| A | B | D | E | F | G | H | I | J | |
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1 | Timestamp | Name | Written Comments | ||||||
2 | 5/6/2026 16:14:44 | Robin Asbury DDS | With years of proper and thorough head and neck education and experience both dentists and hygienists are qualified to inject neurotoxins and dermal fillers or anything else a med spa offers for above the shoulders. As a forward thinking profession, let's encourage patients to trust dental providers because technically we are more qualified than most physicians and nurses regarding continuing education in the head and neck region. | ||||||
3 | 5/6/2026 16:36:28 | Lisa Westhoff RDH MSDH | 1.25 placement of ITR by RDH (B). Limiting "reasonable distance" to a specific milage removes patient autonomy; especially in the most rural areas of CO. There may be a dentist within the required 60 miles but the patient may have an established dental home that is farther than 60 miles. For example, patients living in rural Lamar frequently have dental and medical homes that are well established in Pueblo and CO Springs even though there may be providers within the required 60 miles. Requiring a licensed, educated, and highly skilled dental hygienist to justify why a patient is not seeing the dentist 60 miles away versus the patient's preferred dentist 120 miles away creates undue burden on the licensed RDH and on the patient. This verbiage removes patient autonomy and their right to receive care from the provider of their choosing. It is not up to the Dental Board to dictate where and who a patient receives treatment from. | ||||||
4 | 5/7/2026 7:56:01 | Sarah Tanner RDH, BSDH | May 7, 2026 Colorado Dental Board Stakeholder Meeting – Senate Bill 25-194 Rule Review RE: Stakeholder Feedback Regarding Proposed Rule Revisions and Additions under Colorado Senate Bill 25-194 Dear Members of the Colorado Dental Board, My name is Sarah Tanner, RDH, BSDH, Myofunctional Therapist, and owner of [Luxury Tooth Booth Inc.](https://www.luxurytoothboothinc.com?utm_source=chatgpt.com) in Colorado. I am writing to provide stakeholder feedback regarding the proposed revisions and additions associated with Senate Bill 25-194 and the continuation of the Colorado Dental Practice Act. As a Registered Dental Hygienist with over a decade of experience in private practice, public health, biological dentistry, mobile dentistry, airway health, teledentistry, and independent direct-access care, I strongly support thoughtful modernization of Colorado’s Dental Practice Act that improves patient access, prevention, safety, interdisciplinary collaboration, and utilization of licensed dental hygienists to the full extent of their education and competency. Colorado has become a national leader in expanding access to preventive oral healthcare through direct-access dental hygiene services. My professional journey has allowed me to witness firsthand how essential scope modernization is for reaching underserved populations, including: • Seniors in assisted living and memory care • Homebound and bedbound patients • Rural and underserved communities • Patients with dental trauma and anxiety • Medicaid and uninsured populations • Patients suffering from airway and sleep-related disorders Many of these individuals would otherwise go without preventive care entirely if providers like myself were not able to deliver services in nontraditional and community-based settings. I particularly support the Board’s work regarding: • Teledentistry clarification and implementation • Silver Diamine Fluoride utilization • Expanded preventive capabilities for dental hygienists • Public health-focused modernization • Clarification surrounding infection control standards • Appropriate utilization of allied dental professionals As the owner of a mobile and studio-based dental hygiene practice, teledentistry has become an essential tool in improving communication, triage, preventive education, continuity of care, interdisciplinary referrals, and patient accessibility. Many patients I serve face transportation, mobility, cognitive, or financial barriers that make traditional care settings difficult or impossible to navigate. Additionally, I appreciate the inclusion and recognition of Silver Diamine Fluoride (SDF) within proposed rule revisions. SDF has become one of the most valuable minimally invasive preventive tools available, especially for pediatric, medically compromised, geriatric, and special-needs populations. Expanding and clarifying its use helps preserve dentition, reduce infection risk, minimize unnecessary extractions, and improve quality of life for vulnerable patients. I also believe it is critical that Colorado continue recognizing the growing role dental hygienists play in whole-body healthcare integration. As both a dental hygienist and myofunctional therapist involved in airway and sleep apnea care, I routinely see the connection between oral inflammation, sleep-disordered breathing, cardiovascular health, diabetes, and systemic disease. Dental hygienists are uniquely positioned to provide preventive screenings, patient education, early intervention, and collaborative referrals that improve overall public health outcomes. My hope is that Colorado continues moving toward: • Greater utilization of licensed dental hygienists • Increased preventive access for underserved populations • Support for independent and direct-access practice models • Collaborative medical-dental integration • Safe modernization that reflects current education and evidence-based practice • Regulatory clarity that supports innovation while maintaining patient protection I would also encourage the Board to continue ensuring that rule language supports practical implementation for providers working in mobile, community-based, and nontraditional practice settings. These models are increasingly important in addressing workforce shortages, access disparities, and preventive care gaps throughout Colorado. I appreciate the Board’s willingness to hear stakeholder feedback and to engage dental professionals directly affected by these legislative and regulatory changes. I remain passionate about advancing prevention-focused, patient-centered care and advocating for safe, accessible, and evidence-based oral healthcare delivery throughout our state. Thank you for your time, consideration, and continued service to the people of Colorado. Respectfully, Sarah Tanner, RDH, BSDH Myofunctional Therapist Owner, [Luxury Tooth Booth Inc.](https://www.luxurytoothboothinc.com?utm_source=chatgpt.com) Clinical Director, [SASA Clinics – Snoring and Sleep Apnea Clinics](http://snoringandsleepapneaclinics.com?utm_source=chatgpt.com) Lakewood & Parker, Colorado | ||||||
5 | 5/7/2026 9:41:55 | Graig Bears | |||||||
6 | 5/10/2026 17:10:23 | Mason Miner | To Members of the Colorado Dental Board I have some suggested wording changes to 1.34 B. Recommended wording: A licensed dentist must ensure that any neuromodulator or dermal filler that will be injected into a patient is approved for use by the United States Food and Drug Administration (FDA). Reason: Remove language specifying dentistry as most pharmaceuticals are approved for medical use and dentistry falls under the medical umbrella. Also as once upon a time, nitrous oxide was a separate permit, now it is included in the license, so should these injectable products be included in the license. There is not a need to have a special permit for them. Omit D. = does the Board really want to be burdened by having a “special permit” in order to perform these injections? Complaints regarding this are so few. Is it really worth the effort? Does it really help to protect the public by having a “special permit?” Or is this just another attempt for the State to impose a tax or fee to get more money. The Board should also provide or include language for products like Sculptra and others which are not dermal fillers but are other facial injectable products. Alternative language: A dentist who administers neuromodulators, dermal fillers, and other FDA approved facial aesthetic products/pharmaceuticals shall provide documentation regarding their training, education, credentials, and qualifications for the procedures performed that are authorized in this section if the Board so requests the documentation regarding their education and training. E. I recommend the following wording. Instead of burdening the Board with unnecessary special permitting and while still protecting the public, revise this section: If the Board seeks to verify the credentials of a dentist who administers neuromodulators, dermal fillers, and other such facial injectable products/pharmaceuticals, upon request the dentist must provide documentation of having successfully completed a ten (10) hour didactic and hands-on course of study in the injection of such neuromodulators