Colorado is the most consequential state on this list for employment terms. In 2022 the Legislature rewrote the non-compete statute around earnings thresholds and notice requirements, and in 2025 Senate Bill 25-083 wrote the practice of dentistry directly into that statute alongside medicine and advanced practice nursing. If you are an associate or an owner in Colorado, that change probably matters more to you than everything else on this page. The equipment side has its own local flavor: CDPHE registers x-ray facilities annually but uses privately registered qualified inspectors to do the machine inspections.
Key takeaways
- Colorado requires at least 30 hours of CE during each two-year license period, including at least 2 hours of infection control, at least 16 hours of clinical or science-based coursework, at least 50 percent live and interactive, and current BLS certification (worth up to 2 hours of credit). Dentists owe at least 1 hour of opioid or substance use training per period.
- Senate Bill 25-083, effective August 6, 2025, excludes a covenant not to compete that restricts the practice of dentistry from the highly compensated worker exemption, and prohibits covenants that stop a health care provider from telling patients about their continuing practice, their new contact information, or the patient's right to choose a provider.
- Under HB22-1317, a non-compete is void unless the worker earns at or above the state's highly compensated worker threshold, a non-solicit requires 60 percent of that threshold, and the employer must give separate written notice. The penalty is $5,000 per worker harmed plus actual damages, costs and fees.
- X-ray facilities register with CDPHE initially and annually on form R-4, and machines are inspected initially and periodically by registered qualified inspectors at intervals that vary from one to three years. Removing a machine is form R-61.
Rules change, so verify before acting. Everything below was checked against an official Colorado or federal source in September 2026. The non-compete provisions are new enough that courts have not fully worked through them, and the earnings thresholds are adjusted by the state labor department. Confirm with the agency and with Colorado counsel before acting.
Who regulates what
| Topic | Agency | Official link |
|---|---|---|
| Dentist, hygienist and dental therapist licensure | Colorado Dental Board, DORA Division of Professions and Occupations | Colorado Dental Board |
| Continuing education | Colorado Dental Board | Dental continuing education |
| Practice act and board rules | Colorado Dental Board | Colorado dental laws |
| X-ray facility registration | CDPHE X-ray Certification Unit | X-ray machine facilities |
| Who may operate an x-ray machine | CDPHE and the relevant licensing board | X-ray machine operators and technologists |
| Qualified inspectors and service companies | CDPHE X-ray Certification Unit | Service companies and qualified inspectors |
| Non-competes and restrictive employment agreements | Colorado General Assembly, C.R.S. 8-2-113 as amended | SB25-083 |
| Amalgam separators and dental wastewater | US EPA rule, enforced by your local pretreatment control authority | EPA dental effluent guidelines |
License renewal and continuing education
The Colorado Dental Board publishes a structured CE requirement rather than a flat number, and the structure is where people lose hours.
- 30 hours during each two-year license period for dentists, academic dentists, dental therapists and dental hygienists with an active Colorado license.
- At least 2 hours of infection control related education.
- At least 16 hours of clinical or science-based courses.
- At least 50 percent of the required hours must be live and interactive.
- Current BLS certification is required, and counts for a maximum of 2 hours of CE credit.
- At least 1 hour of opioid or substance use training each license period for dentists and academic dentists.
New licensees get relief: a first renewal after 12 to 24 months of licensure requires 15 hours, and under 12 months requires none. The board conducts compliance audits after the renewal period closes, so keep certificates rather than relying on a vendor portal.
The live and interactive rule deserves a second read. Fifteen of your thirty hours have to be delivered in a format where you can interact, which rules out the stack of recorded courses many licensees buy in the last month. Plan at least one real meeting or study club sequence per cycle.
X-ray equipment: registration and inspection
Colorado splits the job. CDPHE's X-ray Certification Unit holds the registration; private, state-registered qualified inspectors perform the machine inspections. Every non-federal facility using x-ray machines for any purpose must register.
What the unit publishes:
- Register initially and annually with the X-ray Certification Unit, using the online R-4 registration form each year. CDPHE emails an invoice once the form is processed.
- Inspections are performed initially and periodically by registered qualified inspectors, with frequency varying from one to three years depending on machine and facility type, per Table 2-1 of Part 2, Section 2.5.1.3 of the regulations.
- Report changes including new machines or imaging suites, and report address changes, ownership changes and radiation safety officer changes within 30 days.
- Removing a machine is form R-61, filed when a machine is sold, transferred, disposed of, or the facility closes.
- Lapsed registration can carry a $50 reinstatement fee.
CDPHE warns explicitly that failing to notify it about machines no longer in use may keep generating registration notifications and can result in monetary penalties. In other words, the R-61 is not a courtesy filing.
Because Colorado uses third-party qualified inspectors, the inspection is something you schedule and pay for rather than something that happens to you. Put the next due date in your calendar the day the current report lands, and keep the report with your registration. CDPHE publishes a list of registered qualified inspectors and service companies.
Who may take radiographs
Colorado-licensed dentists, physicians, chiropractors, podiatrists and veterinarians may operate radiation machines subject to the Part 2 requirements. Individuals holding a current ARRT registration in their modality need no additional state registration. For dental, chiropractic, veterinary and podiatry assistants, CDPHE says non-physicians operating x-ray equipment in these fields must complete training specified by each respective board, which points the question back to the Colorado Dental Board. Colorado separately registers limited scope operators, fluoroscopy operators, provisional mammographers and bone densitometry operators, but those categories do not describe a dental assistant taking bitewings.
We could not pull the dental board's specific assistant radiography training requirement from an official page, so confirm it with the board before assigning radiographs to a new hire.
