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SB25-194 Rule Making Timeline

Posted by [email protected] on Aug. 12, 2025  /  Licensure, Advocacy/Legislation  /  Subscribe 0

SB25-194 Is Now Law—But What Does That Mean for Colorado Dental Hygienists Right Now?

On August 6, 2025, the updated Colorado Dental Practice Act (SB25-194) officially went into effect—continuing the Act through 2034 and bringing many exciting scope of practice updates for Registered Dental Hygienists (RDHs).

However, here’s the key takeaway for RDHs: many of the new provisions cannot be put into practice yet. Why? Because the law requires the Colorado Dental Board to first promulgate rules—formal regulations that define education, training, delegation, and other requirements before these changes can be implemented.

Until those rules are adopted, RDHs must continue practicing under the current Dental Board Rules and Regulations.

Why Rules Are Required

SB25-194 adds new authorities for RDHs—such as expanded prescribing options, immunizations, and neuromodulators—but also directs the Dental Board to set the parameters for how these procedures can be performed safely and consistently statewide.

Rulemaking ensures there are clear guidelines on:

• Education & training requirements

• Delegation protocols

• Recordkeeping and competency standards

• Approved medications and materials

Provisions Waiting on Rule Making

Here are key RDH-related updates in SB25-194 that require Board-adopted rules before they can take effect:

• Analgesia, nitrous oxide, sedation-related tasks – must align with Board rules, including training requirements to administer nitrous oxide under indirect supervision (RDH can continue to administer nitrous oxide under direct supervision). (12-220-305)

• Immunizations – rules will define delegation from dentists or other licensed professionals, patient age limits, and minimum training standards. (12-220-305, 12-220-504)

• Neuromodulators & dermal fillers – rules needed for training, ongoing competency, recordkeeping, and delegation. (12-220-305, 12-220-504)

• Expanded prescribing authority – nonnarcotic analgesics, anti-inflammatories, and antibiotics all require completion of Board-approved rules and additional education requirements established. (12-220-503)

What This Means for RDHs Today

While the law is in effect, you cannot begin performing any of the new tasks that require Board rulemaking until those rules are finalized and in place. This process often includes:

1. Draft rules prepared by the Board.

2. Stakeholder meetings and opportunities for public comment.

3. Formal adoption of final rules, followed by an implementation date.

How to Stay Informed

CODHA will track the rulemaking process closely and share updates as soon as the Board schedules discussions or releases draft rules.

You can also monitor progress directly:

• Colorado Dental Board – Sunset Dental Practice Act page

Bottom line: SB25-194 has set the stage for exciting growth in Colorado RDH practice—but implementation will come in phases, starting with Board rulemaking. Until then, keep practicing within your current scope, and stay tuned for updates on when these new authorities will officially be available to you.

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