and dermal fillers in the region of the oral cavity and associated adjacent structures, to include the oral and maxillofacial regions. It is illogical to have a special permit for this when these products are temporary and not permanent. With that in mind, why is there not a special permit for placing dental implants which are far more invasive and complications are far more impactful than facial esthetic products? Why are these products be singled out? It is also illogical to specify how much training one must have in order to provide these services. It is also illogical to mandate ongoing CE for this. The reason, these are temporary. Significant / severe complications are very rare with facial injectable products. Mandating CE does not protect the public, which the Board knows. Along that line, if CE is going to be mandated, why not have a special permit and ongoing CE requirements for the surgical placement of dental implants which again are far more invasive and intrusive. The public should be protected more with dental implant procedures than facial injectables. Mandating the 10 hours of training for dental hygienist in my view helps to protect the public as hygienists do not have as extensive of training in facial anatomy that dentists receive. Thank you for your consideration Mason Miner, DDS DEN 8689 | ||||||
7 | 5/19/2026 9:15:31 | Dani Ford | The Colorado Dental Hygienists’ Association provided both verbal and written testimony during the April 30, 2026 rulemaking hearing regarding proposed revisions to Sections 1.33(C) and 1.33(H)(2). Specifically, we recommended revising these sections so that the educational requirements for dentists practicing in integrated healthcare settings, as well as for dental hygienists and dental therapists, continue to incorporate all components of Section B(1)(A–G), rather than omitting subsection (A) as currently written. Removing education related to vaccine handling and storage is inconsistent with both state and federal immunization requirements. The Centers for Disease Control and Prevention (CDC), as well as the Colorado Immunization Branch, require that all personnel who receive, handle, store, or administer vaccines complete comprehensive, competency-based education addressing both vaccine administration policies and proper storage and handling procedures. Cold chain maintenance and compliance are essential components of safe vaccine management and administration, regardless of the healthcare setting in which vaccines are provided. Omitting these educational requirements from the rules would create inconsistency with established immunization standards and could jeopardize patient safety and regulatory compliance. For these reasons, Sections 1.33(C) and 1.33(H)(2) should be revised to explicitly reference Section B(1)(A–G) in its entirety. While the depth or duration of training may appropriately vary depending on the provider role or practice setting, education regarding vaccine storage and handling cannot be excluded. The Colorado Dental Association also supported this recommendation during the April 30, 2026 rulemaking hearing. We are disappointed that this correction has not yet been incorporated into the proposed rules. If left unchanged, the language will create confusion and misinformation during implementation and may result in noncompliance with existing immunization standards and regulations. Section 1.33 C NEEDS to read: A dentist who administers vaccines within a hospital or Integrated Health Care setting, such as a Federally-Qualified Health Center, Accountable Care Organization or Healthcare Maintenance Organization that includes other appropriately trained vaccinators and where the dentist is not directly responsible for the storage of vaccines shall only be required to complete an immunization delivery course of at least four (4) hours in length that includes sections (B)(1)(a-g) of this Rule. And section 1.33 H(2) NEEDS to read: Such training courses must cover topics that include sections (B)(1)(a - g) of this Rule We strongly urge the Board to correct this language before the rules are finalized and published to ensure clear, consistent, and compliant implementation. Failure to do so will create unnecessary confusion regarding educational requirements and may result in inconsistency with existing state and federal immunization standards. | ||||||
8 | 5/19/2026 18:10:27 | Colorado Dental Association - Lauren Harvey | 1.34 Administration of Neuromodulators and Dermal Fillers • In 1.34 D. – Strike the current language in D. entirely, as it implies that a dentist must get a permit to administer botox and fillers. There should NOT be a permit required; rather, the requirement should be to document required training and education, as is the case with immunizations, opioids, etc. • After E., include the following: o “Documentation of successful completion of required training and education courses must be kept on file by the dentist for review by the Board, upon request.” • In 1.34 J. – Strike the current language in J. entirely (same rationale as noted above for 1.34 D.) • In 1.34 K. – Strike “A licensed dental hygienist may apply to the Board upon successful completion of a course approved by the Board that meets the minimum requirements as follows:” o Replace with “A licensed dental hygienist seeking to administer neuromodulators and dermal fillers must provide documentation of having successfully completed a course approved by the Board that meets the minimum requirements as follows:” • After K., include the following: o “Documentation of successful completion required training and education courses must be kept on file by the dental hygienist for review by the Board, upon request.” 1.36 Practice of Teledentistry. o As written, this section, and particularly part J., may create overly restrictive requirements for the provision of teledentistry. We would suggest that teledentistry regulations should mirror more of what is found in telemedicine regulations - specifically in the Colorado Medical Board Policy Section 40-27 Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine o As well, P. 2. References the term “supervision” in a general manner, however that is not specific as it should be for dentistry. There is unsupervised, indirect supervision, and direct supervision. P.1. already covers indirect supervision, what is the need or rationale for including P.2.? This could create confusion that direct supervision could be done through teledentistry, which is not correct based on the definition of direct supervision | ||||||
9 | 5/20/2026 | Kevin M. Patterson, DDS, MD | 5.20.26 Stakeholder meeting written comments: Issue #1 Reasonable distance Statute does not state that a mileage number be applied to “reasonable”. In our review and recommendations of statutes the term “reasonable” was decided on and approved by the legislature. Due to the nature of the topography of Colorado reasonable distance may mean different things based on the region in the state and the time of year as weather events can significantly add to the driving times and distances as alternate routes may be necessary. This definition is listed in 1.25B and 1.35A2, For the reasons above the “sixty (60) miles” should be stricken as the definition of reasonable. 1.25 Placement of Interim Therapeutic Restorations by Dental Hygienists B. Before providing interim therapeutic restorations, a dental hygienist shall confirm in communication to the supervising dentist a referral for follow-up care to a licensed dentist within a reasonable distance. “Reasonable distance” is defined to mean within sixty (60) miles from the location where the interim therapeutic restoration is placed or any greater distance if the reason for referral to such location is documented in the patient’s chart. 1.35 Itinerant Surgery (A)(2.) As used in this section, “a reasonable distance” means within sixty (60) miles of the location where the itinerant surgery was performed or any greater distance if the reason for referral to such location is documented in the patient’s chart. Issue #2 Permit requirement for a dentist to administer neuromodulators and dermal fillers. It was never the intent of the approved practice act legislation to require a dentist to obtain a permit to administer neuromodulators and dermal fillers. These procedures are now listed in statute as to what defines the practice of dentistry. For the same reason a dentist does not need a separate permit to perform oral surgery, endodontic, periodontal, orthodontic and prosthodontic procedures, the ability to administer neuromodulators and dermal fillers should also not require a permit. There are clearly defined rules that must be followed for a dentist to provide these services so requiring a permit will increase the administrative burden for the dental board and the financial burden for dental providers. The medical practice act, rules and policies do not have a permit requirement for a medical provider to provide these services, all that is mentioned is that the provider needs to have sufficient training. 