ADHA and Partner Organizations Submit Joint Letter Correcting Misrepresentations About DDH Compact
CHICAGO, February 24, 2025 – The American Dental Hygienists’ Association (ADHA®), along with the American Dental Association (ADA), the Coalition for Modernizing Dental Licensure, and The Council of State Governments, have submitted a joint letter to Dimensions of Dental Hygiene magazine to correct false information and misrepresentations published in the January 13 article titled “A Closer Look at Competing Compacts.” The letter provides accurate information about the Dentist and Dental Hygienist Compact (DDH Compact) and clarifies misconceptions regarding licensure portability requirements.
The text of the letter to Dimensions of Dental Hygiene is as follows:
________________________
February 24, 2025
RE: Response to Compact Article
Dear Dimensions of Dental Hygiene,
The purpose of this letter is to correct false information and misrepresentations included in the January 13 article in Dimensions of Dental Hygiene titled, “A Closer Look at Competing Compacts”.
1. Author Claims: “The compact agreement further asserts that “state participation in the compact includes providing alternative pathways for individuals to obtain an unrestricted license, which does not disqualify a state from participating in the compact.” Allowing multiple, nontraditional educational pathways can lead to a lack of uniformity in training and experience. Consider on-the-job trained preceptor dental hygienists and internationally trained dentists holding a “qualifying dental hygiene license;” they are not currently eligible to work in most states. However, the DDHC agreement can provide them with a pathway to employment in all compact-participating states.”
This is false. The language from the compact quoted above 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. In order for a licensee to participate they must meet the requirements listed in the compact including CODA education, successfully completing a clinical assessment and passing the National Board Exams.
2. Author Claims: “Furthermore, states have expanded the duties of dental assistants to include coronal scaling; polishing; placing dental sealants; and monitoring and administering nitrous oxide — tasks currently performed by licensed dental hygienists. In Maryland, state-approved training for expanded function dental assistants consists of nonaccredited Department of Education programs, including high school vocational programs, rather than accredited dental hygiene programs.”
Dental assistants are not included in the Dentist and Dental Hygienist Compact. The compact requires that licensee hold a “Qualifying license”. The definition of “qualifying license” is limited to dentistry and dental hygiene. There is no loophole for dental assistants to use the compact.
3. Author Claims: “In contrast, the DDHC model grants a privilege to work across state lines. Currently, most state laws prohibit the practice of on-the-job trained or preceptor dental hygienists as well as the inclusion of internationally trained dentists working as dental hygienists (rather than as dentists). However, the DDHC privilege model supports nontraditional education or experience. This compact undermines the profession by allowing dental hygiene practice under varied and less stringent regulations. Furthermore, it does not guarantee standardization of education and independent assessment of basic clinical skills for job entry readiness.”
This is false. As stated in the response to claim #1, any licensee using the compact must have 1) CODA accredited degree 2) pass national board exams 3) pass a clinical exam for licensure. The DDH Compact does not allow internationally trained dentists to work as dental hygienists. The DDH Compact does not allow on the job trained hygienists. In order for a licensee to participate they must meet the requirements listed in the compact.
Additional Points of Clarity
- Compact Privilege vs. License
The article draws a distinction between the IDDLC and the DDH Compact based on the credential issued which authorizes practice in other compact member states. 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 hygienist is allowed to do vs. what a license would afford them 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 vs. license.
The drafters of the DDH compact determined the compact privilege model is the best fit for dentistry and dental hygiene.
2. Clinical Exams
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 OSCE (objective structured clinical examination).
Rather than limit the compact to only one clinical exam, the DDH Compact defines clinical exam broadly to encompass these di erent types of tests of clinical competency.
There are multiple valid and reliable pathways to licensure that are accepted by states. 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.
The author mentions California’s licensure upon graduation pathway. 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 they pass a clinical exam.
The IDDLC requires the ADEX exam exclusively (licensees who passed another regional “psychomotor” exam prior to January 1, 2024 are grandfathered). 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 at the exclusion of others. New dentists and dental hygienists (practicing under 5 years) who took an exam other than ADEX, or any dentist who took the DLOSCE or completed a PGY-1 are excluded from participating and would be forced to reexamine if they wanted to utilize the compact. The IDDLC reduces mobility for these dentists.
3. State Specific Requirements
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 (local anesthesia for example), the licensee needs to satisfy those prior to legally providing those services. The compact gets a hygienist access to work in another compact state quickly, but what the hygienist is allowed to do is still governed by each state. The same principle applies for dental specialties. The compact gets a dentist authorization to practice general dentistry in a streamlined manor, but any extra requirements to practice a specialty would still need to be satisfied. In short, licensees must abide by all of the laws and rules in whatever state they are practicing.
Conclusion
The DDH compact is widely supported as the agreed upon solution to licensure portability issues for dentistry and dental hygiene. The list of supporters includes the ADA, ADHA, Association of Dental Support Organizations, American Dental Education Association, American Student Dental Association, American Association of Endodontists, and American Association of Orthodontists. The compact has been enacted in 10 states and has pending legislation in 16 states during 2025. Conversely the IDDHLC has been enacted by zero states.
Thank you for considering this information, and we hope you provide this additional clarity to your readers.
Sincerely,
Erin Haley-Hitz, RDH, BSDH, MS, FADHA, MAADH
President, American Dental Hygienists’ Association
Brett Kessler, DDS
President, American Dental Association
JoAnn Gurenlian, RDH, MS, PhD, AAFAAOM, FADHA
Chair, Coalition for Modernizing Dental Licensure
Matt Shafer
Deputy Policy Director National Center for Interstate Compacts
The Council of State Governments