What Changed in 2025-2026

Purpose

Collect the freshness-sensitive rule changes and stale-prep traps most likely to cause wrong answers on the California Dental Law & Ethics exam. Every entry names what changed, when it took effect, what old prep says, and what the current answer is. If your preparation materials predate the effective dates listed here, re-memorize these entries to ensure compliance with current regulations.

2025 Changes To Know

All of these changes originate from Senate Bill 1453 (Ashby, Ch. 483, Stats. 2024), effective January 1, 2025—currently the single biggest source of stale preparation materials.

• Sedation permits were renamed: The current permit categories are GA (General Anesthesia), MGA (Medical General Anesthesia, for physicians providing GA in a dental office), MS (Moderate Sedation), PMS (Pediatric Minimal Sedation—never "Pediatric Moderate Sedation"), and OCS-A (Oral Conscious Sedation – Adult).¹ Old prep teaches the retired "Conscious Sedation" permit; the current answer uses the new names. Note, however, that the phrase "conscious sedation" still appears in some statutes (such as BPC §1680(z)'s 7-day adverse event reporting rule), so do not automatically reject an answer choice simply for containing it.²
• Physical presence became explicit: The dentist who administers or orders moderate sedation, deep sedation, or general anesthesia must be physically present in the treatment facility the entire time the patient is sedated, and a dentist applying for or renewing a GA permit must hold current ACLS.¹ Old prep treats "available nearby" as sufficient; the current answer is physical presence in the facility, full stop.
• The duty table's C and DD supervision codes were deleted: The Board replaced its Table of Permitted Duties with the "Table of Dental Auxiliary Duties Delegable by Supervising Dentist," effective January 1, 2025 (approved at the November 7–8, 2024 Board meeting). The old table's C code (dentist, RDH, or RDHAP may supervise) and DD code (dentist's discretion between general and direct) are gone; the current legend is CR / D / G only.³ Old prep — and the CDA's older member chart — still teaches C/DD as current codes.⁴ The current answer: only Direct and General supervision levels exist (BPC §1741), and the dentist's discretion rule lives in BPC §1752.4(c)–(d), with §1777 as the exception.⁵
• The Licensure by Portfolio pathway was repealed: Following a Department of Consumer Affairs (DCA) Office of Professional Examination Services psychometric review, SB 1453 removed the portfolio route from the Dental Practice Act.⁶ Old study guides list portfolio as a fifth pathway; the current answer is that no candidate can pursue California dentist licensure through a portfolio.
• DA infection-control timing changed: Unlicensed dental assistants must complete the Board-approved 8-hour infection-control course—consisting of at least 4 hours didactic, 2 hours laboratory/preclinical, and 2 hours clinical instruction (16 CCR §1070.6)—before performing any basic supportive procedures that involve potential exposure to blood or saliva.^{7 8} Old prep allowed a one-year grace period; the current answer is that there is no grace period at all.
• The old general EF auxiliary cap was repealed: Former BPC §1753.7's three-EF rule is gone.¹ BPC §1684.5(d)'s separate total-five concurrent-supervision limit remains for specified RDAEFs, RDHs, and RDHAPs providing cross-referenced services; do not restate it as a generic chairside cap or as textually “telehealth-only.”²
• Coronal polishing opened to DAs: Under BPC §1750(f)(4), an unlicensed DA may perform coronal polishing after completing a Board-approved course (with the 8-hour infection control course and current BLS as prerequisites), under direct supervision only.^{7 3} Old prep treats this as an RDA-only duty.
• License display replaced name posting: SB 1453 amended BPC §1700. Offices must display the actual license, permit, or registration of each person practicing dentistry where patients can easily see it (failure is a misdemeanor).⁹ Old prep says "conspicuously post the names of all employees"; that rule has been repealed.
• OA/RDA experience barriers were repealed: Old prep requiring months of DA work experience before qualifying for the OA/RDA pathways is stale; SB 1453 removed those barriers to entry.¹
• Use the current Board duties table: Always answer auxiliary-scope questions using the Dental Board of California's Table of Permitted Dental Auxiliary Duties, updated effective January 1, 2025.³ Do not rely on older screenshots or pre-2025 role charts.

