management services agreement. Similar arrangements operate in states such as California, New York, Massachusetts, and Alabama, where corporate practice restrictions have existed for years.

The real question is no longer whose name appears on the ownership form. It is who makes the decisions.

Who hires and fires dentists. Who sets production targets. Who controls fees and schedules. Who selects laboratories, implants, supplies, and treatment protocols. Who decides whether a patient receives a crown, an extraction, an implant, or a denture. Who can punish a clinician for refusing treatment that is profitable but not indicated.

Those are the questions Colorado appears ready to examine.

The new rules emphasize substance over form. A dentist who serves as a nominal owner while a management company exercises actual control may face discipline. The same risk may extend to dentists who work in an improperly owned or controlled practice. That places responsibility directly on the license holder, not only on the corporation or its attorneys.

For practicing dentists, the implication is immediate. A title such as owner dentist, clinical director, or partner does not protect anyone if the dentist lacks real authority. A monthly distribution check does not prove independence. Neither does a signed management agreement.

Dentists considering employment, partnership, or ownership inside a DSO should examine how the organization functions in real life. Contracts matter, but daily workflow matters more. Clinical autonomy should be visible in hiring, treatment planning, scheduling, materials, referrals, patient records, and disciplinary decisions. When business pressure reaches the operatory, the dentist’s license remains the most exposed asset in the room.

The strongest argument against overstating the Colorado rules is that large national DSOs have spent decades building compliant management structures. Many may continue operating with little disruption. Their legal teams already understand how to separate the clinical entity from the management company.

The strongest argument for taking the rules seriously is enforcement. Colorado has now placed clearer language and disciplinary consequences behind principles that were often vague or lightly tested. The practices most vulnerable may not be the largest organizations. They may be smaller regional groups, new private equity platforms, poorly drafted partnerships, and informal owner dentist arrangements that were never truly independent.

Other provisions of Senate Bill 25-194 also affect licensure, recordkeeping, anesthesia, advertising, laboratory work orders, immunizations, dental hygiene, dental therapy, teledentistry, interim therapeutic restorations, silver diamine fluoride, neuromodulators, fillers, and itinerant surgery. Some rules are already effective. Others remain in later phases of rulemaking. Dentists should not assume that a statutory change is operational until the corresponding Board rule has been adopted.

The headline is Colorado is testing whether dentist ownership means genuine professional control or merely a name on corporate paperwork.

When business pressure and clinical judgment conflict, who is really running the practice?

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Colorado’s Dental Practice Act Overhaul

Primary Sources

Colorado General Assembly

SB25-194, Sunset Dental Practice Act
https://www.leg.colorado.gov/bills/sb25-194

Colorado Department of Regulatory Agencies

Colorado Dental Sunset Information
https://dpo.colorado.gov/DentalSunset

Colorado Dental Association

Rulemaking Underway for the Dental Practice Act: Some Rules Effective June 30
https://cdaonline.org/news/latest-news/rulemaking-underway-for-the-dental-practice-act-some-rules-effective-june-30/

Legislative Update, April 1, 2026
https://cdaonline.org/dentalprof/featured-news/legislative-update-april-1-2026/

Legal Analysis

DDS Lawyers

As Corporate Practice of Dentistry Concerns Escalate, Colorado Enacts Stricter Regulations Over DSO Involvement in Dental Practices
https://www.ddslawyers.com/as-corporate-practice-of-dentistry-concerns-escalate-colorado-enacts-stricter-regulations-over-dso-involvement-in-dental-practices


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