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Board starts rulemaking to align dentist vaccine rules with state public-health guidance
Summary
The board moved to initiate rulemaking to amend CCR §106 so dentists may continue prescribing and administering influenza and COVID-19 vaccines consistent with California Department of Public Health guidance under AB144; staff will submit the package for agency review.
The Dental Board of California on May 13 authorized staff to initiate rulemaking to update CCR Title 16, section 106 to conform with AB144 and the California Department of Public Health (CDPH) recommendations governing dental administration of influenza and COVID-19 vaccines.
Brandt Nelson briefed the board on the statutory changes: Assembly Bill 144 (effective September 17, 2025) amended Business and Professions Code section 1625.6 to authorize dentists to prescribe and administer influenza and COVID-19 vaccines "consistent with the California Department of Public Health recommendations." Nelson said the regulation update is intended to reflect the statutory change and recent federal and state updates regarding vaccine availability and recommendations.
Board members discussed practical questions, including where dentists may administer vaccines and the training and documentation required for providers. Regulatory counsel clarified there is no separate permit required for immunization so long as a dentist meets the education and training requirements set out in the regulation; the board's regulation will set or cross-reference the training and practice requirements for vaccine administration. Several board members referenced volunteer experience administering vaccines during the pandemic and emphasized that dentists regularly give injections as part of dental practice.
The motion to initiate rulemaking was approved by the board. Staff will submit the proposed text to the DCA director and BCSH for review; if no adverse comments are received, staff may post a 45‑day public notice and proceed to public hearing and adoption as authorized.
Why it matters: The update codifies that dentists may prescribe and administer influenza and COVID‑19 vaccines consistent with CDPH guidance. The change preserves dentists' ability to serve as vaccinators under state public-health recommendations and clarifies training and practice requirements in California regulations.
Next steps: Staff will submit the proposed amendments for agency review and, subject to the public-comment process, complete the formal rulemaking.
