3.2 Dental Therapist (DT) & Advanced Dental Therapist (ADT) Scope

3.2 Dental Therapist (DT) & Advanced Dental Therapist (ADT) Scope

Landmark Legislation: In 2009, the Minnesota Legislature enacted Minnesota Statutes § 150A.105 (Dental Therapy) and § 150A.106 (Advanced Dental Therapy), establishing the first mid-level dental practitioner licensing framework in the United States. The explicit statutory purpose of the dental therapy model is to alleviate critical oral health disparities in underserved, rural, and safety-net populations across Minnesota.

Minnesota's dental therapy model is structured as a two-tier professional pathway: the Dental Therapist (DT) and the Advanced Dental Therapist (ADT). While both mid-level tiers deliver preventative, restorative, and palliative care, they differ substantially in their educational prerequisites, clinical supervision requirements, diagnostic authority, and surgical extraction parameters.

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The Collaborative Management Agreement (CMA)

Under Minnesota Statutes § 150A.105, Subd. 3, a dental therapist or advanced dental therapist cannot practice independently. Every DT and ADT must maintain an active, executed Collaborative Management Agreement (CMA) with a Minnesota-licensed dentist.

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|                 MANDATORY ELEMENTS OF A COLLABORATIVE AGREEMENT                |
|                                                                                |
|  1. Practice Settings & Specific Clinical Locations                            |
|  2. Supervision Levels for Each Delegated Scope Procedure                      |
|  3. Standing Protocols for Medical Emergencies & Quality Assurance             |
|  4. Explicit Patient Referral & Hospital Transfer Pathways                     |
|  5. Specific Drug Formulary Authorization (Analgesics, Antibiotics, etc.)     |
|  6. Annual Review, Signature, and Retention on Practice Premises               |
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Key Statutory Mandates for CMAs:

• Supervising Dentist Limit: A licensed dentist may not enter into a collaborative management agreement with more than five (5) full-time equivalent dental therapists at any one time (MN Stat. § 150A.105, Subd. 3(c)).
• Practice Settings: The agreement must delineate the exact physical or mobile clinical settings where care is rendered.
• Annual Renewal: The CMA must be reviewed, updated, and signed annually by both the therapist and the collaborating dentist.
• Regulatory Filing: The signed agreement must be kept on file at the practice site and provided immediately to the Board of Dentistry upon inspection or formal request.

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Dental Therapist (DT) Scope & Supervision (MN Stat. § 150A.105)

The collaborative management agreement is the gatekeeper. Under § 150A.105, subd. 3, a DT must enter a written CMA with a Minnesota-licensed dentist before performing any service. A collaborating dentist "is limited to entering into a collaborative agreement with no more than five dental therapists or advanced dental therapists at any one time." The agreement must include ten specified elements: practice settings and populations served; limitations on services including the level of supervision required; age- and procedure-specific practice protocols with case selection criteria, assessment guidelines, and imaging frequency; a procedure for creating and maintaining dental records; a plan to manage medical emergencies in each setting; a quality assurance plan with patient care review, referral follow-up, and chart review; protocols for administering and dispensing medications; criteria for patients with specific medical conditions or complex medication histories, including consultation before initiating care; supervision criteria for dental assistants; and a plan for clinical resources and referrals beyond the DT's capabilities. The collaborating dentist "shall accept responsibility for all services authorized and performed by the dental therapist," and agreements "must be reviewed, updated, and submitted to the board on an annual basis."

Educational & Licensure Pathways — MN Rules 3100.1180

Subpart 1 lists exactly what a dental therapy applicant must provide the Board:

• a completed application, a form of current government-issued identification, and the fee in MN Stat. § 150A.091, subd. 2 ($220 for a dental therapist);
• evidence of graduating with a baccalaureate degree or a master's degree from a dental therapy education program approved by the Board or accredited by CODA or another board-approved national accreditation organization;
• evidence of passing a board-approved clinical examination in dental therapy within the past five years;
• evidence of passing the Board's jurisprudence examination within the past five years;
• documentation of current CPR certification; and
• a criminal background check under MN Stat. § 214.075.