2026 Changes To Know

• Breach notice got a hard deadline (SB 446, effective 1/1/2026): Civil Code §1798.82 now requires notice to affected California residents no later than 30 calendar days after discovering a breach, plus a sample notice to the Attorney General within 15 calendar days of notifying individuals if more than 500 residents are affected.¹⁰ Old prep says "without unreasonable delay"; that standard is a stale-prep trap.
• MICRA caps keep rising (AB 35, replacing the flat cap since 2023): For 2026, noneconomic damages are capped at approximately $470,000 (non-death) and $650,000 (wrongful death), stackable up to 3 times across unaffiliated defendants, and rising annually toward $750K/$1M plateaus.¹¹ Old prep's flat $250,000 answer is obsolete.
• Private equity clinical control is banned (SB 351, HSC §1191, effective 1/1/2026): Private equity groups and hedge funds may not dictate diagnostic tests, referrals, patient quotas, treatment options, or coding/billing, nor can they own patient records.¹² Their non-compete and non-disparagement clauses are void. Precision point: MSOs are not named in §1191—old summaries stating "SB 351 bans MSOs" overstate the law; a PE-backed MSO is reached only through its controlling investors.
• MSOs answer to AB 1415 instead (effective 1/1/2026): MSOs, private equity groups, and hedge funds are OHCA "noticing entities" that must give the Office of Health Care Affordability written notice at least 90 days before material transactions.¹³
• CURES reporting carve-out (AB 82, effective 1/1/2026): Prescribers and dispensers are prohibited from reporting testosterone or mifepristone prescriptions to CURES (HSC §11165(k)).¹⁴ Old prep treats all controlled-substance dispensing as reportable.
• Medi-Cal coverage change (AB 116, effective 7/1/2026): State-funded full-scope Medi-Cal dental benefits end for undocumented adults age 19 and older, leaving only restricted-scope emergency coverage for that population.¹⁵

Current Official Guidance Worth Re-Memorizing

These rules are not newly passed 2025-2026 bills, but older preparation materials routinely omit or misstate them—re-verify each against the dates and citations shown.

