On July 22, 2026, the NYS Department of Health (DOH) finalized regulations establishing new requirements for dentists outside of New York City who use cone beam computed tomography (CBCT) equipment in their offices.

NYSDA Opposed the Accreditation Requirement

NYSDA has been actively challenging the CBCT accreditation requirement since it was first proposed. The Department issued drafts of these regulations twice beginning in 2024, and NYSDA formally opposed the accreditation requirement each time: See HERE and HERE

Earlier this year, NYSDA met with DOH to further protest the accreditation requirement and followed that meeting with an additional formal letter of opposition. See HERE

After the regulations were finalized, NYSDA again met with DOH to emphasize the significant burden these requirements will place on dental practices and to urge the Department to exercise appropriate flexibility and patience in enforcement. NYSDA also challenged the Department's interpretation of the deadline for submitting accreditation applications. See HERE

Despite NYSDA's sustained efforts and repeated objections, DOH proceeded with the accreditation requirement.

NYSDA does not agree with the Department's assessment that these requirements are necessary and appropriate as written, and we remain concerned about the cost, availability of qualified medical physicists, and potential impact on access to care.

NYSDA Continues to Work on Behalf of Members

NYSDA's advocacy on this issue did not end when the regulations were finalized. We are continuing to engage with DOH, medical physics organizations, and accreditation agencies to identify ways to make the compliance process as workable as possible for our members.

We are also working to better understand the availability of qualified medical physicists and the practical challenges dentists may encounter in meeting the new requirements.

Important Clarification for New York City Dentists

Just recently, DOH clarified that these CBCT accreditation requirements do NOT apply to dental CBCTs within New York City (Bronx, Kings, New York, Queens, and Richmond counties). New York City dental offices are governed by Article 175 of the New York City Health Code. While the City could address CBCT requirements separately in the future, the requirement does not currently apply to dental offices within the City.

Learn More

The key part of these regulations can be found here on the State of NY website:
https://regs.health.ny.gov/content/section-1665-diagnostic-cone-beam-computed-tomography-cbct

NYSDA’s website helps to summarize these requirements: https://www.nysdental.org/practice-support/nys-regulations-on-cbct

NYSDA will continue to advocate on this issue and keep members informed as additional information and developments become available