Two failed clinical attempts triggers mandatory remediation (subp. 2). If an applicant "fails twice any part of the clinical examination required by Minnesota Statutes, section 150A.06, subdivision 1d, the applicant must not retake the examination until the applicant successfully completes additional education provided by an institution approved by the board." That education "must cover all of the subject areas failed," and the institution must report to the Board which areas were failed, what education addressed them, and that the applicant completed it. The requirement repeats each time the applicant fails twice.

ADT certification through the rule (subp. 3). A Minnesota-licensed dental therapist seeking advanced certification provides a completed application, the § 150A.091, subd. 2 fee ($100 for an advanced dental therapist), evidence of at least 2,000 hours of dental therapy clinical practice under direct or indirect supervision, evidence of the baccalaureate or master's dental therapy degree, evidence of graduating from a master's advanced dental therapy education program, and evidence of passing a board-approved certification examination in advanced dental therapy.

Renewal, reinstatement, and emeritus (subps. 4–6). A dental therapist renews under MN Rules 3100.1700 on the ordinary biennial birth-month cycle — but note the asymmetry in subpart 4: "The onetime certification for an advanced dental therapist does not require renewal once obtained." A terminated dental therapy license is reinstated under 3100.1850, and a dental therapist may apply for emeritus inactive status under 3100.1340 or emeritus active status under 3100.1350.

Supervision Levels — the statute splits the list in two

MN Stat. § 150A.105, subd. 4 assigns each service to a level, and subd. 4(e) confirms that "general supervision" and "indirect supervision" carry the meanings given in MN Rules 3100.0100, subpart 21. There is no direct-supervision or personal-supervision tier for dental therapists in the statute. The collaborative management agreement may restrict or prohibit a listed service or raise the required supervision level, but it cannot expand the list.

DT services under GENERAL supervision — § 150A.105, subd. 4(c)

"unless restricted or prohibited in the collaborative management agreement":

1. oral health instruction and disease prevention education, including nutritional counseling and dietary analysis;
2. preliminary charting of the oral cavity;
3. making radiographs;
4. mechanical polishing;
5. application of topical preventive or prophylactic agents, including fluoride varnishes and pit and fissure sealants;
6. pulp vitality testing;
7. application of desensitizing medication or resin;
8. fabrication of athletic mouthguards;
9. placement of temporary restorations;
10. fabrication of soft occlusal guards;
11. tissue conditioning and soft reline;
12. atraumatic restorative therapy;
13. dressing changes;
14. tooth reimplantation;
15. administration of local anesthetic; and
16. administration of nitrous oxide.

DT services under INDIRECT supervision — § 150A.105, subd. 4(d)

1. emergency palliative treatment of dental pain;
2. the placement and removal of space maintainers;
3. cavity preparation;
4. restoration of primary and permanent teeth (the statute states no Black's-classification limit — the Class I, II, and V ceiling belongs to the hygienist and dental assistant restorative functions under § 150A.10, subd. 4, not to dental therapists);
5. placement of temporary crowns;
6. preparation and placement of preformed crowns;
7. pulpotomies on primary teeth;
8. indirect and direct pulp capping on primary and permanent teeth;
9. stabilization of reimplanted teeth;
10. extractions of primary teeth;
11. suture removal;
12. brush biopsies;
13. repair of defective prosthetic devices; and
14. recementing of permanent crowns.

Two boundaries to hold onto. Tooth reimplantation is general supervision but stabilization of the reimplanted tooth is indirect. Pulpotomies are limited to primary teeth, while pulp capping reaches permanent teeth. Extractions of permanent teeth are outside the DT scope entirely and belong only to a certified ADT within the mobility limits of § 150A.106, subd. 3.

