Why the Dental Compact Is Not Issuing Privileges Yet

The Dentist and Dental Hygienist Compact is law in 13 states, and it has been in effect since April 22, 2024. Yet the Council of State Governments (CSG) still says plainly that "compact privileges are not yet being issued." No dentist or hygienist has been able to apply for one.

That gap is not a mystery. The Commission that runs the compact publishes its agendas and minutes, and they show where the work stands: a data system that needs money, a central definition that commissioners still disagree about, and a lawsuit from Virginia dentists. Here is what the public record shows as of October 2026.

What did CSG originally expect?

CSG's implementation timeline, written when the seventh state enacted the compact, set out the steps in order. The Commission would form in summer 2024 and hold its first meeting that fall. Through 2025 it would acquire a data system, which CSG said "is expected" to take 10 to 12 months, write rules, approve a fee structure and hire staff. Then states would onboard, each on its own timeline, and only then would applications open.

The same document said the compact "will not be fully operational for an estimated 18-24 months." Counting from April 2024, that pointed to sometime between October 2025 and April 2026. The compact's home page still carries the same 18 to 24 month language today.

Is the data system built?

No. The data system is how member boards would see who holds a license, who holds a privilege and who has been disciplined. CSG calls it "a foundational piece of compact operations."

The record shows slow progress. The Commission issued a Request for Information in March 2025, with responses due May 5, 2025. At its November 10, 2025 meeting, the Commission reviewed proposals from two vendors, Inspiring Apps and So Company, and voted to move forward with Inspiring Apps. The motion was amended to add a "caveat clarifying securing funding," after Virginia's commissioner raised concern about "moving forward with RFP without funding."

Two months later, the January 12, 2026 minutes record the Finance Committee's report that "an additional $96,000 would be needed, plus additional funds up to point of licensing fees." The same minutes note a fundraising letter asking the ADA for funding and that CSG had "approached the DoW for additional funding." No later minutes posted on the compact site report that the money was secured or the contract signed.

Why does the "clinical assessment" rule matter so much?

To get a privilege, the model law requires that a dentist or hygienist "successfully completed a Clinical Assessment for licensure." States reach that standard in very different ways. Some rely on a hands-on exam such as ADEX. New York requires a residency. Ohio's statute accepts a CODA-accredited residency in place of a clinical exam. The compact FAQ itself lists "hands-based skills assessments, the DLOSCE, and PGY-1 dental residency programs" as pathways states accept.

The Commission's draft Rule 1.2 would read the requirement broadly: "any examination or process recognized or accepted by a Participating State as providing evidence of clinical competence." It names psychomotor exams, objective structured clinical exams, "dental residency experience," and "a portfolio-based assessment of clinical competence."

That breadth is the dispute. In January 2026 a public commenter identified in the minutes as chair of a licensure committee spoke against the draft. At the May 18, 2026 meeting, Minnesota's new commissioner said "a hands-on assessment should be included, as it is integral to the profession," and Iowa's commissioner agreed. Ohio's commissioner noted that Ohio "allows licensure without the psychomotor exam, but would require a one-year residency." Legal counsel explained that the rule keeps the Commission from second-guessing which assessments each board uses. Three public commenters spoke in favor of the draft; two others asked for changes, one of them for a hands-on requirement.

The Commission voted to send the rule to a public hearing, which its meeting page lists for June 26, 2026. As of October 2026, the minutes for that hearing still read "Coming Soon," and the August 10, 2026 meeting is marked canceled. No later meeting is listed.

What about the fee and the application?

Neither exists. The compact FAQ says the member states "will set up the fee structure through rules." The rulemaking page lists the clinical assessment draft and nothing on fees. The FAQ's description of the application process is still in the future tense: "The commission will also set up a data system and an application process. Once this is established, practitioners will be able to apply."

How does the Virginia lawsuit fit in?

On June 11, 2024, three Virginia dentists filed suit against the Virginia Board of Dentistry challenging the state's implementation of the compact, according to CSG's news page. The court dismissed the case on December 5, 2024. CSG reported that all plaintiffs filed an appeal on December 30, 2024. CSG has not posted an outcome, and we have not found one in a primary source.

When will privileges actually start?

Nobody has said, and we will not guess. The honest reading of the record is that four things have to happen first: funding for the data system, a signed contract and build, a final clinical assessment rule, and state onboarding. CSG's own estimate for the data system alone was 10 to 12 months once work begins.

Any site promising a launch date, or selling "compact privileges," is selling something the Commission has not created. CSG's FAQ notes that a privilege fee is "typically less than the fee for a license" in other compacts, which is one more reason to be skeptical of anyone charging for compact access now.

Which way should you go in the meantime?

If you need to practice in another state within the next year, apply for a license there. That is true for member states and for everyone else. The routes are well established:

• Licensure by credentials, for dentists with several years of recent practice. See dental license by credentials and years-of-practice rules.
• Licensure by exam, for newer dentists, through ADEX or another exam the state accepts. See ADEX and which clinical exams each state accepts.
• Hygienist licenses by credentials, covered in hygienist license by credentials.

Our Dentist License by Credentials service is $799 per state and our Dental Hygienist License service is $449 per state. We prepare every document, a question-by-question guide, the verifications and the scheduling, and we track the file to approval. You complete, sign and submit the application and pay the board directly. We offer no compact product and will not until the Commission does. The dental compact hub tracks each development.