1.34 Administration of Neuromodulators and Dermal Fillers D. A dentist seeking to administer neuromodulators and dermal fillers shall apply to the Board, pay any applicable fees, and provide documentation regarding their training, education, credentials, and qualifications before undertaking to perform procedures authorized in this section. E. A dentist seeking to administer neuromodulators and dermal fillers must “upon request” provide documentation of having successfully completed a ten (10) hour didactic and hands-on course of study in the injection of such neuromodulators and dermal fillers in the region of the oral cavity and associated adjacent structures, to include the oral and maxillofacial regions. This course of study must include the following components: Issue #3: Restrictive language pertaining to the practice of teledentistry Medical policy statement 40-03 outlines the definition of the provider/patient relationship so these requirements of when a relationship is established should be the same for dentistry. Telehealth is not an exclusive means of care delivery to any specific healthcare profession it is a tool used by healthcare providers to increase access to care. Language that is too restrictive will do exactly the opposite of increasing access to care with telehealth services. In order to bring language in dental rules in line with medicine rules then points 1.36 (E) 4-7 should be eliminated from 1.36. Similarly, section 1.36(J) should also be eliminated. We recommend adopting the language from Medical Policy 40-27 into 1.36 as it clearly spells out the requirements to be met when providing telehealth services. Below please find pertinent medical policy statements 40-03 and 40-27 pertaining to the definition of the patient-doctor relationship, pertinent section is highlighted in yellow, and guidelines for the use of telehealth services. These documents already exist on the medical side and language for dentistry should be similar. 40-03 Policy Statement Regarding the Provider/Patient Relationship Date Issued: 11/13/97 Date(s) Revised: 7/1/10; 8/20/15 Purpose: To clarify the Colorado Medical Board’s definition of, and position concerning the provider/patient relationship. POLICY: The Colorado Medical Board (“Board”) adopts the following policy regarding the provider- patient relationship: The Board defines “Provider” to include licensees regulated by the Board and the “Provider- Patient Relationship” as the mutual understanding, between a provider and patient, of the shared responsibility for the patient’s healthcare. This relationship is established when: A. The provider agrees to undertake diagnosis and treatment of the patient, and the patient, or a medical proxy for the patient, agrees to be treated- whether or not there has been an in-person encounter between the patient and the provider; and, B. The provider: i. Verifies and authenticates the patient’s identity and location; ii. Discloses his or her identity and applicable credential(s) to the patient; and, iii. Obtains appropriate informed consent after any relevant disclosures regarding the delivery models and treatment methods or limitations, including any special informed consents regarding the use of telehealth technologies. A “Provider-Patient Relationship” has not been established when either the identity of the provider is unknown to the patient, or the identity of the patient is not known to the provider. Further, the Board finds the relationship between a provider and a patient is fundamental and is not to be constrained or adversely affected by any considerations other than what is best for the patient. The existence of other considerations, including financial or contractual concerns is, and must be, secondary to the fundamental relationship. Prevailing models of medical practice may result in an inappropriate restriction of the provider’s' ability to practice quality medicine, creating negative consequences for the patient. It is the expectation of the Board that providers take those actions they consider necessary to assure that the procedures in question do not adversely affect the care that they render to their patients. 5.20.2026 rule for consideration 1.36 Practice of Teledentistry E. A dental practitioner-patient relationship may be established either in-person or through telehealth /teledentistry but must include all of the following: 1. Thorough verification and authentication of the location and, to the extent possible, identity of the patient; 2. Disclosure and validation of the dental practitioner’s identity and credentials; 3. Receipt of appropriate consent from a patient after disclosure regarding the delivery model and treatment method or limitations, including informed consent regarding the use of teledentistry technologies. a. The consent requirements of this section do not apply to the transmission of diagnostic images to another dental practitioner or healthcare provider or dental specialist or the reporting of diagnostic test results by that specialist. b. If the consent is obtained verbally, the shall document the consent in the patient's record. 4. Establishment of a diagnosis through the use of acceptable dental practices, such as patient history, physical examination, and appropriate diagnostic and laboratory testing to establish diagnoses; 5. Discussion with the patient of any diagnosis and supporting evidence as well as risks and benefits of various treatment options; 6. The availability of a distant site provider or other coverage for appropriate follow-up care; 7. A written visit summary provided to the patient. J. Dental practitioners using teledentistry/ telehealth technologies to deliver dental care services to a patient must, prior to diagnosis and treatment, do at least one (1) of the following: 1. Provide an appropriate examination in-person; 2. Require another Colorado-licensed healthcare provider be present at the originating site with the patient at the time of the diagnosis; 3. Make a diagnosis using audio or visual communication for time-sensitive or urgent circumstances rather than routine diagnosis; 4. Meet the standard of service required by applicable professional societies in guidelines developed for establishing a dental practitioner-patient relationship as part of an evidenced-based clinical practice in teledentistry. 40-27 Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine Date Issued: 8/20/2015 Date(s) Revised: 12/18/2020; 8/19/21 Purpose: To provide guidance regarding the appropriate use of telehealth technologies in the practice of medicine. Policy: The Colorado Medical Board (“Board”) has adopted the following guidelines for providers utilizing telehealth technologies in the delivery of patient care. I. Introduction The advancements and continued development of medical and communications technology offer opportunities for improving the delivery and accessibility of health care, particularly in the area of telehealth, which includes the practice of medicine using electronic communication, information technology, or other means of interaction between a healthcare provider in one location and a patient in another location with or without an intervening healthcare provider. The Colorado Medical Board (“Board”) recognizes that using telehealth technologies in the delivery of medical services offers potential benefits in the provision of medical care. However, in fulfilling its duty to protect the public, the Board must also consider patient safety concerns in adapting rules and policies historically intended for the in-person provision of medical care to new delivery models involving telehealth technologies. The Board is committed to assuring patient access to the convenience and benefits afforded by telehealth technologies, while promoting the responsible practice of medicine by providers. The Board has developed guidelines to educate licensees as to the appropriate use of telehealth technologies in the delivery of medical services directly to patients. These guidelines do not set a standard of care, do not alter generally accepted standards of medical practice, the scope of practice of any health care provider, or authorize the delivery of health care services in a setting, or in a manner, not otherwise authorized by law. It is the expectation of the Board that providers of medical care, electronically or otherwise, maintain the highest degree of professionalism and should: • Place the welfare of patients first; • Maintain the generally accepted standards of medical practice; • Adhere to recognize ethical codes governing the medical profession; • Properly supervise non-physician