Practice-setting limitation — § 150A.105, subds. 2 and 8

A dental therapist "is limited to primarily practicing in settings that serve low-income, uninsured, and underserved patients or in a dental health professional shortage area." Subdivision 8 defines those settings concretely: critical access dental provider settings designated under § 256B.76, subd. 4; dental hygiene collaborative practice settings under § 150A.10, subd. 1a, para. (e), including medical facilities, assisted living facilities, federally qualified health centers, and community-clinic-grant organizations; military and veterans administration settings; a home-bound patient's residence regardless of income; oral health educational institutions; or any other clinic or practice setting, including mobile dental units, in which at least 50 percent of the DT's or ADT's total patient base consists of patients enrolled in a Minnesota health care program, patients with a medical disability or chronic condition creating a significant barrier to dental care, or uninsured patients with annual gross family income at or below 200 percent of the federal poverty guidelines. Memorize the two numbers: 50 percent patient base and 200 percent FPG.

Supervising assistants, and the armed-forces exception

• § 150A.105, subd. 7: a licensed dental therapist "is limited to supervising no more than four licensed dental assistants or nonlicensed dental assistants at any one practice setting," and only to the extent the CMA permits.
• § 150A.105, subd. 3a: while practicing under the auspices of the Minnesota National Guard or any branch of the armed forces (including the Space Force), the collaborating dentist may be determined by the command structure, and the DT's civilian collaborating dentist is not responsible for supervising services performed under the armed-forces auspices.

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Advanced Dental Therapist (ADT) Scope & Certification (MN Stat. § 150A.106)

An Advanced Dental Therapist (ADT) is a board-certified master-level practitioner who possesses significantly broader clinical autonomy and diagnostic authority.

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|        ADT CERTIFICATION - ALL SEVEN REQUIREMENTS (MN Stat. 150A.106 subd. 1)   |
|                                                                                |
|   (1) complete a dental therapy education program;                             |
|   (2) pass an examination demonstrating competency under the dental therapy    |
|       scope of practice;                                                       |
|   (3) be LICENSED as a dental therapist;                                       |
|   (4) complete 2,000 HOURS of dental therapy clinical practice under DIRECT    |
|       OR INDIRECT supervision;                                                 |
|   (5) graduate from a MASTER'S advanced dental therapy education program;      |
|   (6) pass a board-approved CERTIFICATION EXAMINATION demonstrating competency |
|       under the advanced scope of practice; and                                |
|   (7) submit an application and fee for certification as prescribed by the     |
|       board (ADT application fee $100 - MN Stat. 150A.091 subd. 2).            |
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Note the wording of item (4): the 2,000 hours are dental therapy clinical practice under direct or indirect supervision. An ADT is certified by the Board, not separately licensed — the underlying credential remains the dental therapist license.

Supervision Level: General Supervision

MN Stat. § 150A.106, subd. 2(b) states that the ADT services and procedures described in subdivision 2 "may be performed under general supervision." Under MN Rules 3100.0100, subp. 21, item D, that means the collaborating dentist need not be in the office or on the premises, but must have prior knowledge of and consent to the procedures. Subdivision 3(a) adds a limit that survives the general-supervision label: "An advanced practice dental therapist shall not perform any service or procedure described in subdivision 2 except as authorized by the collaborating dentist."

Expanded Clinical Authority for ADT:

