Fact vs Fiction in Licensure Portability

Licensure compacts effectively address oral health workforce shortages by enhancing professional mobility. Currently, two competing licensure compacts are available for dentistry and dental hygiene: the Dentist and Dental Hygienist (DDH) Compact and the Interstate Dental and Dental Hygiene Licensure Compact (IDDLC).

Drafted by the Council of State Governments (CSG), the DDH Compact was created in partnership with the American Dental Association and American Dental Hygienists’ Association. The DDH Compact has been enacted in 10 states and currently has pending legislation in 16 states. It was developed collaboratively over the course of 2 years through a transparent, inclusive, deliberative process lead by CSG with funding support from the US Department of Defense.

Proponents of the IDDHLC, which is supported by the American Association of Dental Boards (AADB), have historically opposed any compact for dental professionals. The organization is now pressuring state officials to withdraw their support for the DDH Compact. The goals and function of the DDH Compact have frequently been mischaracterized. Following are common misconceptions regarding the DDH Compact, along with key facts for clarity.

1. The DDH Compact will allow dental hygienists licensed through alternative pathways to practice via the compact (such as preceptorship or internationally trained dentists).
FALSE: The DDH Compact affirms that member states may have alternative pathways to licensure, but those pathways do not qualify someone to be compact eligible. The DDH Compact does not affect alternative licensure pathways, but those licensees cannot use the compact. The DDH Compact does not allow internationally trained dentists to work as dental hygienists. The DDH Compact does not allow on-the-job trained dental hygienists to participate. Any licensee using the compact must graduate from a Commission on Dental Accreditation-accredited program, pass national board exams, and successfully undergo a clinical exam for licensure.

2. The DDH Compact will expand the scope of practice for dental assistants.
FALSE: Dental assistants are not included in the DDH Compact. The compact requires that licensees hold a “qualifying license,” which is limited to dentistry and dental hygiene. There is no loophole for dental assistants to use the compact.

3. The compact privilege granted under the DDH Compact is not equivalent to a license.
FALSE: The compact privilege model has been successfully used by a number of other healthcare professions including psychology and physical therapy. As stated in the DDH Compact, a privilege “means the authorization granted by a remote state to allow a licensee from a participating state to practice as a dentist or dental hygienist in a remote state.”A licensee practicing on a compact privilege can practice to the full extent of the scope allowed in that state. There are no restrictions on what a dental hygienist is allowed to do vs what a license would afford him or her the opportunity to do. Dental boards have jurisdiction over anyone practicing under a compact privilege. From a regulatory standpoint, there is no difference between privilege and license.

4. The DDH Compact eliminates the “hand skills” exam requirement.
FALSE: The DDH Compact defines clinical assessment broadly to encompass multiple pathways to licensure. Currently states accept hands-based clinical exams, dental residency programs, and a computer-based objective structured clinical examination. Twelve states accept pathways to dental licensure that do not involve a single-encounter, hand-skills assessment. The DDH Compact ensures that all recognized pathways are valid for use of the compact to ensure maximum portability.

Licensure upon graduation does not meet the compact’s definition of clinical assessment. Any California dental hygienist licensed by this pathway would not be eligible until he or she passes a clinical exam. The IDDLC requires the ADEX exam exclusively (licensees who passed another regional “psychomotor” exam prior to January 1, 2024 are grandfathered in). All new dentists and dental hygienists would be required to pass the ADEX exam. The IDDLC creates clear economic advantages for AADB, CDCA-WREB-CITA, and the ADEX exam by codifying their status in the compact.

Under the IDDLC, dentists and dental hygienists practicing fewer than 5 years who took an exam other than ADEX, or any dentist who took the DLOSCE or completed a PGY-1 would be forced to re-examine if they wanted to utilize the compact; this reduces mobility for these  clinicians.

5. The DDH Compact doesn’t address additional permitting for expanded scope functions.
FALSE: The DDH compact requires any dentist or dental hygienist practicing under a compact privilege to adhere to all of the laws and rules that govern the practice in that state. If a state has certain restrictions or extra requirements for expanded scope, the licensee needs to satisfy those prior to legally providing those services. The compact enables dental hygienists access to work in another compact state quickly, but what they are allowed to do is still governed by each state. The same principle applies for dental specialties. In short, licensees must abide by all of the laws and rules in whatever state they are practicing.

When Congress appropriated funding to the Department of Defense to work with CSG on compact development, it specified in the authorizing legislation that the compacts must be “mutual recognition compacts.” The IDDHLC expedited licensure model is not a mutual recognition compact because it requires standardized qualifications regardless of each state’s licensing requirements. Congress recognizes that mutual recognition compacts are the only true form of licensure reciprocity. For these reasons, the Department of Defense does not support the IDDHLC. In a 2018 white paper, the US Federal Trade Commission endorsed mutual recognition compacts as “the lowest barrier to cross state practice.”¹ With a broad base of support, the DDH Compact continues to be widely embraced as the best long-term solution for licensure portability for dentistry.

Reference

1. United States Federal Trade Commission. Policy Perspectives: Options to Enhance Occupational License Portability. Available at ftc.gov/​​system/​​files/​​documents/​​reports/​​options-enhance-occupational-license-portability/​​license_​​portability_​​policy_​​paper_​䁮.pdf. Accessed March 28, 2025.

From Dimensions of Dental Hygiene. May/June 2025; 23(3):14-15.