clinicians; and, • Protect patient confidentiality. This policy does not apply to the use of telehealth technologies when solely providing consulting services to another provider who maintains the primary provider-patient relationship with the patient, the subject of the consultation. II. Definitions For the purpose of this policy, the following terms are defined as: A. "TELEHEALTH" 1. “Telehealth” means a mode of delivery of health care services through HIPAA-compliant telecommunications systems, including information, electronic, and communication technologies, remote monitoring technologies, and store-and-forward transfers, to facilitate the assessment, diagnosis, consultation, treatment, education, care management, or self-management of a covered person's health care while the person is located at an originating site and the provider is located at a distant site. 2. “Telehealth” includes “Telemedicine” as defined in section 12-240-104(6), C.R.S. 3. This policy defines “telehealth” for purposes of compliance with the Medical Practice Act. Telehealth may be defined differently in different statutory contexts, including but not limited to, insurance requirements or reimbursement. B. “TELEHEALTH TECHNOLOGIES” means technologies and devices enabling secure electronic communications and information exchange between a licensee in one location and a patient in another location with or without an intervening healthcare provider. C. "DISTANT SITE" means a site at which a provider is located while providing health care services by means of telehealth. D. "ORIGINATING SITE" means a site at which a patient is located at the time health care services are provided to him or her by means of telehealth. E. “STORE-AND-FORWARD TRANSFER" means the electronic transfer of a patient's medical information or an interaction between providers that occurs between an originating site and distant site when the patient is not present. F. "SYNCHRONOUS INTERACTION" means a real-time interaction between a patient located at the originating site and a provider located at a distant site. G. “PROVIDER” means a licensee regulated by the Colorado Medical Board. H. “PROVIDER-PATIENT RELATIONSHIP” means the relationship as defined in Board Policy 40-3. III. Guidelines A. Licensure Providers who evaluate, treat or prescribe through telehealth technologies are practicing medicine. The practice of medicine occurs where the patient is located at the time telehealth technologies are used. Therefore, a provider must be licensed to practice medicine in the state of Colorado in order to evaluate or treat patients located in Colorado utilizing telehealth technologies or otherwise. B. Establishment of a Provider-Patient Relationship Where an existing provider-patient relationship is not present, a provider must take appropriate steps to establish a provider-patient relationship consistent with the guidelines identified in Board Policy 40-3. Provider-patient relationships may be established using telehealth technologies so long as the relationship is established in conformance with generally accepted standards of practice. C. Evaluation and Treatment of the Patient An appropriate medical evaluation and review of relevant clinical history, commensurate with the presentation of the patient to establish diagnoses and identify underlying conditions and/or contra-indications to the treatment recommended/provided, s h o u l d be performed prior to providing treatment, including issuing prescriptions, electronically or otherwise. Treatment and consultation recommendations made in an online setting, including issuing a prescription via electronic means, will be held to the same standards of appropriate practice as those in traditional (encounter in person) settings. Treatment, including issuing a prescription based solely on an online questionnaire, does not constitute an acceptable standard of care. D. Informed Consent Appropriate informed consent should be obtained for a telehealth encounter including those elements required by law and generally accepted standards of practice. E. Continuity of Care Physicians should adhere to generally accepted standards of medical practice as it relates to continuity and coordination of care. F. Referrals for Emergency Services An emergency plan should be provided by the provider to the patient when the care provided using telehealth technologies indicates that a referral to an acute care facility or Emergency Department for treatment is necessary for the safety of the patient. G. Medical Records The medical record should include, if applicable, copies of all patient-related electronic communications, including patient-provider communication, prescriptions, laboratory and test results, evaluations and consultations, records of past care, and instructions obtained or produced in connection with the utilization of telehealth technologies. Informed consents obtained in connection with an encounter involving telehealth technologies should also be filed in the medical record. The patient record established during the use of telehealth technologies must be accessible and documented for both the provider and the patient, consistent with all established laws and regulations governing patient healthcare records. H. Privacy and Security of Patient Records & Exchange of Information Providers should meet or exceed applicable federal and state legal requirements of medical/health information privacy, including compliance with the Health Insurance Portability and Accountability Act (HIPAA) and state privacy, confidentiality, security, and medical record retention rules. Written policies and procedures should be maintained at the same standard as traditional in-person encounters for documentation, maintenance, and transmission of the records of the encounter using telehealth technologies. I. Disclosures and Functionality for Providing Online Services Disclosures and advertising should be made in accordance with state and federal law. J. Prescribing Prescribing medications, in-person or via telehealth technologies, is at the professional discretion of the provider. The indication, appropriateness, and safety considerations for each telehealth visit prescription must be evaluated by the provider in accordance with current standards of practice and consequently carry the same professional accountability as prescriptions delivered during an encounter in person. However, where such measures are upheld, and the appropriate clinical consideration is carried out and documented, providers may exercise their judgment and prescribe medications as part of telehealth encounters. The recommendation of medical marijuana via telehealth technologies is prohibited. K. Parity of Professional and Ethical Standards There should be parity of ethical and professional standards applied to all aspects of a provider’s practice. A provider’s professional discretion as to the diagnoses, scope of care, or treatment should not be limited or influenced by non-clinical considerations of telehealth technologies, and provider remuneration or treatment recommendations should not be materially based on the delivery of patient-desired outcomes (i.e. a prescription or referral) or the utilization of telehealth technologies. L. Exemptions from Policy 40-27: Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine The Colorado Medical Board recognizes the challenges during a public health emergency. The Food and Drug Administration (“FDA”) guidelines for testing in times of a public health emergency shall guide Colorado policy for the purposes of Policy 40-27: Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Medicine. Issue #4: 1.37 (P)(2)- There is no term “general supervision” in dental statutes or rules there is only unsupervised, direct supervision or indirect supervision. Teledentistry would be a form of indirect supervision as the provider is not in the same location and the DH or DT being supervised. P. Supervision. With the exception of administering nitrous oxide inhalation analgesia, or performing expanded functions, a dentist may delegate and supervise services to be performed by a dental hygienist or dental therapist. 1. When indirect supervision of a dental hygienist or dental therapist is required, a dentist may provide indirect supervision using live video. A dentist is not required to directly supervise the entire delivery of dental care but must appear upon request using live video with a response time similar to what would be expected if the dentist were present in the treatment facility. 2. When general supervision of a dental hygienist or dental therapist is required, a dentist may utilize teledentistry. Thank you, Kevin Patterson, DDS, MD | ||||||