For general mechanics, see dental x-ray registration and inspections, plus intraoral x-ray units and CBCT units.
Buying and selling used equipment in Colorado
Ownership changes are spelled out
CDPHE addresses transactions directly. When you buy a business, you complete the online R-4 registration form and pay the facility registration fee. When you sell, you provide information to the new owner that lets them complete the R-4. Do not assume the buyer's filing closes your registration: file the R-61 for machines that leave your control and confirm your own registration is closed or transferred.
The inspection tail is a real number
A used pan or CBCT arriving at your practice has to be inspected by a qualified inspector, and that cost lands on you, not the seller. Ask when the unit was last inspected and get a copy of the report before you buy. A recent, clean report from a Colorado-registered qualified inspector is worth real money in a negotiation, and its absence is a reason to hold back part of the price.
Ask for the compliance file, not just the machine
In a practice purchase, request the current R-4 registration, the machine list, the most recent inspection report for each unit, and the name of the RSO on file. Our practice acquisition due diligence checklist covers the rest.
Amalgam separators and wastewater
Colorado does not publish a separate state separator rule. The federal EPA dental rule at 40 CFR Part 441 applies if you place or remove amalgam and discharge to a publicly owned treatment works: a compliant separator, best management practices (no flushing scrap amalgam, no oxidizing line cleaners), and a one-time compliance report filed with your pretreatment control authority, usually the local water and sanitation district. Ask that district what it expects from an incoming owner. See amalgam separators and dental waste disposal.
Run the pre-purchase equipment checklist and read the hidden costs of buying used equipment before you commit.
Non-competes and employment
Colorado rebuilt this area in two steps.
Step one, HB22-1317. The 2022 law makes a covenant not to compete void unless the worker earns annualized cash compensation at or above the state's threshold amount for highly compensated workers, and makes a non-solicit provision available only for workers earning at least 60 percent of that threshold. The threshold used is the greater of the amount in effect at the law's effective date or when the covenant is executed. The employer must give separate, clear written notice in the worker's language, before the worker accepts the offer or at least 14 days before the covenant takes effect, that identifies the agreement by name and states that it contains a covenant not to compete that could restrict the worker's options for subsequent employment. Violations carry a penalty of $5,000 per worker or prospective worker harmed, plus actual damages, reasonable costs and attorney fees.
Step two, SB25-083. Signed June 3, 2025 and effective August 6, 2025, this bill excludes from the highly compensated worker exemption a covenant not to compete that restricts the practice of medicine, the practice of advanced practice registered nursing, or the practice of dentistry in this state. It also prohibits covenants that prevent a health care provider from informing patients about their continuing practice, their new professional contact information, or the patient's right to choose a health care provider. Separately, it permits ownership-based covenants for minority business owners who receive equity compensation, with duration calculated by dividing the total sale consideration by the worker's average annualized compensation.
Read those two together and the practical picture for a Colorado associate dentist is unusual. In most states, earning well puts you above whatever statutory floor exists and leaves you exposed. In Colorado, high earnings no longer buy an employer the highly compensated worker route for a covenant that restricts the practice of dentistry. Whether your specific covenant survives is still a question for counsel, but the starting point has moved.
Every Colorado dental employer should also check the patient notification piece. A clause telling a departing dentist not to contact patients at all is now squarely in the crosshairs of the health care provider provision. Have Colorado counsel rewrite the template rather than editing it yourself.
At the federal level, the FTC's non-compete rule is not in effect. The Commission voted on September 5, 2025 to dismiss its appeals and accede to the vacatur, so state law governs. See our national overview of non-compete agreements for dentists, the associate contract red flags guide, and the associate contract review checklist.
What we could not confirm
- The current dollar amount of Colorado's highly compensated worker threshold and the 60 percent non-solicit figure. Those are set and adjusted by the state labor department; confirm the number in effect on the date your covenant was signed.
- Whether SB25-083 applies to agreements signed before August 6, 2025. Ask Colorado counsel about your specific contract.
- Colorado x-ray facility registration fee amounts. CDPHE says an invoice is emailed after the R-4 is processed but does not publish the fee on the pages we read.
- The specific inspection interval for dental x-ray machines. CDPHE points to Table 2-1 of Part 2 and says intervals range from one to three years.
- The Colorado Dental Board's specific radiography training requirement for dental assistants.
- Colorado dentist renewal cycle dates. The board publishes a two-year license period but we did not confirm the calendar dates.
- Colorado limits on non-dentist ownership of a dental practice. The practice act text sits behind linked PDFs we could not open; read it with a dental-specific attorney.
Where to verify
- Colorado Dental Board: board home, continuing education, and dental laws
- CDPHE X-ray Certification Unit: unit home, x-ray machine facilities, certification FAQs, and operators and technologists
- Colorado General Assembly: SB25-083 and HB22-1317 as signed
- US Environmental Protection Agency: dental effluent guidelines, 40 CFR Part 441
- Federal Trade Commission: September 2025 statement on the non-compete rule
Putting it to work
If you are an owner in Colorado, two jobs are overdue. Get your employment templates reviewed against SB25-083, especially any language restricting patient contact, and set a calendar reminder for the annual R-4 registration plus the next qualified inspector visit for each machine. If you are an associate weighing an offer, ask whether the restrictive covenant was drafted before or after August 2025, and get a Colorado employment attorney to tell you what it is actually worth.
Related reading: non-compete agreements for dentists, x-ray registration and inspections, the associate contract review checklist, and the rest of the state resources directory.
This guide is educational content and does not constitute legal, financial, tax, or clinical advice. Laws and regulations vary by state and change over time. Consult your own dental-specific attorney, CPA, and state dental board before acting.