Set up your compliance calendar

Build the recurring-obligation calendar for a dental group: entity filings, DSO registration renewals, dental license and DEA renewals, CAQH re-attestation, recredentialing cycles, and the CDT rollover every January 1.

A compliance calendar tracks recurring obligations for each entity, dentist, and payer. Without one, license renewals, CAQH attestations, and DSO registration deadlines are easy to miss.

Why the calendar grows quickly in a DSO-PC group

A single practice may have one entity’s filings and one dentist’s credentials. A DSO-PC group tracks the same obligations across more entities, clinicians, locations, and payers:

• Per entity: annual reports, franchise taxes, registered-agent renewals, and foreign qualifications for each PC and the DSO
• Per state: DSO registration or licensure where required, each on its own clock
• Per clinician: licenses, DEA registrations where applicable, malpractice coverage, CAQH, and continuing education for each dentist and hygienist
• Per dentist per payer: recredentialing for each participating payer
• Per entity per payer: revalidations and contract renewals

A five-state group with fifteen clinicians and eight payers may be tracking several hundred dated obligations. A spreadsheet can be sufficient at first. Move to a task or credentialing system once owners, reminders, evidence, or reporting become difficult to manage in one sheet.

The obligations

Corporate, per entity

Obligation	Typical cadence	Consequence of missing
State annual report / statement of information	Annual (varies; some biennial)	Late fees, then administrative dissolution
Franchise tax	Annual	Penalties, loss of good standing
Registered agent renewal	Annual	Missed service of process
Foreign qualification annual report	Annual, per state	Loss of authority to do business
Board and shareholder minutes	Annual minimum	Weakens corporate formalities, see Maintain corporate formalities
Beneficial ownership reporting	As required, confirm current status	Verify with counsel; requirements changed materially since 2024

Administrative dissolution can affect more than corporate status. A dissolved PC may put payer contracts and billing privileges at risk, and reinstatement plus payer notification can take months. Set the annual-report reminder 60 days early.

DSO registration renewals, per state that requires them

Several states regulate dental support organizations by name, and the filings recur:

State	Obligation	Cadence
Texas	DSO registration with the Secretary of State (Bus. & Com. Code ch. 73); ≥10% owners and services disclosed	Annual, by January 31; up to $$1,000/day for failure to file1
Arizona	Business-entity registration with the Board of Dental Examiners, per office (A.R.S. § 32-1213)	Triennial renewal; 30-day change notifications2
Kansas	Registration with the Kansas Dental Board (K.S.A. 65-1470); contract copies inspection-ready	Register within 30 days of a contract; update within 30 days of any change3
Nevada	Practice-manager registration with the Board of Dental Examiners (NRS 631.388)	Keep current; confirm cadence with the board4
New Mexico	Non-dentist owner license from the Board of Dental Health Care (§ 61-5A-5.1)	Renewal per board rule. Confirm the current cycle5

Initial requirements are covered in Register a DSO and each state’s row in DSO laws by state. Add the corresponding renewals and change-notice deadlines to the operating calendar after formation counsel finishes the initial filings.

The CDT rollover, every January 1

The ADA revises the CDT dental procedure code set annually, effective January 1, and claims must use the version in effect on the date of service. The CDT 2026 cycle included 60 changes: 31 new codes, 14 revisions, and 6 deletions.⁶ Each December, confirm that the PMS and clearinghouse will update their code tables on January 1, revise fee schedules where needed, and brief the clinical team on reporting changes.