10 | 5/20/2026 8:51:03 | Jessica Jack | I am a pediatrician who has done research supporting vaccination in the dental setting and am working to implement this practice once rulemaking is complete The Colorado Dental Hygienists’ Association provided both verbal and written testimony during the April 30, 2026 rulemaking hearing regarding proposed revisions to Sections 1.33(C) and 1.33(H)(2). Specifically, we recommended revising these sections so that the educational requirements for dentists practicing in integrated healthcare settings, as well as for dental hygienists and dental therapists, continue to include all components of Section B(1)(A–G), rather than excluding subsection (A) as currently written. Removing education related to vaccine handling and storage is inconsistent with both state and federal immunization requirements. The Centers for Disease Control and Prevention (CDC), along with the Colorado Immunization Branch, require that all personnel who receive, handle, store, or administer vaccines complete comprehensive, competency-based education addressing both vaccine administration policies and proper vaccine storage and handling procedures. Cold chain maintenance and compliance are critical components of safe vaccine management and administration, regardless of the healthcare setting in which vaccines are provided. Omitting these educational requirements from the rules creates inconsistency with established immunization standards and may jeopardize patient safety and regulatory compliance. For these reasons, Sections 1.33(C) and 1.33(H)(2) should be revised to explicitly reference Section B(1)(A–G) in its entirety. While the depth or duration of training may appropriately vary depending on the provider role or practice setting, education related to vaccine storage and handling cannot be excluded. The Colorado Dental Association also supported this recommendation during the April 30, 2026 rulemaking hearing. We are disappointed that this correction has not yet been incorporated into the proposed rules. If left unchanged, the language will create confusion during implementation and may contribute to noncompliance with existing immunization standards and regulations. Section 1.33(C) SHOULD read: “A dentist who administers vaccines within a hospital or Integrated Health Care setting, such as a Federally Qualified Health Center, Accountable Care Organization, or Health Maintenance Organization that includes other appropriately trained vaccinators, and where the dentist is not directly responsible for vaccine storage, shall only be required to complete an immunization delivery course of at least four (4) hours in length that includes sections (B)(1)(a-g) of this Rule.” And Section 1.33(H)(2) SHOULD read: “Such training courses must cover topics that include sections (B)(1)(a-g) of this Rule.” I strongly urge the Board to correct this language before the rules are finalized and published to ensure clear, consistent, and compliant implementation. Failure to do so will create unnecessary confusion regarding educational requirements and may result in inconsistency with existing state and federal immunization standards. | ||||||
11 | 5/20/2026 13:23:17 | Scott Hamilton DDS | “The Colorado Dental Hygienists’ Association and Colorado Dental Association provided both verbal and written testimony during the April 30, 2026 rulemaking hearing regarding proposed revisions to Sections 1.33(C) and 1.33(H)(2). Specifically, we recommended revising these sections so that the educational requirements for dentists practicing in integrated healthcare settings, as well as for dental hygienists and dental therapists, continue to incorporate all components of Section B(1)(A–G), rather than omitting subsection (A) as currently written. Removing education related to vaccine handling and storage is inconsistent with both state and federal immunization requirements. The Centers for Disease Control and Prevention (CDC), as well as the Colorado Immunization Branch, require that all personnel who receive, handle, store, or administer vaccines complete comprehensive, competency-based education addressing both vaccine administration policies and proper storage and handling procedures. Cold chain maintenance and compliance are essential components of safe vaccine management and administration, regardless of the healthcare setting in which vaccines are provided. Omitting these educational requirements from the rules would create inconsistency with established immunization standards and could jeopardize patient safety and regulatory compliance. For these reasons, Sections 1.33(C) and 1.33(H)(2) should be revised to explicitly reference Section B(1)(A–G) in its entirety. While the depth or duration of training may appropriately vary depending on the provider role or practice setting, education regarding vaccine storage and handling cannot be excluded. The Colorado Dental Association also supported this recommendation during the April 30, 2026 rulemaking hearing. We are disappointed that this correction has not yet been incorporated into the proposed rules. If left unchanged, the language will create confusion and misinformation during implementation and may result in noncompliance with existing immunization standards and regulations. Section 1.33 C NEEDS to read: A dentist who administers vaccines within a hospital or Integrated Health Care setting, such as a Federally-Qualified Health Center, Accountable Care Organization or Healthcare Maintenance Organization that includes other appropriately trained vaccinators and where the dentist is not directly responsible for the storage of vaccines shall only be required to complete an immunization delivery course of at least four (4) hours in length that includes sections (B)(1)(a-g) of this Rule. And section 1.33 H(2) NEEDS to read: Such training courses must cover topics that include sections (B)(1)(a - g) of this Rule We strongly urge the Board to correct this language before the rules are finalized and published to ensure clear, consistent, and compliant implementation. Failure to do so will create unnecessary confusion regarding educational requirements and may result in inconsistency with existing state and federal immunization standards.” | ||||||
12 | 5/27/2026 13:45:18 | Sonja OLeary, MD | As a pediatrician and department chair overseeing pediatric services and integrated school-based health clinics, I am writing to express concern regarding the current proposed revisions to Sections 1.33(C) and 1.33(H)(2) discussed during the April 30, 2026 rulemaking hearing. The proposed language removes educational requirements related to vaccine handling and storage for dentists practicing in integrated healthcare settings, as well as for dental hygienists and dental therapists. This omission is inconsistent with established immunization standards and does not align with operational expectations within integrated healthcare delivery systems. In pediatric and school-based healthcare settings, vaccine administration is not an isolated clinical task. It is part of a highly regulated system of patient safety, cold chain management, quality assurance, and regulatory compliance. Regardless of whether a provider is directly responsible for vaccine inventory management, all personnel involved in receiving, handling, storing, or administering vaccines must understand the principles of vaccine storage and handling in order to safely participate in immunization delivery. Both the Centers for Disease Control and Prevention (CDC) and the Colorado Immunization Branch require competency-based education addressing vaccine administration, storage, handling, and cold chain maintenance. These standards exist because improper storage or handling can compromise vaccine integrity, reduce efficacy, contribute to waste, and ultimately place patients at risk. The proposed language should read as follows: Section 1.33(C): “A dentist who administers vaccines within a hospital or Integrated Health Care setting, such as a Federally-Qualified Health Center, Accountable Care Organization or Healthcare Maintenance Organization that includes other appropriately trained vaccinators and where the dentist is not directly responsible for the storage of vaccines shall only be required to complete an immunization delivery course of at least four (4) hours in length that includes sections (B)(1)(a-g) of this Rule.” Section 1.33(H)(2): “Such training courses must cover topics that include sections (B)(1)(a-g) of this Rule.” I am disappointed this correction has not yet been incorporated into the proposed rules despite concerns raised during the hearing by both dental and healthcare stakeholders. If finalized as currently written, the rules may create confusion regarding training expectations and result in inconsistencies with existing state and federal immunization standards. I respectfully urge the Board to revise this language prior to final adoption to ensure clarity, patient safety, regulatory alignment, and consistent implementation across integrated healthcare settings. | ||||||
