Colorado’s rules are mid-transition: SB 25-194 took effect August 6, 2025, and the Dental Board’s amended rules phase in through January 1, 2027, with further rulemaking under way. Check the legislation tracker for pending changes.
1. CPOD status
Tier: Strict. Three provisions work together. C.R.S. § 12-220-303(1)(a) states: “Only a dentist licensed to practice dentistry in this state pursuant to this article 220 may be the proprietor of a dental practice in this state.” Section 12-220-305(1)(b) provides that a person practices dentistry by serving as “a proprietor of a place where dental operation, oral surgery, or dental diagnostic or therapeutic services are performed.” Section 12-220-104(13) defines “proprietor” to include a person who employs dental licensees or assistants to operate an office, supplies dental material, equipment, or offices for compensation, or retains ownership or control of dental material, equipment, or an office and makes it available for dental use. The definition expressly excepts bona fide equipment or material sales secured by a chattel mortgage or retain-title agreement and loans of articulators. Proprietor names, license numbers, ownership percentages, and other Board-required information must be immediately and publicly available at the practice in a Board-approved format, and changes must be reflected within 30 days (§ 12-220-303(2)(a)–(c)). The statute no longer requires the information to sit specifically at the reception desk.2. Other professions
This page covers dentistry only. Medicine, optometry, veterinary practice, and other professions are governed by different statutes and boards, even within the same state. For medical-practice sources, use the MSO-PC Wiki.3. Professional entity forms
Corporate practice is prohibited (§ 12-220-304(1)) except through a professional service corporation of licensees; practice by an LLC of licensees or an LLP of licensees is also permitted (§ 12-220-304(3)), as is group practice (§ 12-220-304(2)). Hygienists may be proprietors of dental hygiene practices only (§ 12-220-303(1)(b)), not dental practices. Under § 12-220-303(1)(c)(I), a nonprofit may be proprietor if it is a community health center under 42 U.S.C. § 254b or at least 50% of its patients meet the statute’s low-income definition. A political subdivision may also be proprietor under § 12-220-303(1)(c)(II). Neither route may affect the treating licensee’s independent professional judgment (§ 12-220-303(1)(c)(III)). Also confirm before filing:- Naming rules, designator requirements, and any limits tied to licensed owners’ names; several states regulate dental trade names separately
- Board pre-approval or certificates, whether the dental board must act before (or after) the secretary of state will file
- Officer and director licensure, including states that restrict these roles as well as ownership to licensees
4. Fee structure
Rule 1.7(E)(2)(d), effective January 1, 2027, requires the DSO payment agreement not to constitute improper fee sharing under C.R.S. § 12-220-201(1)(v). The rule does not categorically prohibit a DSO from leasing real property: Rule 1.7(F) excludes a real-property owner or lessor from proprietor status if that person does not also lease or provide dental material or equipment. Combined premises-and-equipment arrangements therefore lose that regulatory safe harbor. Verify the fee and asset package as a whole with Colorado counsel. For the MSA, test whether a percentage-of-collections fee is permitted under the state’s dental, fee-splitting, referral, tax, and contract rules. Several states expressly restrict revenue-linked dental management fees, and the Aspen Dental settlements imposed related party-specific terms. Flat and cost-plus formulas are not automatic safe harbors; the services, calculation, amount, control rights, and actual payments still matter. See Fee-splitting rules and Set the management fee.5. Noncompetes
No dental-specific noncompete statute was identified for this page. Verify current Colorado law with counsel before including one. Federal noncompete policy changed substantially in 2025 and 2026. The FTC’s Non-Compete Rule was vacated, the agency dismissed its appeals in September 2025, and the rule was removed from 16 C.F.R. pt. 910 effective February 12, 2026. State law remains central. Dental enforcement resolutions in New York and California have also restricted noncompetes for the settling parties as a corporate-practice remedy. Verify the current rule, worker, agreement type, transaction context, effective date, and remedy in this state. See the legislation tracker.6. DSO-specific law and registration
Colorado does not register DSOs. It regulates their role through the proprietor rules. SB 25-194 (signed May 5, 2025, effective August 6, 2025), the Dental Practice Act sunset-continuation bill, prompted Rule 1.7 amendments adopted April 30, 2026. Effective January 1, 2027, Rule 1.7(E) defines a DSO as a provider of administrative, operational, and nonclinical business-management support. It bars a DSO from serving as proprietor and permits licensees to use its services only if the DSO does not influence professional judgment, the dentist reviews billing and can correct accounts, the dentist has immediate record access, and the payment agreement is not improper fee sharing. Licensees who practice where a DSO acts as proprietor may face discipline. The Secretary of State lists the rule filing as effective June 30, 2026, but the adopted text itself states: “The provisions of this Rule 1.7 shall take effect on January 1, 2027.” Treat January 1, 2027 as the operative date for Rule 1.7’s new ownership and DSO provisions. See Register a DSO for the states with true filing regimes.7. Death and transition
An unlicensed heir may serve as temporary proprietor for up to one year after the dentist’s death, extendable by the board for an additional twelve months on good cause (§ 12-220-303(3)(a)(I)).8. Practical structuring notes
- Audit asset leases before January 1, 2027. A DSO may fit Rule 1.7(F) as a real-property-only landlord, but the same lessor cannot rely on that safe harbor if it also furnishes dental material or equipment.
- The ownership disclosure (§ 12-220-303(2)(a)–(c)) is straightforward and easy for regulators to check. Keep the Board-approved format available at the practice and report changes within 30 days.
- Colorado’s dental rules remain active rulemaking territory. Before closing or issuing an opinion, check both the Secretary of State eDocket and the current 3 CCR 709-1 rather than relying on a hearing draft.
9. The standing checklist
- Confirmed the permitted entity form for dentistry in this state
- Confirmed whether dental board pre-approval or a certificate is required before filing
- Confirmed whether officers and directors must be licensed dentists
- Confirmed the management fee structure is lawful here, including any restriction on revenue-linked fees
- Clinical carve-out drafted against this state’s current statutory language, including any enumerated control prohibitions
- Transfer restriction and succession documents checked against this state’s death-transition window
- Noncompete provisions checked against current state law
- DSO foreign-qualified before it has employees here
- Any DSO registration, licensure, or disclosure obligation identified and calendared
- Trade-name and advertising-disclosure rules for dental practices checked
10. Sources and where to verify
For the cases and statutes referenced above, see DSO & dental case law and the 51-jurisdiction table. For enacted and pending legislation, see the dental legislation tracker.