HOUSE OF REPRESENTATIVES STAFF ANALYSIS
BILL #: HB 547 Dentistry
SPONSOR(S): Altman
TIED BILLS: IDEN./SIM. BILLS:
REFERENCE ACTION ANALYST STAFF DIRECTOR or
BUDGET/POLICY CHIEF
1) Healthcare Regulation Subcommittee 16 Y, 0 N Osborne McElroy
2) Health Care Appropriations Subcommittee 15 Y, 0 N Aderibigbe Clark
3) Health & Human Services Committee 17 Y, 0 N Osborne Calamas
SUMMARY ANALYSIS
The Board of Dentistry (BOD), within the Department of Health (DOH), regulates dental practice in Florida,
including dentists, dental hygienists, and dental assistants licensed under the Dental Practice Act. A dentist is
licensed to examine, diagnose, treat, and care for conditions within the human oral cavity and its adjacent
tissues and structures. There are currently 17,193 dentists with active licenses to practice in Florida.
Prior to October 2011, the dental licensure examination was developed and administered by the Board and the
Department of Health. As of October 1, 2011, Florida stopped administering its own practical and clinical dental
examinations, and the American Dental License Examination (ADEX), developed by the American Board of
Dental Examiners, Inc., replaced the Florida Diagnostic Skills Examination as Florida’s dental licensure exam.
The ADEX is administered by the CDCA-WREB-CITA© (CDCA).
Current law includes requirements which are now obsolete as Florida no longer develops or administers its
own dental licensure exam. Current law also specifies that a passing score on the ADEX is only valid for 365
days after the date that the results were published.
Current law requires all applicants for dental licensure who relocate to Florida and apply for dental licensure
with ADEX scores obtained in a different state engage in full-time practice during their first year of licensure
within the geographical bounds of Florida.
HB 547 significantly revises the dental licensure requirements relating to the dental licensure exam. The bill
deletes language which has been made obsolete through the use of a national licensure exam.
The bill also deletes the provision making ADEX scores valid for only 365 days after the scores were
published. The bill revises experience requirements for licensure for dentists who have active, valid licensure in
another United States jurisdiction. The bill deletes the requirement that out-of-state licensed dentists engage in
full-time practice during their first year of licensure within the geographical bounds of Florida.
The bill has an insignificant, negative fiscal impact on DOH, and no fiscal impact on local government.
The bill provides an effective date of July 1, 2024.
This docum ent does not reflect the intent or official position of the bill sponsor or House of Representatives .
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DATE: 2/22/2024
FULL ANALYSIS
I. SUBSTANTIVE ANALYSIS
A. EFFECT OF PROPOSED CHANGES:
Background
Regulation of Dental Practice in Florida
The Board of Dentistry (BOD), within the Department of Health (DOH), regulates dental practice in
Florida, including dentists, dental hygienists, and dental assistants who are licensed under the Dental
Practice Act.1 A dentist is licensed to examine, diagnose, treat, and care for conditions within the
human oral cavity and its adjacent tissues and structures. 2
There are currently 17,193 dentists with active licenses to practice in Florida. There are 41 out-of-state
registered telehealth dentists.3
Dental Licensure
Any person wishing to practice dentistry in this state must meet specific education and examination
requirements and apply to DOH for licensure. The applicant must submit two recent photographs with
their application and verify the accuracy of their application by oath. 4
To be eligible for dental licensure, an applicant must apply to the DOH to take and pass the following
examinations:5
The American Dental License Examination (ADEX); and
An examination on Florida laws and rules relating to dentistry.
The American Dental License Examination (ADEX)
Prior to October 2011, the dental licensure examination was developed and administered by the Board
and the Department of Health. As of October 1, 2011, Florida stopped administering its own practical
and clinical dental examinations, and the American Dental License Examination (ADEX), developed by
the American Board of Dental Examiners, Inc., replaced the Florida Diagnostic Skills Examination as
Florida’s dental licensure exam.6 The ADEX is inclusive of a comprehensive diagnostic skills
examination covering the full scope of the practice of dentistry. 7 The ADEX is administered by the
CDCA-WREB-CITA© (CDCA).8
The ADEX is administered by the CDCA in two formats: the Curriculum Integrated Format (CIF) and
the Traditional Format. The CIF is administered throughout the candidate’s third and fourth year of
dental school. The Traditional Format is administered during the candidate’s fourth year. Due to this
type of administration, dental students complete the ADEX prior to applying for licensure.9 The ADEX
examination fee is $2,795.0010 and is paid directly to the CDCA by the applicant.11 Current law requires
1 S. 466.004, F.S.
2 S. 466.003(3), F.S.
3 See, Department of Health, License Verification web search. Available at https://mqa-
internet.doh.state.fl.us/MQASearchServices/HealthCareProviders (last visited January 14, 2023).