• The passing standard is criterion-referenced, not 75% (16 CCR §1031, amended effective 7/1/2022): The passing score is set per test form by the modified Angoff method.¹⁶ Prep teaching that "you need a 75% to pass" reflects the pre-July-2022 regulation and is outdated. Related format trap: The Candidate Information Bulletin publishes no fixed "75 questions / 90 minutes" for the dentist exam—that format belongs to other licensing boards.¹⁷
• Exam fees and retakes: The Board application fee is $125 (with a two-year eligibility window); each sitting—including the first attempt and every retake—carries a separate $27.23 PSI examination fee, with re-registration taking 7–10 business days after a failing result.^{17 18}
• Pediatric sedation staffing (SB 501, BPC §1647.2, operative 1/1/2022): Moderate sedation on a patient under 13 requires at least two support personnel in addition to the operating dentist.¹⁹ The dentist and at least one personnel member must hold current PALS-and-airway certification, and the dentist must hold a pediatric-endorsed MS or GA permit (a PMS permit never covers moderate sedation).
• CMIA authorizations accept e-signatures (AB 1697, effective 1/1/2024): Civil Code §56.11 validates medical release authorizations "signed, including with an electronic or handwritten signature."²⁰ Old prep implying a wet-ink signature requirement is stale; however, the 14-point-type and separate-signature formatting rules still apply.
• Record copy fees are capped (SB 815, HSC §123110(j), effective 1/1/2024): Patient-requested copies max out at $0.25 per page ($0.50 per page from microfilm).²¹
• Record retention has no universal seven-year floor: The Dental Board has said no general law sets one period for every dentist.²² HSC §123145's adult/minor periods apply only when a provider licensed under one of four listed HSC provisions ceases operation.²³ Medi-Cal's 10-year requirement is a separate program rule using the applicable later service, audit, or contract trigger.²⁴
• The §650(h) digital safe harbor exists (AB 457, effective 1/1/2022): Referral-fee prohibitions under BPC §650 do not apply to fees paid to neutral, non-endorsing internet advertising or appointment-booking platforms.²⁵ Old prep teaching that "any per-booking platform fee is an illegal kickback" is stale—but steering or endorsing a specific dentist still invalidates the safe harbor, and BPC §650.01 still flatly bans self-referral for enumerated services (no disclosure cure; only §650.02 exceptions like own-office services apply).^{26 27}
• Knox-Keene and Medi-Cal Dental are separate lanes: HSC §1373.96 uses condition-specific durations and does not automatically classify orthodontics as a serious chronic condition.²⁸ For specified Medi-Cal Dental transitions, DHCS APL 25-002 may require care—including orthodontia—beyond 12 months through completion.²⁹
• AB 2338 default surrogates: For adults lacking capacity with no advance directive or designated agent, the Probate Code framework added by AB 2338 follows specified family priorities.³⁰ The correct consent lane order is: recorded designation → agent under power of attorney → conservator → default surrogate.
• Pediatric anesthesia warning language (AB 1622, since 2019): The BPC §1682 informed consent warning tells the parent to "consult with your dentist, family physician, or pediatrician as needed"—incorporating all three professionals, not "consult a pediatrician" alone.³¹
• California is not in the dental compact: The Dentist and Dental Hygienist Compact (DDHC) has 13 member states as of mid-2026 (Oklahoma joined as the thirteenth in May 2026), but California is not a member, and no compact privileges are being issued anywhere yet.³² An out-of-state dentist treating a patient located in California needs a full California license.
• 16 CCR §1005 is under active rulemaking: The Board is amending the infection-control minimum standards, but the operative text remains unchanged since 2011.³³ Answer from the current version, and use the correct terminology: §1005 says "standard precautions," not "universal precautions."³⁴
• CURES uses current 7-day nonrefillable exemption language: The official DCA flyer uses 7-day (not the stale 5-day) wording in the emergency-department, surgical/procedural, and timely-access exception lanes.³⁵
• Good Samaritan rules are lane-specific: BPC §1627.5(a)'s outside-practice and colleague-request clauses, §1627.5(b)'s declared-emergency clause, and HSC §1799.102 have different location, compensation, training, and misconduct language. The colleague-request clause has no stated location condition. BPC §2395 protects physicians and podiatrists, not dentists.^{36 37}
• MedWatch is not one universal mandatory form: ADA §5.D.1 creates an ethical communication duty, while ordinary clinician Form 3500 reporting is voluntary. Mandatory federal reporting depends on role, setting, product, and event; CMIA permits qualifying voluntary reports; California's seven-day BPC §1680(z) rule is separate.^{38 39 40 41}
• 2025 ADA Code updates: Advisory Opinion 5.F.7 holds social-media influencer statements made on behalf of a practice to strict veracity standards.⁴¹ Updated Advisory Opinion 4.E.1 clarifies that paying an influencer a percentage of professional fees collected constitutes illegal and unethical fee-splitting.

What To Purge From Old Prep

• "You need 75% to pass" (the standard has been criterion-referenced via modified Angoff since July 2022)—and "the exam is exactly 75 questions in 90 minutes."
• "Licensure by Portfolio is a current California pathway."
• "The duties table uses C and DD supervision codes"—those codes were deleted from the official table effective 1/1/2025; the legend is now CR / D / G only.
• "California breach notice is simply prompt / without unreasonable delay."
• "DAs have a one-year grace period to get their infection-control course"—and "the 8-hour course is 6 hours didactic / 2 hours lab" (it is 4/2/2).
• "A dentist may supervise at most 2 (or 3) EF auxiliaries"—that general cap was repealed; do not erase §1684.5(d)'s distinct total-five rule for specified concurrent supervision.
• "PMS means Pediatric Moderate Sedation"—it stands for Pediatric Minimal Sedation; moderate sedation under 13 requires a pediatric-endorsed MS or GA permit plus PALS.
• "Coronal polishing is RDA-only" and "you must post all employee names on the wall."
• "The mandatory CE core is 2-2-2"—it is four core requirements: 2 DPA + 2 IC + 2 CA-Opioid + hands-on BLS.
• "BPC §1683.6 requires a written estimate over $300 or 4 visits, with re-consent at 5% variance"—no such section exists in the current Dental Practice Act; the correct duty is BPC §654.3(h)'s written plan before third-party credit.
• "MICRA is still a flat $250,000."
• "SB 351 explicitly bans MSOs."
• "All per-patient platform booking fees are kickbacks."
• "Every kickback or self-referral problem can be fixed with written disclosure"—BPC §650.01's self-referral ban for enumerated services has no disclosure cure.
• "Testosterone and mifepristone are CURES-reportable" (AB 82 ended this in 2026).
• "The current CURES emergency-style exemption is 5 days."
• "Adult records are always 7 years"—there is no universal private-dental-office period; apply the limited HSC closure rule, Medi-Cal rule, and every other governing requirement to the actual facts.
• "CMIA authorizations must be wet-signed."
• "All Good Samaritan statutes use one scene/no-payment/training checklist"—and "BPC §2395 protects dentists."
• "Every ordinary dentist must file mandatory Form 3500A for every suspected adverse reaction."
• "California joined the dental licensure compact."
• "Reject any answer choice containing the phrase 'conscious sedation'"—the permit was renamed, but BPC §1680(z)'s reporting text still uses the phrase.

