The 2025 CPOM debate considered but did not adopt dental coverage. Use the legislation tracker to watch for later bills extending SB 951 concepts to other professions in the 2026–2027 sessions.
1. CPOD status
Tier: Strict- ORS 679.020(2) is a standalone ownership prohibition, not a definitional net: only a licensed dentist may own, operate, conduct, or maintain a dental practice, office, or clinic.
- ORS 679.020(3) excepts labor organizations, universities and accredited institutions, local governments, and certain nonprofits; excepted entities must generally name an actively licensed dentist as dental director (ORS 679.020(4)(a), with limited exceptions in ORS 679.022).
- ORS 679.020(6) preserves a real DSO lane: a nonlicensee may own or lease practice assets other than clinical dental records, employ or contract with personnel other than licensed dentists, and manage nonclinical business aspects. It is an express support safe harbor, bounded by subsection (2)‘s ownership/operation prohibition.
- The definition of “dentistry” is clinical (ORS 679.010(9)(a)); the licensure requirement is ORS 679.025(1). The Oregon Board of Dentistry enforces § 679.020.
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: Oregon professional corporations under ORS ch. 58, or PCs and LLCs consistent with § 679.020(2)‘s dentist-ownership rule. SB 951’s new PC-governance rules (amendments in the ORS ch. 58 range) apply to medical, not dental, PCs. Ownership: Dentist-only, per ORS 679.020(2), subject to the § 679.020(3) exceptions. 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-splitting and management-fee structure
No express percentage-fee statute for dentistry was located in ORS ch. 679. The ownership statute supplies the relevant control rule. A fee arrangement that gives the DSO the economics and control of an owner in substance may conflict with § 679.020(2)‘s “operate, conduct or maintain” language. Verify the fee 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. Dentist noncompetes
SB 951’s noncompete and governance restrictions target medical licensees and do not cover dentists; dentist noncompetes run on Oregon’s general employment-law limits on noncompetition agreements. Verify current 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
No dental registration regime; SB 951 (2025) does not apply under its current definitions. The corporate-practice statute signed June 9, 2025 applies to “medical entities” and “medical licensees,” defined to include physicians, physician associates, nurse practitioners, and naturopathic physicians. Dentists are outside those definitions. The compliance dates of January 1, 2026 for newer MSOs and January 1, 2029 for preexisting MSOs therefore apply to medical MSOs, not DSOs. Dental management relationships remain governed by ORS ch. 679. Verify the enrolled-bill section numbers with counsel before quoting SB 951. For the states that do require DSO registration, see Register a DSO.7. Death and transition window
ORS 679.020(7) supplies a transition rule when all dentist ownership interests are held by an administrator, executor, personal representative, guardian, conservator, or receiver. The fiduciary may retain the interest for 12 months; the Board shall extend that period for another 12 months on 30 days’ notice and may grant further extensions on reasonable request. This is temporary ownership authority, not permission for the fiduciary to render care. See Plan for succession.8. Practical structuring notes
SB 951 commentary generally describes the medical statute, not Oregon dental law. Dental groups remain subject to ORS 679.020(2)‘s ownership rule. In a friendly-PC structure, the licensed dentist owns the practice entity and the DSO provides support at fair market value without operating or maintaining the clinic in substance. The reviewed statute provides lay-ownership exceptions for specified nonprofits with a dental director. Because the 2025 session considered extending coverage to dentistry, recheck the law before each new clinic or acquisition.9. Verification 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.