4 S. 466.006(1)(b), F.S.
5 S. 466.006, F.S.
6 Department of Health, Agency Bill Analysis for HB 547 (2024). On file with the Health & Human Services Committee.
7 Rule 64B5-2.013, F.A.C.
8 Supra, note 6.
9 Id.
10 CDCA, ADEX Dental: Examination Overview. Available at https://adextesting.org/adex-dental/ (last visited January 31, 2024).
11 Supra, note 6.
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DOH to consult with the BOD in planning the times, places, physical facilities, training of personnel, and
other arrangements concerning the administration on the examination. 12
To take the ADEX clinical examination for dentists, an applicant must be at least 18 years of age and:
Be a graduate of a dental school accredited by the American Dental Association (ADA)
Commission on Dental Accreditation (CODA) or its successor entity, if any, or any other dental
accrediting entity recognized by the US Department of Education;
Be a dental student in the final year of a program at an ADA-CODA accredited dental school
who has completed all the coursework necessary to prepare the student to perform the clinical
and diagnostic procedures required to pass the examinations. A passing score on the
examination is valid for 365 days;13 and
Have completed Part I and II of the National Board Dental Examination (NBDE), administered
by the Joint Commission on National Dental Examinations (JCNDE); 14 or
Have an active health access dental license in this state; and
o The applicant has 5,000 hours within four consecutive years of clinical practice
experience providing direct patient care in a health access setting; the applicant is a
retired veteran dentist of any branch of the US Armed Services who has practiced
dentistry while on active duty and has at least 3,000 hours within three consecutive
years of clinical practice experience providing direct patient care in a health access
setting, or the applicant has provided a portion of his or her salaried time teaching health
profession students in any public education setting and has at least 3,000 hours within
three consecutive years of clinical practice experience providing direct patient care in a
health access setting; and
o The applicant has not been disciplined by the BOD, except for citation offenses or minor
violations;
o No claim or action for damages for personal injury alleged to have been caused by error,
omission, or negligence in the performance of the licensee’s professional services has
been reported to the Office of Insurance Regulation; and
o The applicant has not been convicted of or pled nolo contendere to, regardless of
adjudication, any felony or misdemeanor related to the practice of a health care
profession.
A person who has graduated from a dental school that is not accredited by the ADA-CODA, a US
Department of Education-recognized dental accrediting entity, or otherwise approved by the BOD, may
only sit for the ADEX after they submit proof of the following to the BOD: 15
At least two consecutive academic years at a full-time supplemental general dentistry program
accredited by the American Dental Association Commission on Dental Accreditation. This
program must provide didactic and clinical education at the level of a D.D.S. or D.M.D. program
accredited by the ADA-CODA; and
Successful completion of Part I and II of the National Board Dental Examination (NBDE),
administered by the Joint Commission on National Dental Examinations (JCNDE).
The BOD will then confirm an applicant’s eligibility and notify the CDCA.16
Current law specifies that a passing score on the ADEX is only valid for 365 days after the date that the
results were published.17 This provision presents issues for some licensure applicants who completed
dental school and passed the ADEX in Florida, but choose to pursue residency without first obtaining a
12 S. 466.006(5), F.S.
13 S. 466.006(4), F.S.
14 American Dental Association, Joint Commission on National Dental Examinations, Upholding Quality Oral Care For All. Available at
https://jcnde.ada.org/ (last visited January 31, 2024).
15 Florida Board of Dentistry, Dentist – Process. Available at https://floridasdentistry.gov/licensing/dentist/#tab-process (last visited
January 31, 2024).
16 Id.
17 S. 466.006(4), F.S.
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Florida dental license. A licensure applicant who graduated from an accredited Florida dental school
may have passed the ADEX and then leave the state to complete a residency without first obtaining a
Florida dental license. Upon returning to Florida, such person’s ADEX scores will be invalid due to the
length of time that has passed and the person will be required to take and pass the ADEX again to be
eligible for licensure in Florida.18
The results of the ADEX administered out-of-state are valid for Florida licensure, however, such exam
scores are also only valid for 365 days after the date that the results were published. A licensure
applicant who passed the ADEX in another state more than 365 days prior is still eligible for licensure,
but must meet the following additional requirements:19
Confirmation that the applicant completed the ADEX examination after October 1, 2011.