Footnotes

Footnotes

1. A20 Dental Board of California, SB 1453 alert for anesthesia and sedation changes effective 1/1/2025. https://www.dbc.ca.gov/formspubs/alert_sb_1453.pdf ↩ ↩² ↩³ ↩⁴

2. A15 California Business & Professions Code §§1680 and 1684.5 — unprofessional conduct, Board records demands, exact seven-day report triggers, patient-of-record rules, and concurrent supervision. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1680. ↩ ↩²

3. A6 Dental Board of California, Table of Permitted Dental Auxiliary Duties, effective 1/1/2025. https://www.dbc.ca.gov/formspubs/pub_permitted_duties.pdf ↩ ↩² ↩³

4. B9 California Dental Association — Tables of Permitted Duties (PRCD028-0719, © 2019; superseded; retains the pre-2025 C/DD legend — stale-prep reference only). https://oralhealthsupport.ucsf.edu/sites/g/files/tkssra13081/files/wysiwyg/CDA%20table-of-permitted-duties%20_highlighted%20duties%20for%20RDA.RDAEF.RDH.RDHAP.pdf ↩

5. A95 BPC §1752.4 — RDA authorized duties; subdivision (c)–(d) assigns the supervising dentist the general-vs-direct supervision determination, except as provided in §1777. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1752.4. ↩

6. A64 Assembly Business & Professions Committee, Analysis of SB 1453 (Ashby, Ch. 483, Stats. 2024) — repeal of the Licensure by Portfolio pathway, effective 1/1/2025. https://abp.assembly.ca.gov/system/files/2024-07/1-sb-1453-ashby-analysis.pdf ↩

7. A38 California Business & Professions Code §1750 — DA definition, basic supportive procedures, infection control, and coronal polishing. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1750. ↩ ↩²

8. A70 16 CCR §1070.6 — Board-approved 8-hour infection-control course content for dental assistants. https://www.dbc.ca.gov/formspubs/1070oal1.pdf ↩

9. A37 California Business & Professions Code §1700 — current license, permit, and registration display. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1700. ↩

10. A48 SB 446 amending California Civil Code §1798.82 — 30-calendar-day breach-notice deadline effective 1/1/2026. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260SB446 ↩

11. A56 AB 35 (2022) — MICRA noneconomic-damages schedule replacing the old flat $250,000 cap; 2026 figures approximately $470K non-death and $650K wrongful death. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB35 ↩

12. A59 Senate Bill 351 (2025), codified at California Health & Safety Code §1191 — private equity and hedge fund clinical-control prohibitions, effective 1/1/2026. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=1191 ↩

13. A81 Assembly Bill 1415 (2025) — OHCA "noticing entities" material-transaction notice. https://hcai.ca.gov/affordability/ohca/assess-market-consolidation/mcn-cmir-faqs/ab-1415-frequently-asked-questions-faq/ ↩

14. A60 Assembly Bill 82 (2025); HSC §11165(k) — CURES reporting exemptions for testosterone and mifepristone, effective 1/1/2026. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB82 ↩

15. A63 Assembly Bill 116 Health Omnibus — elimination of State-only Medi-Cal dental benefits for undocumented adults effective July 1, 2026. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB116 ↩

16. A65 16 CCR §1031 — criterion-referenced passing score set by the modified Angoff method, amended effective 7/1/2022. https://www.law.cornell.edu/regulations/california/16-CCR-1031 ↩

