REGULATIONS

A wave of new laws is expanding what hygienists can do solo

Like a talented drummer who to everyone’s surprise also has a great singing voice, hygienists are getting a chance to launch their solo careers.

What's happening: A wave of state laws is expanding what hygienists can do without a dentist physically on-site. The American Dental Hygienists' Association counts 43 states permitting some form of direct access (a hygienist treating patients without a prior dentist exam), up from 28 in 2008. Recent states that have moved on this include:

• New York created an "RDH-CP" credential that lets experienced hygienists (at least 3 years and 4,500 hours) practice in hospitals, FQHCs, schools, long-term care, and mobile units under a written collaborative agreement without a dentist present.
  

• Utah's added hospitals to the public-health settings where hygienists can practice without dentist supervision.
  

• Colorado broadened diagnostic, prescriptive, and anesthesia authorities as part of its Sunset Dental Practice Act reauthorization.
  

• Maine added "dental hygiene diagnosis" and removed general supervision in a 2023 reform, and proposed changes would extend independent-practice hygienists' anesthesia authority further.
  

• Legislation under review in South Carolina would expand authorized procedures in schools and public-health settings.

Why it’s happening: States are trying to solve the problem of limited access to dental services without waiting years to train more dentists. Amid a broader shortage of oral health providers, the model of every hygiene visit requiring dentist supervision is an expensive bottleneck that’s becoming politically untenable.

Why it matters: For DSOs, expanded hygienist scope has the potential to change where patients enter the system, how dentist time gets allocated, and where growth can happen outside the four walls of a traditional practice. That could include: 

• Building hygiene-led access channels: Depending on local rules, that could mean standalone hygiene facilities to community preventive programs to mobile care.
  

• Free dentists for higher-value work: If hygienists can independently handle more tasks, dentists can focus their time on higher-value jobs with better margins.
  

• Grow in underserved markets with lower fixed costs: Traditional de novo growth requires heavy dentist recruitment, buildout costs, local marketing, and payer contracting. Hygiene-led outreach can test demand before committing to a full clinic.
  

• Stand out as an employer for hygienists: Hygienists who want more responsibility, professional growth, flexible settings, or community-based care may prefer DSOs that offer advanced pathways.
  

• Gain a competitive edge at scale: More autonomy also means more complexity when it comes to regulations and compliance. While smaller practices may struggle to operationalize the rules, DSOs can use this as a competitive strength.

Yes, but: An expanded scope of practice for hygienists also raises the price of talent in an environment where 40% of practices don’t have enough hygienists and 90% say it’s “very” or “extremely” challenging to hire for those roles.

• Amid a shortage, more autonomy will mean higher wages and more options—including, in some states, the ability to start independent practices focused on in-scope treatments.

Bottom line: Hygienist autonomy can unlock new access and revenue models, but it also makes hygienists more powerful in the labor market. More than ever, hygienists will need to be recruited, developed, retained, and paid like providers with true leverage—because they have it.