Graduation from a dental school accredited by the American Dental Association Commission on
Dental Accreditation or its successor entity, if any, or any other dental accrediting organization
recognized by the United States Department of Education. If the applicant did not graduate from
such a dental school, the applicant may submit proof of having successfully completed a full-
time supplemental general dentistry program accredited by the American Dental Association
Commission on Dental Accreditation of at least two consecutive academic years at such
accredited institution.
Verification that the applicant currently possesses a valid and active dental license in good
standing, with no restriction, which has never been revoked, suspended, restricted, or otherwise
disciplined, from another state or territory.
Submission of proof that the applicant has never been reported to the National Practitioner Data
Bank (NPDB), the Healthcare Integrity and Protection Data Bank, or the American Association
of Dental Boards Clearinghouse, unless successfully appealed.
Submission of proof that the applicant has been consecutively engaged in the full-time20
practice of dentistry in another state or territory in the five years, or since the date of initial
licensure if less than five years, immediately preceding the date of application for licensure.
In Fiscal Year 2022-2023, 175 applicants applied for dental licensure in Florida with ADEX scores
issued in another state and older than 365 days. Of the 175 applicants, 127 met the additional
requirements to become licensed in Florida.21
All applicants for dental licensure who apply for dental licensure with ADEX scores obtained in a
different state must engage in full-time practice during their first year of licensure within the
geographical bounds of Florida. Full-time practice is defined as 1,200 hours. Thirty days prior to the
expiration of license, the BOD is required to notify the licensee of the need to comply with the full-time
practice requirement. If the BOD does not receive a response, the licensee must be served with a
notice of pending expiration and be given 20 days to submit proof of full-time practice. If no response is
received or the licensee if unable to prove full time practice, the BOD will enter an administrative order
to expire the license.22
Continuing Education
Licensed dentists are required to complete at least 30 hours of continuing education (CE) in dental
subjects biennially, as a condition of their licensure renewal. A minimum of two hours of CE must be on
18 Supra, note 6.
19 S. 466.006(4)(b), F.S.
20 See, S. 466.006(4)(b)2., F.S.; Full-time practice is defined as a minimum of 1,200 hours per year for each year in the consecutive 5 -
year period or since initial licensure, and must include any combination of the following active clinical practice of dentistry providing
direct patient care, full-time practice as a faculty member employed by an accredited dental or dental hygiene school, or full-time
practice as a student at an accredited postgraduate dental education program.
21 Supra, note 6.
22 S. 466.006(6), F.S.
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the safe and effective prescribing of controlled substances. The remaining CE courses must contribute
directly to the dental education of the dentist and may include attendance at lectures, study clubs,
college postgraduate courses, or scientific sessions of conventions; and research, graduate study,
teaching, or service as a clinician. The BOD may authorize up to three hours of CE biennially for a
practice management course that includes principles of ethical practice management, provides
substance abuse, effective communication with patients, time management, and burnout prevention
instruction.23
Effect of the Bill
HB 547 removes the BOD and DOH from the dental licensure examination administration process. The
bill deletes language made obsolete due to the administration of the ADEX by CDCA and codifies the
current examination process by eliminating the following requirements:
Applicants must apply to DOH to sit for the ADEX, and reapply to retake the exam;
Applicants must submit two photographs to DOH;
The BOD must set the examination and reexamination fees.
DOH must consult with the Board of Dentistry in planning all arrangements concerning the
administration of the examination; and
DOH must conduct a mandatory standardization exercise for all examiners.
Under the bill, an applicant who has passed the ADEX will be eligible for dental licensure upon applying
to DOH and demonstrating that the applicant is at least 18 years of age and:
A graduate of an accredited dental school;
Has successfully completed the examination administered by the JCNDE (the NBDE); and
Has successfully completed the laws and rules examination.
The bill deletes the provision that ADEX scores are only valid for 365 days.
The bill removes language related to an obsolete licensure pathway for full licensure for a Health
Access Dentist which does not include passage of the examination of the NBDE. This language is
inconsistent with s. 466.0067(6), F.S., which requires all applicants for a Health Access Dental license
to have passed the examination of the NBDE.
The bill revises the requirements for an out-of-state applicant to prove their full-time practi