According to the Legislative Budget Board (LBB), HB 1803 is projected to have no net fiscal impact on General Revenue-related funds through the biennium ending August 31, 2027. Although it does not include an appropriation, the bill provides statutory authority for the Texas State Board of Dental Examiners (TSBDE) to implement and administer the Dentist and Dental Hygienist Compact, including charging fees to recover associated costs.
Implementation of the compact will require TSBDE to hire 5 additional full-time employees beginning in fiscal year 2026. These positions include license and permit specialists to process applications, an investigator to manage an expected increase in complaints, and an attorney to handle legal issues. The associated personnel costs total approximately $415,274 in the first year and $380,209 annually thereafter. These costs are anticipated to be fully offset by new fee revenues authorized under the compact.
In addition to staffing, the agency anticipates a one-time technology expense of $35,065 in fiscal year 2026 for updating its regulatory database and purchasing computer equipment for new staff. While the compact commission may impose an annual assessment fee on member states, the exact amount is not yet known and is not reflected in the fiscal estimate. Nonetheless, it is expected that any such cost would also be offset by revenue from newly authorized fees.
There is no anticipated fiscal impact on local governments. The bill’s fiscal structure is designed to ensure cost neutrality to the state by empowering the regulatory agency to recoup all implementation and operational costs through fee collection.
HB 1803, which would enact the Dentist and Dental Hygienist Compact (DDHC), presents a well-intentioned effort to address a documented workforce shortage in the dental profession in Texas. It proposes to streamline licensure recognition among participating states, enabling dentists and dental hygienists licensed in one state to more easily practice in others. The bill is particularly responsive to concerns raised by stakeholders such as the Texas Dental Hygienists' Association and others, citing over 260 designated dental health professional shortage areas across Texas.
Despite its merits in expanding mobility and facilitating quicker workforce entry, the bill raises serious structural concerns under the principle of limited government. Specifically, HB 1803 delegates significant regulatory authority to a newly formed multistate administrative body, the Dentist and Dental Hygienist Compact Commission. This commission is empowered to adopt binding rules that would automatically apply to Texas and other member states without requiring further legislative approval. Such a delegation effectively removes core regulatory decisions from the Texas Legislature and vests them in a body that is not directly accountable to Texas voters.
This arrangement differs meaningfully from other interstate licensure compacts, such as the Nurse Licensure Compact, which often impose narrower scopes of rulemaking or provide stronger mechanisms for state oversight. In the case of HB 1803, the commission would control not only standards for licensure privileges and enforcement actions, but also assess annual fees from each member state and maintain authority over conflict resolution among member states. This design introduces the risk of regulatory overreach without an adequate off-ramp for Texas in the event of future rule changes that conflict with state policy.
Additionally, the bill’s fiscal structure, while revenue-neutral on paper, depends on TSBDE’s authority to levy new fees on applicants and licensees to cover implementation costs and future compact assessments. While the fiscal note assumes fee offsets will balance out administrative costs, the legislature has no control over how much the Compact Commission may eventually charge member states through assessments. This again places considerable discretion in the hands of an unelected body.
Given the significant shift of rulemaking and financial discretion away from Texas institutions and toward an external compact commission, the bill as written fails to uphold the principle of limited, accountable government. Therefore, Texas Policy Research recommends that lawmakers vote NO on HB 1803 unless amended. Lawmakers should establish legislative oversight of compact rules, limit financial exposure, clearly preserve Texas’s regulatory sovereignty, and include an opt-out or sunset provision.