13 | 6/26/2026 | Joe Mullin | Dear Board Chair Gill and Vice Chair Politano: Attached please find comments from the American Society of Plastic Surgeons in opposition to the proposed amendments to Rule 3 CCR 709-1. Thank you for your consideration of our position on this important issue. Please do not hesitate to contact me with any questions.RE: Oppose Proposed Amendments to Rule 3 CCR 709-1 Dear Gill and Vice Chair Politano: On behalf of the American Society of Plastic Surgeons, I write in opposition to the proposed amendments to Rule 3 CCR 709-1. ASPS is the largest association of plastic surgeons in the world, representing more than 8,000 members and 92 percent of all board-certified plastic surgeons in the United States – including 180 in Colorado. Our mission is to advance quality care for plastic surgery patients and promote public policy that protects patient safety. As surgeons, we encourage you to preserve the established high level of patient care in Colorado by opposing the proposed amendments. We strongly believe that these procedures on the maxillofacial region or associated and adjacent structures should only be performed by licensed medical doctors (MDs) or doctors of osteopathic medicine (DOs) who meet appropriate education, training, and professional standards. If passed, the proposed amendments would allow dentists to perform procedures that fall squarely outside the scope of dentistry – and thus beyond a level appropriate for a dentist’s training and clinical capacity. We must even more strongly oppose these efforts to expand the scope of practice for dental hygienists. There are serious patient risks involved with including these injections in the scope of practice for dentists and dental hygienists, because they lack clinical training to perform injections outside of the oral cavity. For example, an injection error of just a few millimeters can result in a punctured eyeball with resulting catastrophic vision loss. Such errors could also result in a perforated blood vessel, which connects to the back of the eye and can cause immediate and permanent vision loss. Another severe risk is misdiagnosing a cancerous lesion as benign, and then improperly injecting it, which can result in the spread of cancer. While some injections are intended for cosmetic use, the risk of an injection error noted above still exists. In terms of cosmetic injections, ASPS’s policy statement on the administration of botulinum toxin neuromodulators – enclosed for your review – goes into great detail on the background of the development of injecting botulinum toxins and other similar therapies. It took over 30 years of research and development to derive clinical uses of botulinum toxins to treat serious medical conditions, such as cervical dystonias, cranial nerve VII disorders, benign essential blepharospasm, general spasticity, strabismus, migraine headaches, hyperhidrosis, vocal cord dysfunction, anal fissures, urinary incontinence, bruxism, vasospastic disorders of the hand, and other conditions. Botulinum toxins are now an established component of facial rejuvenation. To ensure patient safety and promote quality of care, it is important to appreciate training differences between surgeons, dentists, and dental hygienists. A doctor of dental surgery (DDS) or doctor of medicine in dentistry (DMD) completes four years of dental school following graduation from an undergraduate program. A dental hygienist might only complete two years of dental hygiene school at the undergraduate program. In contrast, plastic surgeons must attain a core medical and surgical education while completing ten to twelve years of training, which includes increased responsibility and decision-making authority in the hospital setting. Board-certified plastic surgeons must: (1) earn a medical degree; (2) complete six to eight years of full-time experience in a residency training program accredited by the Accreditation Council for Graduate Medical Education (ACGME); and (3) the last three years of training must be completed in the same program. In fact, we urge you to read a recent North Carolina State Board of Dental Examiners’ statement regarding elective cosmetic procedures to further understand the differences in training expectations for dentists. The dental board itself released a position statement that the use of cosmetic facial procedures, drugs, or cosmetic chemical facial enhancement for purely cosmetic applications is outside of the appropriate scope of practice for dentistry, as it does not involve the treatment of the teeth, gums, alveolar process, jaws, maxilla, mandible, or adjacent tissues or structures of the oral cavity. Allowing dentists and dental hygienists, who have not also fulfilled the requisite medical school and postdoctoral residency training, to inject botulinum toxin neuromodulators in this region would jeopardize patient safety and lower the standard of care in Colorado. Thank you for your leadership on this important issue. Please do not hesitate to contact Joe Mullin, ASPS State Affairs Manager, | ||||||
14 | 7/1/2026 13:47:30 | Micaela Fontaninni, RDH | I respectfully request that the Board reconsider the language in Rule 1.34(H), specifically: “A patient of record shall have had a comprehensive examination by the delegation dentist or physician within the two (2) years prior to the administration of the injection.” This requirement may create an unnecessary barrier to care for patients seeking elective neuromodulator or dermal filler treatment. It may limit access for walk-in patients, individuals in rural or underserved communities, patients seeking care through mobile practices, and patients who already maintain an established relationship with another dentist or physician. Rule 1.34(H) also appears more restrictive than the established physician-delegation model used for medical-aesthetic services in Colorado. If physician-delegated cosmetic injectable services can be performed safely through appropriate evaluation, informed consent, documentation, training, and oversight, I respectfully request that the Board explain what additional patient safety benefit is achieved by requiring a comprehensive examination by the delegating dentist or physician within the previous two years. If a comprehensive examination is deemed necessary, I respectfully ask the Board to consider whether a recent examination by the patient’s own dentist or physician, or an evaluation by the delegating provider through telehealth when clinically appropriate, could satisfy this requirement. I respectfully request that Rule 1.34(H) be revised to preserve patient safety while improving access to care, maintaining patient choice, and allowing qualified dental hygienists to practice within the scope authorized by Colorado law. | ||||||
15 | 7/6/2026 7:40:43 | Colorado Dental Association | 1.13 Limited Prescriptive Authority for Dental Hygienists • In B. 1., for the required two hours of continuing education, we suggest the two hours be specifically designated as one required hour on antibiotics and one required hour one NSAIDS 1.25 Placement of Interim Therapeutic Restorations by Dental Hygienists • We are concerned about around “reasonable distance” being defined as 60 miles. • As discussed with multiple stakeholders during the Sunset legislative process, the statute does not state that a mileage number be applied to “reasonable”. The statute also does not require the Board to define “reasonable distance”. • Due to the nature of the topography of Colorado reasonable distance may mean different things based on the region in the state and the time of year as weather events can significantly add to the driving times and distances as alternate routes may be necessary. 1.33 Administration of Immunizations • For 1.33(C) and 1.33(I)(2), we agree with Dani Ford’s comments to incorporate all components of training topics required in Section B(1)(a-g), rather than omitting subsection (a) as currently written. • Initially the thinking behind omitting (a), pertaining to proper storage and handling of vaccines, was that dental professionals in integrated health care settings are not in charge of vaccine storage duties. However, it makes more sense to have a uniform training standard that applies to all dental professionals administering immunizations, that they have covered all the same training topics. Dental professionals in integrated health care settings may have less direct responsibility for storing vaccines, but it is still important for them to have training on storage as well as handling of vaccines. This is why (a-g) should be covered in (C) and (I)(2), rather than just (b-g) 1.34 Administration of Neuromodulators and Dermal Fillers • We appreciate and agree with the changes made in section D., which makes it clear that the requirement is for a dentist to keep on file their certificate of completion of appropriate training, which can be inspected by the Board upon request. We similarly agree with that change in G. 2. 1.35 Itinerant Surgery • We are concerned about around “reasonable distance” being defined as 60 miles. • As discussed with multiple stakeholders during the Sunset legislative process, the statute does not state that a mileage number be applied to “reasonable”. The statute also does not require the Board to define “reasonable distance”. • Due to the nature of the topography of Colorado reasonable distance may mean different things based on the region in the state and the time of year as weather events can significantly add to the driving times and distances as alternate routes may be necessary. | ||||||