1. Oral Health Assessments & Diagnosis: An ADT is statutorily authorized to perform comprehensive oral health assessments, formulate dental disease diagnoses, and establish authoritative treatment plans within their scope of practice.
2. Permanent Tooth Extractions (§ 150A.106, subd. 3(b)): "An advanced dental therapist may perform nonsurgical extractions of periodontally diseased permanent teeth with tooth mobility of +3 to +4 under general supervision if authorized in advance by the collaborating dentist."
   • Strict Prohibition (same paragraph): "The advanced dental therapist shall not extract a tooth for any patient if the tooth is unerupted, impacted, fractured, or needs to be sectioned for removal." Four disqualifiers, stated flatly — no depth qualifier such as "below the bone line" appears in the statute.
   • Referral duty (subd. 3(c)–(e)): the collaborating dentist is responsible for directly providing or arranging any necessary advanced services; the ADT must refer patients needing care beyond the ADT scope; and the CMA must contain specific written protocols for situations exceeding that scope, with a dentist available for timely consultation during treatment.
3. Dispensing and Administering Authority (§ 150A.106, subd. 4): An ADT may provide, dispense, and administer only three categories, within the CMA and with the collaborating dentist's authorization:
   • analgesics, anti-inflammatories, and antibiotics.
   • The authority "shall extend only to the categories of drugs identified in this subdivision, and may be further limited by the collaborative management agreement," and the authority to dispense includes sample drugs in those categories if the CMA permits.
   • Strict Prohibition: an ADT "is prohibited from providing, dispensing, or administering a narcotic drug as defined in section 152.01, subdivision 10." Note the statutory phrasing — it is a narcotic-drug ban keyed to the Chapter 152 definition, not a "Schedule II" ban, and it applies to dispensing and administering, not merely prescribing. The identical prohibition applies to dental therapists under § 150A.105, subd. 5(d).

Underserved Population Practice Mandate

Under MN Stat. § 150A.105, Subd. 2, dental therapists and advanced dental therapists must practice primarily in settings serving low-income, uninsured, and underserved patients. Qualifying safety-net settings include:

• Federally Qualified Health Centers (FQHCs) and Community Health Centers.
• Nonprofit community dental clinics or rural hospital-based dental programs.
• Dental Health Professional Shortage Areas (HPSAs).
• Private practice settings where at least 50% of the patient base consists of individuals enrolled in Minnesota Health Care Programs (Medical Assistance/MinnesotaCare) or who are uninsured/underserved.

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Master Scope Comparison: DT vs. ADT

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Clinical Case Study & Decision Analysis

Clinical Case: Rural Satellite Clinic Emergency

• Patient: A 62-year-old uninsured agricultural worker presents to a remote nonprofit safety-net dental clinic in Beltrami County with severe pain in the lower right quadrant. The collaborating dentist is 75 miles away at the central regional health facility.
• Provider: An Advanced Dental Therapist (ADT) with active Board certification and an executed CMA is staffing the satellite clinic under General Supervision.
• Clinical Findings: Tooth #31 has severe localized horizontal bone loss with Class 3 mobility, a deep 9mm periodontal pocket with purulence, and severe tenderness to percussion. Tooth #30 has an extensive coronal fracture extending 3mm subgingivally into the alveolar crest, but is firmly anchored (zero mobility).
• ADT Management:
  1. Tooth #31: The ADT diagnoses chronic severe periodontitis with acute periodontal abscess. Because tooth #31 is a permanent tooth with Class 3 mobility due to periodontal disease, the ADT may legally perform a simple non-surgical extraction under local anesthesia pursuant to the CMA.
  2. Tooth #30: Because tooth #30 is a non-mobile, fractured permanent molar requiring surgical sectioning or surgical root retrieval, the ADT cannot extract tooth #30. The ADT provides emergency palliative care (smoothes sharp edges, places a temporary sedative dressing), prescribes a 7-day course of amoxicillin and ibuprofen per the CMA formulary, and schedules a priority surgical referral with the collaborating dentist.

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Exam Traps & Common Misconceptions

• ⚠️ Exam Trap 1: Permanent Tooth Extraction Limits for ADT. An ADT cannot extract any permanent tooth they encounter. The permanent tooth must be periodontally diseased with Class 3 or 4 mobility and amenable to simple non-surgical forceps extraction. Extracting an intact, non-mobile tooth with irreversible pulpitis or an impacted tooth is a statutory violation.
• ⚠️ Exam Trap 2: DT vs. ADT Supervision Discrepancy. A standard DT can never practice under General Supervision for restorative or extraction procedures; they require Indirect Supervision (dentist on site). Only a board-certified ADT under a valid CMA can practice under General Supervision.
• ⚠️ Exam Trap 3: Collaborative Agreement Dentist Ratio. A single licensed dentist is legally capped at supervising a maximum of 5 full-time equivalent dental therapists simultaneously.