17. A1 Dental Board of California, Candidate Information Bulletin (Dental Law and Ethics Examination). https://www.dbc.ca.gov/formspubs/licensed_le_booklet.pdf ↩ ↩²

18. A2 Dental Board of California, Application to Obtain Eligibility to Take the Law and Ethics Examination. https://www.dbc.ca.gov/applicants/law_and_ethics_exam.shtml ↩

19. A80 California Business & Professions Code §1647.2 — pediatric moderate-sedation requirements for patients under 13. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1647.2. ↩

20. B1 California Confidentiality of Medical Information Act (CMIA), Civil Code §56 et seq.; valid-authorization requirements. https://leginfo.legislature.ca.gov/faces/codesTOCSelected.xhtml?tocCode=CIV ↩

21. A9 California Health & Safety Code §123110 — patient inspection, copies, and the §123110(j) per-page fee caps. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=123110. ↩

22. B11 Dental Board of California 2018 Sunset Review Report — no general law sets one record-retention period for all dentists. https://www.dbc.ca.gov/formspubs/sunset_report_2018vol1.pdf ↩

23. A10 California Health & Safety Code §123145 — limited retention rule when one of four listed HSC-licensed providers ceases operation. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=123145. ↩

24. A67 California Welfare & Institutions Code §14124.1 — 10-year minimum record retention for Medi-Cal (Denti-Cal) providers. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=WIC&sectionNum=14124.1. ↩

25. A33 California Business & Professions Code §650 — anti-kickback limits and the §650(h) platform safe harbor. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=650. ↩

26. A82 California Business & Professions Code §650.01 — self-referral ban for enumerated services. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=650.01. ↩

27. A83 California Business & Professions Code §650.02 — exceptions to the §650.01 self-referral ban. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=650.02. ↩

28. A84 California Health & Safety Code §1373.96 — Knox-Keene continuity of care after provider contract termination. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=1373.96. ↩

29. A94 DHCS APL 25-002 — continuity of care for specified Medi-Cal Dental Managed Care transitions. https://www.dhcs.ca.gov/wp-content/uploads/2025/10/APL-25-002-Continuity-of-Care-for-DMC-Members-on-or-after-July-1-2025.pdf ↩

30. A52 California Probate Code §§4683, 4711, 4712, plus AB 2338 default-surrogate framework for adults lacking capacity. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PROB&sectionNum=4683. ↩

31. A40 California Business & Professions Code §1682 — anesthesia informed consent and the AB 1622 pediatric warning language. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1682. ↩

32. A62 Dentist and Dental Hygienist Compact (DDHC) — member-state status (13 states as of May 2026; California not a member). https://ddhcompact.org/ ↩

33. A85 Dental Board of California — Board Meeting Agenda, February 5–6, 2026 (rulemaking update on 16 CCR §1005). https://www.dbc.ca.gov/about_us/meetings/agendas/20260205_dbc_agenda.pdf ↩

34. A14 Dental Board of California minimum standards for infection control, 16 CCR §1005. https://www.dbc.ca.gov/formspubs/1005mt.pdf ↩

35. A13 DCA CURES mandatory-consultation flyer and exemptions. https://www.dca.ca.gov/publications/cures_flyer.pdf ↩

36. A53 California Business & Professions Code §1627.5 — dentist Good Samaritan immunity. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=1627.5 ↩

37. A88 California Business & Professions Code §§2395 and 2041 — Medicine-chapter Good Samaritan immunity limits (excludes dentists). https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=BPC&sectionNum=2395 ↩

38. A90 FDA MedWatch and medical-device reporting — ordinary clinician Form 3500 reporting is voluntary; mandatory duties vary by role, setting, product, and event. https://www.fda.gov/safety/medical-product-safety-information/medwatch-forms-fda-safety-reporting ↩

39. A92 California Civil Code §56.10(c)(14) — CMIA permission for qualifying voluntary FDA disclosures. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=56.10. ↩

40. A93 Dental Board of California courtesy notice and form for BPC §1680(z) reports. https://www.dbc.ca.gov/licensees/notice_courtesy_reporting.shtml ↩

41. C1 American Dental Association — Principles of Ethics and Code of Professional Conduct (2025 online edition; Advisory Opinions 5.F.7 and 4.E.1). https://commons.ada.org/codeethics/ ↩ ↩²