16 | 7/6/2026 15:09:58 | CODHA, Alyssa Aberle | Draft rule 1.13 A appears to have mistakenly struck the word “agents” after “reversal”. The word agents needs to remain for this section to make sense. | ||||||
17 | 7/6/2026 15:11:11 | CODHA, Alyssa Aberle | Draft rule 1.13 B. is inconsistent with statute - In statute, prescriptive authority of dental hygienists is listed under unsupervised dental hygiene. However, in the proposed draft rules, the Colorado Dental Board has written, “Pursuant to section 12-220-503(1)(g)(V), a dental hygienist who has completed appropriate postsecondary coursework may shall not prescribe, dispense, and administer, or dispense the following: non-narcotic analgesics, anti-inflammatories, and antibiotics within the parameters of a written articulation plan, with the authorization of the supervising dentist.” The term “collaborating dentist” should be used here, as it is in the rest of this rule and in statute. - This section should be corrected so that it does not contradict statute. 12-220-503 is what constitutes practicing unsupervised dental hygiene. | ||||||
18 | 7/6/2026 15:11:33 | CODHA, Alyssa Aberle | Draft rule 1.13 F. is redundant as BLS for healthcare providers is already required for all dental hygienists, regardless of whether or not they are prescribing these medications. | ||||||
19 | 7/6/2026 15:12:16 | CODHA, Alyssa Aberle | Education Requirement - CODHA agrees with the language proposed by The Board in section 1.13.B.1. Which says, “Pursuant to section 12-220-503(1)(g)(V), C.R.S., the postsecondary course or continuing education course developed at a postsecondary level must be a minimum of two (2) hours.” - The Colorado Dental Board could specify that one hour of education should be focused on antibiotic stewardship and the other hour could be general pharmacology or pain management related. | ||||||
20 | 7/6/2026 15:13:40 | CODHA, Alyssa Aberle | 1.25 - Placement of Interim Therapeutic Restorations by Dental Hygienists CODHA strongly recommends that The Board remove the definition of “reasonable distance” as was added into 1.25.B. during the last meeting. - C.R.S. 12-220-505 states, “Before providing interim therapeutic restorations, a dental hygienist shall confirm in communication to the supervising dentist a referral for follow-up care to a licensed dentist within REASONABLE PHYSICAL PROXIMITY to the location where the interim therapeutic restoration is being placed. The language in rules uses the term “reasonable distance”, which can be different. - C.R.S. 12-220-505 has used the term “reasonable proximity” since 2021 and the board has not felt the need to define it further. The board was told at their last meeting that they MUST define what this term means, but that is NOT required by statute. - During the legislative process in 2021 and 2025, stakeholders and legislators discussed this term and whether or not it needed to be defined by time or mileage. Because Colorado is such a large state geographically, what is “reasonable” to someone who lives in Lamar, is different from what is “reasonable” to someone who lives downtown Denver. By defining this, we could limit care being provided in the most rural and underserved parts of the state if there is not a dentist available within that distance. The reason Colorado allows dental hygienists to place interim therapeutic restorations is SO THAT patients who can not access a dental office easily may seek care from a dental hygienist who is working under the supervision, and in collaboration with, a dentist. - By defining this term with an arbitrary mileage restriction, the Board restricts a patient’s autonomy to choose a provider and limits them to seek treatment from the nearest provider, rather than the provider they choose. | ||||||
21 | 7/6/2026 15:14:18 | CODHA, Alyssa Aberle | 1.26 - Application of Silver Fluorides and Other Related Safe Alternative Medicaments for Strengthening Teeth and Preventing Tooth Decay by Dental Therapists and Dental Hygienists - Draft rule 1.26 D. should be stricken because a written articulated plan is no longer required for silver fluorides or other medicaments under this section per rule 1.13 revisions. | ||||||
22 | 7/6/2026 15:16:47 | CODHA, Alyssa Aberle | Draft rule 1.34 B. states that we must use products that are approved for use in dentistry by the FDA. Are these products specifically approved for “use in dentistry”? Or is there another way to phrase this? | ||||||
23 | 7/6/2026 15:17:50 | CODHA, Alyssa Aberle | Section 1.34.D. AND Section 1.34. J. AND Section 1.34.K - Section 1.34. D, J, and K sound like it is requiring a permit, but does not state that it is requiring a permit. It states that a dentist must “apply to the Board, pay any applicable fees, and provide documentation…” However, during the legislative process for SB 25-194, DORA emphasized the administrative burden of permits and the cost to both the agency and the licensees. - Nothing in statute requires a permit process for the administration of neuromodulators or dermal fillers by dentists or dental hygienists. - CODHA and CDA recommend that the board handle education and training for these procedures similar to those for lasers and set the education requirements, but does not require a permit as this would require much more time, administrative processes, and fees. - CODHA recommends language similar to what is required for lasers to state: “A licensee administering neuromodulators and/or dermal fillers, or supervises another licensee administering neuromodulators and/or dermal fillers, must maintain evidence of training as required in this Rule. Upon request of the Board, the licensee must submit evidence of such training.” | ||||||
24 | 7/6/2026 15:18:15 | CODHA, Alyssa Aberle | Section 1.34.H. C.R.S. 12-220-504 (1)(e) states a dental hygienist can administer “neuromodulators and dermal fillers for therapeutic and cosmetic purposes under the direct supervision of a licensed dentist, or the delegation of a licensed physician or other delegated professional”. The language used in 1.34.H should be the same as what is in statute. | ||||||
25 | 7/6/2026 15:19:45 | CODHA, Alyssa Aberle | Section 1.34. N. - Section 1.34.N. states that a dental hygienist can only administer such an injection to a patient of record. This “patient of record” language is not found in statute and may present barriers for some practice settings where these procedures are being performed. - The Board attempted to define a “patient of record” which is currently proposed as, “A patient of record shall have had a comprehensive examination within the two (2) years prior to the administration of the injection”. In 2017, the Colorado Dental Board discussed evaluations that could be completed by a dental hygienist and determined that a dental hygienist could NOT complete a comprehensive evaluation within their scope of practice. Based on this decision, a dental hygienist who does not work with a dentist could not fulfill this requirement to consider a patient a “patient of record”. This would limit the scope of practice beyond what is allowed in statute. - This “patient of record” definition also limits the supervision/delegation. According to C.R.S. 12-220-504 (1)(e), a dental hygienist can administer neuromodulators and dermal fillers under the delegation of a medical professional. However, if the patient has to have had a comprehensive evaluation, and the dental hygienist can not complete this evaluation, then the board has essentially limited the scope of practice beyond what is allowed in statute. | ||||||
26 | 7/6/2026 15:21:14 | CODHA, Alyssa Aberle | Rule 1.36 B - 1.36. B should read “A dental practitioner shall not provide dental care” rather than “a dentist”. - 1.36. B.1 should be at the top of the section, not after the term has been used. - 1.36. B. 3. - “synchronous or” should be stricken. Synchronous means “in real time” so it is contradictory to the phrase it is trying to define. | ||||||
