DC’s rules come from the Health Occupations Revision Act and Board of Dentistry regulations (17 DCMR ch. 42). Check the legislation tracker for pending changes.
1. CPOD status
Tier: Strict. The doctrine appears in the practice definition: under § 3-1201.02(5)(J), a lay proprietor of a dental business is practicing dentistry without a license. The entity exception at (5)(J)(vi) reaches only “[p]artnerships, professional corporations, or professional limited liability companies solely consisting of and operated by dentists licensed under this chapter.” It does not allow minority lay or allied-professional ownership. The proprietorship clause and its exceptions came in with the 2009 amendments to the Health Occupations Revision Act. Unlicensed-practice prohibitions and penalties appear in D.C. Code § 3-1210.01 et seq.; verify the pinpoints with counsel.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
Permitted forms: partnerships, professional corporations, or PLLCs solely consisting of and operated by DC-licensed dentists (§ 3-1201.02(5)(J)(vi)). Professional corporations are organized under D.C. Code Title 29, ch. 5; verify the chapter citation with counsel. Hygienists and physicians: no ownership pathway appears in the dentist-only exception at (5)(J)(vi). The other exceptions to the proprietorship rule, § 3-1201.02(5)(J)(i)–(ix), cover federal and DC government agencies; CODA-accredited dental, hygiene, and assisting schools in educational settings; FQHCs; nonprofit community-based organizations using a majority of public funds to serve indigent persons; DOH-licensed hospitals; dentist-only entities; the death windows described below; and a one-year grandfather keyed to July 7, 2009. 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
No DC statute or rule banning percentage management fees for dental support was located in this research. The exposure runs through the proprietorship clause: a fee-and-control package that makes the DSO the effective manager or operator of the office is the unlicensed practice of dentistry under (5)(J). Verify structure with 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 provision was identified for this page. Before including one, verify current DC law with counsel, including the general ban on noncompetes for lower-paid employees. 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
None. No DC statute or regulation registers or regulates DSOs or dental management agreements by name, and no 2023–2026 DC legislation on corporate dentistry or private equity in dental practice was identified for this page. Verify the result with counsel. The Board of Dentistry’s regulations at 17 DCMR ch. 42 address scope of practice and delegation, not management agreements. See Register a DSO for the states with filing regimes.7. Death and transition
Two one-year windows: the spouse or domestic partner of a deceased licensed dentist may operate for one year following death (§ 3-1201.02(5)(J)(vii)), and an administrator, executor, or personal representative of the estate may operate for one year following creation of the ownership interest ((5)(J)(viii)).8. Practical structuring notes
- The “solely consisting of and operated by” language requires every partner, shareholder, or member of the professional entity to be a DC-licensed dentist. Dentists must also operate the entity.
- Groups often operate across DC, Maryland, and Virginia, but each jurisdiction has a different CPOD analysis. Do not use one entity across all three without confirming the structure with counsel.
- No enforcement authority specific to DSO structures was located for this page. Draft to the statutory text rather than assumed practice, and verify the enforcement posture with counsel.
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.