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Working With a Registered Dental Hygienist in Alternative Practice: What You Need To Know

June 07, 2022 6340

A California active licensed dentist should know the scope of practice and settings for a registered dental hygienist in alternative practice (RDHAP) and the dentist’s responsibilities when working with an RDHAP. In addition, this resource provides information on the requirements and process for becoming a licensed RDHAP.

RDH to RDHAP — What Is Required?

Prior to applying for the RDHAP license, a candidate must:

  • Have a current and active California license as a registered dental hygienist
  • Have been engaged in clinical practice as a dental hygienist for a minimum of 2,000 hours during the immediately preceding 36 months (in California or another state)
  • Possess a Bachelor of Science (BS) degree or transcripts demonstrating the equivalency of 120 semester units
  • Have completed 150 hours of an approved educational RDHAP program
  • Complete fingerprinting requirement

Currently there are three approved educational RDHAP programs in California:

The RDHAP education curriculum focuses on the following:

  • Dental hygiene technique and theory
  • Gerontology
  • Medical emergency
  • Business administration
  • Practice management

Program cost varies from $2,500 to $5,000 among the two private and one public schools.

The license application is available on the Dental Hygiene Board of California website and an online application is on With the application for licensure, a candidate is required to submit:

Once a candidate’s application has been accepted, information on taking the California Law and Ethics exam will be provided.

Scope of practice

The duties that an RDHAP are allowed to perform and the associated supervision levels and settings are specified in the Business and Professions Code Sections 1900 – 1966.6 and 16 CCR §1118. A summary of those duties is included in Tables of Permitted Duties and on the CDA-provided employment poster set.

An RDHAP cannot infer, advertise or imply that they are able to provide dental services or make any type of dental diagnosis beyond evaluating a patient’s dental hygiene status, providing a dental hygiene treatment plan and providing the associated dental hygiene services.

Requirement to establish relationship with a dentist

An RDHAP must provide to the dental hygiene board documentation of an existing relationship with at least one dentist for referral, consultation and emergency services. In establishing a relationship with a dentist, each party should be familiar with the provisions of Business and Professions Code Sections 650, 654.1, 654.2 on unearned rebates and self-referral.

An RDHAP must provide documentation of a current relationship with a licensed dentist at every biennial license renewal. Should an existing dentist relationship end, the RDHAP must report the termination to the dental hygiene board within 30 calendar days and also provide documentation that a new relationship with a licensed dentist has been established for referral, consultation and emergency services. When an RDHAP learns that a dentist with whom they have an existing relationship has been placed under discipline prohibiting practice by the dental board, the RDHAP must terminate the existing relationship and notify the dental hygiene board within 30 calendar days of the termination. The RDHAP also must provide documentation that a new relationship with a licensed dentist has been established for referral, consultation and emergency services.

Independent Contractor or Employee?

The classification of an RDHAP as an independent contractor is dictated by the setting in which the RDHAP is working. Business and Professions Code Section 1925

When employed by a dentist working in a dental practice setting, an RDHAP would not meet the B&P Code or California or Labor Code criteria of independent contractor classification. Under the ABC test used in California and several other states, a worker is considered an employee and not an independent contractor, unless the hiring entity satisfies all three of the ABC test conditions.

When hiring as an employer s a sole proprietor of an alternative dental hygiene practice, an RDHAP may hire another RDHAP as an independent contractor.

Prescription requirement

An RDHAP may provide services to a patient without first obtaining written verification that the patient has been examined by a California-licensed dentist or physician. To continue providing services to a patient 18 months or more after first providing services, an RDHAP must obtain written verification that the patient has been examined by a California-licensed dentist or physician. The verification shall include a prescription for dental hygiene services. A prescription for dental hygiene services is valid for a period based on the dentist’s or physician’s professional judgment but not to exceed two years from the date it was issued. An RDHAP shall refer their patients to a dentist whenever there is suspected disease.

Practice settings

An RDHAP may be an employee or may work as a sole proprietor of their own business. In either situation, an RDHAP must register all places of practice with the dental hygiene board or report that they have no place of practice.

An RDHAP may practice as an employee of:

  • another registered dental hygienist in alternative practice
  • a dentist
  • a primary care clinic or other specialty clinic licensed pursuant to Section 1204 of the Health and Safety Code
  • a primary care clinic exempt from licensure pursuant to subdivision (c) of Section 1206 of the Health and Safety Code
  • a clinic owned or operated by a public hospital or health system
  • a clinic owned and operated by a hospital that maintains the primary contract with a county government to fill the county’s role under Section 17000 of the Welfare and Institutions Code
  • a professional corporation created under the Moscone-Knox Professional Corporation Act

RDHAPs may practice independently only in the following settings:

  • Dental Health Professional Shortage Areas as determined by the Office of Health Planning and Development
  • residences of the homebound
  • nursing homes
  • hospitals
  • residential care facilities
  • other public health settings.

Allowable and permitted actions

An RDHAP may employ and supervise dental assistants to perform intraoral retraction and suctioning. They also may employ another RDHAP, but they are not permitted to hire a registered dental hygienist to provide direct patient services.

An RDHAP may form a professional corporation that complies with the provisions of Business & Professions Code Section 1967-1967.4.

An RDHAP may submit or allow to be submitted any insurance or third-party claims for patient services performed.

A fictitious name permit is required in order to operate a dental hygiene practice under any name other than the name with which the owner or owners are licensed.

An RDHAP may own and operate one mobile dental hygiene clinic. It must be registered as a dental hygiene office or facility with the dental hygiene board and operated in accordance with the board’s regulations.

If an RDHAP’s registered place of practice has been rendered unusable due to loss or calamity, they may operate a mobile dental hygiene clinic provided by the licensee’s property and casualty insurer as a temporary substitute site if the licensee’s insurer registers the mobile dental hygiene clinic with the dental hygiene board.

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