27 | 7/6/2026 15:21:37 | CODHA, Alyssa Aberle | 1.36 E. 3. B. - should read “they shall” not “the shall” for the sentence to make sense | ||||||
28 | 7/6/2026 15:22:49 | CODHA, Alyssa Aberle | Section 1.36. P.1. - The proposed language for this section states that indirect supervision can be provided via live video, but that “the dentist must appear upon request using live video with a response time similar to what would be expected if the dentist were present in the treatment facility”. - The definition of indirect supervision in C.R.S. 12-220-104 (9)(a)(I) does not state that the supervising dentist must be immediately available. Indirect supervision has been required for many years in Colorado and has never required the dentist to be present physically or virtually. - This proposed rule would actually create more supervision requirements if a dental hygienist or dental therapist IS using a form of telecommunications than if they are not. - This proposed rule would essentially prohibit the use of “store and forward” forms of teledentistry that are currently being utilized for patient care. | ||||||
29 | 7/6/2026 15:23:15 | CODHA, Alyssa Aberle | Section 1.36. P. 2. - The proposed language for this section states, “When general supervision of a dental hygienist or dental therapist is required…” However, “general supervision” is not a term used in CRS 12-220. Colorado uses the terms direct or indirect supervision only. - CODHA recommends to strike this part of rule 1.36. | ||||||
30 | 7/8/2026 12:47:59 | Danielle Ford MHA, RDH | Rule 1.36 – Practice of Teledentistry Recommendation: Remove Section P from Rule 1.36. Justification: Section P addresses supervision rather than the practice of teledentistry. This conflicts with the statutory definition of teledentistry in § 12-220-104(14.5), C.R.S., which defines teledentistry as a method of delivering dental services, not a framework for supervision. Keeping supervision provisions within Rule 1.36 also creates organizational inconsistencies and potential confusion. Supervision requirements are more appropriately addressed within the existing dental hygiene and dental therapy practice or supervision rules. | ||||||
31 | 7/7/2026 | Meg Groeller (she/her) Senior Government Relations Associate American Society for Dermatologic Surgery Association (ASDSA) | Good Morning, Please see the attached comments. Thank you, Meg Groeller (she/her) Senior Government Relations Associate American Society for Dermatologic Surgery Association (ASDSA) RE: Oppose Proposed Rule Change (2026-00234) Dear Colorado Dental Board: On behalf of the undersigned organizations, we are writing to share our concerns regarding proposed rule change (2026-00234) that would allow dentists and dental hygienists to administer neurotoxins and dermal fillers. These are medical procedures that should require medical education, training, specific knowledge of facial anatomy (especially around the eyes) and the ability to manage the specific complications that may arise. Procedures by any means, methods, devices or instruments that can alter or cause biologic change or damage the skin and subcutaneous tissue constitute the practice of medicine and surgery. This includes the use of foreign or natural substances by injection or insertion. i,ii Our organizations believe that the medical procedures dentists and dental hygienists are seeking to perform which use Food and Drug Administration (FDA)-regulated devices, such as those that can alter or cause biologic change or damage, should only be performed by a physician or appropriately trained non-physician personnel under the direct, onsite supervision of an appropriately trained physician.iii This legislation jeopardizes patient safety and disregards what is considered adequate and appropriate medical education and training. Quality patient care includes evaluating a patient’s needs and condition(s), selecting an appropriate course of treatment and providing adequate follow-up care. With the growing public demand for facial fillers and neuromodulators, providing patients with properly trained, educated, and supervised medical personnel is a safeguard Colorado should have for its citizenry. Fillers and neuromodulators can also be used to treat scars from injury and surgery, as well as from medical conditions; other applications include correcting facial asymmetries resulting from congenital, accidental, or medical conditions. Our utmost concern is to ensure that these products are safely administered by licensed and qualified physicians or under the direct, on-site supervision of a licensed and qualified physician. As with other cutaneous procedures, it is necessary to receive adequate training before using soft-tissue augmentation agents. Physician injectors should first be made to demonstrate a detailed knowledge of anatomy and possible adverse events (such as sensitivity, infection, and necrosis) through passing an American Board of Medical Specialties (or an ABMS-equivalent Board) examination in one of the CORE aesthetic specialties after residency training in one of these disciplines.iv According to the American Dental Association, three or more years of undergraduate education plus four years of dental school is required to graduate and become a general dentistv and dental hygienists receive anywhere from two to four years of education, resulting in an associate degree, baccalaureate, or master's degrees, in some cases.vi The focus of their education is on oral health, rather than the skin and facial tissue. Dentists and dental hygienists are not required to demonstrate competency in procedures involving skin and soft tissue augmentation with products that can alter or damage living tissue. It is of upmost importance that the physician or nonphysician clinician performing procedures with botulinum toxin or dermal fillers have specific, long-term training (such as a medical residency in dermatologic surgery, plastic surgery, facial plastic surgery or oculofacial plastic surgery). The education for dental hygienists does not include this type of intense training; additionally, any short-term training program offered by manufacturers of these products does not adequately protect patient safety. Physicians complete medical school, residency and in many cases specialized fellowship and then board certification in their specialty. Some medical specialties like dermatology, plastic surgery, facial plastic surgery and oculofacial plastic surgery have focused training in using fillers and neuromodulators involving the skin and adjacent structures, which prepares physicians to perform medical procedures using fillers and neuromodulators safely and effectively. Included in this training is proper technique, and the management of any adverse events. Furthermore, the American Medical Association (AMA) states that, “Cosmetic medical procedures, such as botulinum toxin injections, dermal filler injections, and laser and intense pulsed light procedures, be considered the practice of medicine.”vii During a 2021 meeting of the FDA’s General and Plastic Surgery Committee on Soft-Tissue Fillers, the American Society for Dermatologic Surgery’s Task Force on Soft-Tissue Fillers found that knowledge of vascular anatomy is crucial for all filler injections. Intravascular injection is possible at any location on the face, but certain locations carry a higher risk, such as filler embolization; necrosis; visual abnormalities; blindness; and stroke.viii Thus, we are in firm agreement with the FDA’s further updated consumer guidance in 2023 that anyone considering a neurotoxin or dermal filler consult with a licensed provider who is experienced in injecting dermal fillers, knowledgeable about fillers, anatomy, managing complications and knows the risks and benefits of treatment.ix In 2024, the AMA adopted policy on Dentist Scope of Practice Expansion, recognizing “the threat posed to patient safety when dentists and dental hygienists are authorized to practice medicine and administer procedures outside their level of education and training.”x Simply put, neither dentists nor dental hygienists have the same extensive training physicians have, especially when it comes to adverse event management beyond the dental cavity. To best protect the citizens of Colorado from adverse events and ensure quality patient care, we urge you to amend this proposal. Thank you for your strong consideration on this matter. Should you have any questions regarding this critical patient safety issue, please do not hesitate to contact Kristin Hellquist, Senior Chief Advocacy Officer at the American Society for Dermatologic Surgery Association, Sincerely, American Academy of Otolaryngology-Head and Neck Surgery American College of Surgeons American Society for Dermatologic Surgery Association American Society of Plastic Surgeons The Aesthetic Society | ||||||
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