RD883 - Report Regarding Credentialing of Dentists and Dental Hygienists and Pathways for Internationally Trained Dentists to Practice Dental Hygiene in the Commonwealth – November 24, 2025


Executive Summary:

Pursuant to SB1475, passed during the 2025 General Assembly Session, the Board of Dentistry convened a workgroup which met on August 22, 2025.(*1) The workgroup reviewed and discussed the topics included in SB1475, which were as follows:

1. Licensure by credentialing(*2) statutes governing dentists and the licensure statutes governing dental hygienists, including recommendations on how such statutes can be updated to reflect an expedited pathway for licensure; and

2. Options for and recommendations on a pathway for qualified internationally trained dentists to practice dental hygiene under the supervision of a licensed dentist.

A. Licensure by credentials

The workgroup found that current licensure by credential requirements for dentists in Virginia are generally comparable with most United States jurisdictions. The workgroup reviewed information that the number of dentists in Virginia has remained stable and that the number of licensees planning to retire in the next 10 years has likewise remained stable. The workgroup did not reach consensus on recommendations for changes in active practice requirements for licensure of dentists by credentials pursuant to Virginia Code § 54.1-2709(C).

The workgroup did not reach a consensus regarding potential changes to the existing licensure by credentials requirements for dental hygienists. Licensed dental hygienist workgroup members requested that the workgroup make a recommendation to remove existing active practice requirements found in 18VAC60-25-150 for licensure by credentials as a dental hygienist. That regulation requires an applicant to submit evidence of active clinical practice for 24 of the 48 months preceding the application for licensure. The remaining workgroup members did not support a recommendation to change the active practice requirements for licensure by credentials.

B. Pathway for internationally trained dentists to practice as licensed dental hygienists

The workgroup did not reach a consensus regarding a potential pathway for internationally trained dentists to work as licensed dental hygienistsin Virginia. Workgroup members representing licensed dental hygienists opposed the creation of a pathway for internationally trained dentists that did not require training as a dental hygienist in a program accredited by the Commission on Dental Accreditation (“CODA"). These workgroup members suggested a recommendation that mirrored the current pathway for any applicant seeking licensure as a dental hygienist. Licensed dentist and dental association representative workgroup members suggested pathways that may include some or all of the following:

• Passage of the national exam and/or regional clinical examinations;
• Evaluation of education received from international schools through an evaluation service such as World Education Services, Educational Credential Evaluators, or National Association of Credential Evaluation Services;
• Provision of proof of licensure and work history;
• Passage of an English proficiency exam such as the Test of English as a Foreign Language (“TOEFL") or the International English Language Testing System (“IELTS"); and
• Passage of a refresher course program.

Because the workgroup could not reach consensus, the workgroup did not recommend a potential pathway for licensure of internationally trained dentists as dental hygienists.

C. Impact on the Dental and Dental Hygienists Compact

Finally, the workgroup examined the requirements of the Dental and Dental Hygienists Compact (“DDH Compact"), of which Virginia is a member state. The DDH Compact contains no active practice requirements and no clinical examination requirements for dentists or dental hygienists. The DDH Compact does require graduation from a CODA-accredited educational program. Therefore, Virginia’s participation in the DDH Compact would not be affected by any alteration of active practice requirements for licensure by credentials or implementation of a pathway for internationally trained dentists to work as licensed dental hygienists.

Workgroup Members

Sultan E. Chaudhry, D.D.S., Chair
President
Virginia Board of Dentistry

Marge Green
Licensed Dental Hygienist Representative
Virginia Dental Hygiene Association

Alf Hendricksen, D.D.S.
Vice-President
Virginia Board of Dentistry

Emelia McLennan,
Licensed Dental Hygienist
Virginia Board of Dentistry

Benjamin H. Traynham, Esq.
Representative
Virginia Dental Association

Staff Participants

Erin L. Barrett
Director of Legislative and Regulatory Affairs
Department of Health Professions

Arne Owens
Agency Director
Department of Health Professions

Jamie C. Sacksteder
Executive Director
Virginia Board of Dentistry

Erin T. Weaver
Deputy Executive Director
Virginia Board of Dentistry
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(*1) The agenda for the workgroup contained information regarding the topics the workgroup discussed. The agenda may be found at: https://townhall.virginia.gov/L/GetFile.cfm?File=Meeting\21\40631\Agenda_DHP_40631_v1.pdf. The agenda is referenced hereinafter as “Workgroup Agenda."
(*2) Dentistry, as a profession, refers to licensure by endorsement as “licensure by credentials." This report refers to licensure by credentials consistent with that usage. Reciprocity is a separate licensing mechanism in which an applicant is granted a license to practice in a state based solely on holding another state license to practice in the same profession.