A new bill making its way through the California State Legislature has ignited one of the dental profession’s most contentious workforce debates in years. Assembly Bill 1952, authored by Assemblymember Marc Berman (D-Menlo Park) and sponsored by the California Dental Association, would require the Dental Hygiene Board of California to establish an alternative licensure pathway allowing internationally trained dentists to practice as registered dental hygienists — without completing a Commission on Dental Accreditation (CODA)-accredited dental hygiene program.

The bill was introduced on February 13, 2026, and has already drawn strong reactions from both sides of the dental aisle. For organized dentistry, it represents a pragmatic solution to a growing workforce shortage crisis. For organized dental hygiene, it represents a direct threat to professional standards, educational integrity, and the very identity of the hygiene profession.

The bill’s supporters point to some sobering numbers. California currently has more than 570 federally designated Dental Health Professional Shortage Areas (DHPSAs), and projections from the California Future Health Workforce Commission suggest that access gaps will only widen as the state approaches 2030. Rural and underserved communities — including many Tribal and Federally Qualified Health Center (FQHC) service areas — are disproportionately affected.

“Californians are facing a dental care workforce crisis that only continues to worsen, with millions of residents across the state living with inadequate access to oral health care,” Assemblymember Berman said in a press release announcing the bill. He framed the legislation as a way to put skilled professionals already living in California to work on a faster timeline, rather than requiring them to complete a multi-year U.S. dental residency before they can practice at all.

CDA President Dr. Robert Hanlon echoed that sentiment, describing the bill as a competency-based licensure track that would allow foreign-trained dentists to integrate into California dental teams while increasing the availability of linguistically and culturally diverse care — a meaningful consideration in a state where immigrant communities often face both language barriers and provider shortages simultaneously.

AB 1952 would not simply hand out hygiene licenses to anyone with a foreign dental degree. The bill directs the Dental Hygiene Board to develop a licensure pathway that includes several requirements: applicants must hold a degree equivalent to a DDS or DMD from a non-U.S. dental school, demonstrate academic equivalency through a credential evaluation process, pass required examinations, and complete coursework in California-specific areas including the Dental Practice Act, infection control, gingival soft tissue curettage, nitrous oxide-oxygen analgesia, and local anesthesia.

Notably, however, the bill does not require applicants to have completed a CODA-accredited dental hygiene program — which is the current standard pathway to RDH licensure in California. It also does not require the newly licensed hygienists to practice in underserved or shortage areas, a detail that has drawn criticism from those who argue the bill’s workforce justification rings hollow without such a provision.

The California Dental Hygienists’ Association (CDHA) has come out strongly against the bill, releasing an outreach toolkit to mobilize its membership and coordinate legislative opposition. Their objections center on several key points.

First, CDHA argues that the bill conflates dental education with dental hygiene education. While foreign-trained dentists may have extensive clinical training in restorative and surgical procedures, dental hygiene is a distinct discipline with its own body of knowledge. Hygiene curricula emphasize preventive care, periodontal instrumentation protocols, patient education methodology, and scope-specific clinical calibration — competencies that are not necessarily covered in depth in dental school programs, whether domestic or international.

Second, CDHA challenges the premise that California faces a statewide shortage of dental hygienists. The association contends that CDA’s workforce data relied on a flawed 1:1 dentist-to-hygienist ratio assumption, when in reality most hygienists work for more than one dentist. A more accurate ratio, CDHA argues, is approximately two hygienists per dentist — which significantly changes the math on whether a true shortage exists.

Third, hygienists note that the bill contains no geographic practice requirement. If the goal is to address shortages in underserved areas, the legislation as written does nothing to ensure that newly licensed hygienists actually practice there. A foreign-trained dentist licensed as a hygienist in San Francisco or Los Angeles does little to help patients in the Central Valley or on Tribal lands.

California is not operating in a vacuum. Virginia and Florida have already passed similar legislation creating alternative pathways for internationally trained dentists to enter the hygiene workforce. Florida is simultaneously debating the introduction of dental therapists as mid-level practitioners through HB 363, reflecting a nationwide conversation about how to restructure dental teams to improve access.

These discussions are unfolding against a backdrop of real workforce pressure. The dental hygienist labor market tightened significantly during and after the COVID-19 pandemic, with many hygienists leaving the profession or reducing hours. Practice owners across the country have reported difficulty filling hygiene positions, leading to reduced patient access and longer wait times.

At the same time, there are tens of thousands of internationally trained dentists living in the United States who cannot practice because they have not completed the lengthy and expensive process of obtaining a U.S. dental license. Many of these individuals have years of clinical experience in their home countries. The question AB 1952 raises is whether that experience can be leveraged to fill gaps in the hygiene workforce — and whether it can be done without compromising patient care.

For Federally Qualified Health Centers and Tribal health programs — the providers most directly serving patients in designated shortage areas — the workforce question is not academic. These organizations frequently struggle to recruit and retain dental hygienists, particularly in rural locations where the cost-of-living-to-salary ratio makes positions less competitive compared to private practice in urban and suburban markets.

Whether AB 1952 would meaningfully change that dynamic is an open question. Without a practice location requirement or incentive structure tied to underserved areas, there is no guarantee that the new licensure pathway would direct hygienists where they are needed most. Safety-net providers may find that the bill creates a larger workforce pool in general, but the distribution of that workforce remains market-driven.

AB 1952 is in its early stages, having been introduced in February 2026. It will need to move through committee hearings where both CDA and CDHA are expected to testify, and amendments are likely before it reaches a floor vote. Workgroup discussions have already surfaced potential guardrails that could be added to the bill, including national and regional examination requirements, credential evaluation through established services, proof of prior licensure and clinical work history, English proficiency testing, and structured refresher or bridge programs.

Whether those additions will be sufficient to satisfy the dental hygiene community remains to be seen. CDHA’s longstanding policy position opposes any program or legislation that permits training outside the jurisdiction of an accredited educational facility for licensed health care providers.

AB 1952 sits at the intersection of several forces reshaping the dental profession: access-to-care disparities, workforce shortages, the evolving role of mid-level providers, immigration policy, and the professional identity of dental hygiene itself. Both sides of the debate make legitimate points. The access workforce shortage is real, and the current system leaves qualified clinicians on the sidelines. But professional standards exist for a reason, and creating a two-tiered licensure system raises valid concerns about consistency of care and the long-term implications for the hygiene profession.

This is a bill worth watching closely — and one where the details of any final amendments will matter as much as the legislation’s stated intent. USA Dental Report will continue to follow AB 1952 as it moves through the legislative process. You can track the progress of the bill here.