One adjacent one-time deadline worth a calendar entry now: the HIPAA claims-attachment standard (X12 275) has a compliance date of May 26, 2028; your attachment workflow and vendors will change before then.⁷

Dentist credentials, per dentist (and hygienist)

Obligation	Typical cadence	Notes
State dental license	1–3 years, state-specific	Track per state for multi-state dentists; hygienists’ licenses too
DEA registration	3 years	For every prescriber; plus state controlled-substance registrations where required
Malpractice insurance	Annual	Watch limits against payer minimums; track tail on claims-made policies
CAQH re-attestation	~Every 120 days	Requires frequent attention; calendar the due date and owner
Continuing education	Per state board	Required for license renewal; audit-proof the records
BLS/CPR (sedation permits separately)	2 years; sedation permits per board	Sedation/anesthesia permits carry their own renewal and inspection cycles

Payer, per dentist per payer, and per entity per payer

Obligation	Typical cadence
Commercial recredentialing (Delta member companies generally run a 3-year cycle)8	~Every 3 years
Medicaid / dental benefit administrator revalidation	At least every 5 years, state- and DBA-specific
Medicare; only if enrolled (e.g., DMEPOS for sleep appliances)	DMEPOS every 3 years; check the lookup tool
Payer contract renewal / fee schedule review	Annual, per contract
EFT/ERA re-verification	Occasional; triggered by bank changes

Many dental groups have little or no Medicare activity. If an entity is enrolled, however, revalidation notices go to the address in PECOS. An unattended address can lead to a missed response and deactivated billing privileges.

Facility and equipment

Obligation	Cadence
X-ray equipment registration with the state radiation-control program	Varies by state. Confirm your state’s cycle
Amalgam separator inspection/maintenance records (EPA dental rule)	Per manufacturer and rule. Confirm with your compliance vendor
OSHA/infection-control training	Annual

These cadences depend on the state and equipment. Confirm each one with the relevant program and record the resulting date.

Ongoing monitoring, monthly

Check	Why
OIG LEIE exclusion screening for all staff and contractors	Employing an excluded individual creates civil monetary penalty exposure. Search LEIE
SAM.gov debarment screening	Same exposure for federal programs
State Medicaid exclusion lists	Many states maintain their own
License status spot-check	Catches board actions between renewal dates

Monthly is a widely recommended cadence for exclusion screening. Retain the date and the resulting screenshot or report as evidence of each check.

HIPAA and compliance program

Obligation	Cadence
Security risk analysis	Annual, and on material change
Workforce HIPAA training	Annual, plus at onboarding
BAA inventory review	Annual, plus on every new vendor
Policy review and update	Annual
Incident response plan test	Annual

See Build a minimum viable HIPAA program.

Structural review

Obligation	Cadence	Why
MSA and agreement stack review	Annual, plus on any state law change	CPOD law is moving fast. An MSA drafted in 2023 may not comply where you operate today.
CPOD self-audit	Annual	See Run a CPOD self-audit
Management fee FMV review	Annual, and before any fee change	See Set the management fee
State legislation scan	Quarterly	See the legislation tracker

State-law review is a recurring task because several jurisdictions changed their rules in 2025 and 2026. California’s SB 351 extended private-equity and control restrictions to dental practices effective January 1, 2026.⁹ Kentucky revised its ownership rules effective April 2026 (KRS 313.075, with grandfathering).¹⁰ Colorado adopted Rule 1.7 provisions scheduled to become operative January 1, 2027, and North Carolina ended mandatory board review of management arrangements in July 2026. Recheck the structure against current law rather than relying on the date when the agreements were drafted. See DSO laws by state.

Build it in an hour

1. Make one table with six columns

   Obligation · Entity or person · Jurisdiction/payer · Due date · Owner · Lead time

2. Populate from the sections above

   Include every entity, dentist, hygienist, and payer. The inventory establishes the scope before you assign dates and owners.

3. Set lead times, not due dates, as the alert

   60 days for anything requiring a filing or a committee. 30 days for renewals. 14 days for attestations.

4. Assign a named owner to each row

   “Operations” is not an owner. A person is.

5. Put it somewhere with real reminders

   Use a shared calendar with alerts, a task system, or credentialing software. Choose a tool that the assigned owners will review and update.

6. Review it monthly

   Add the coming 60 days to the monthly close checklist.

Template

Copy this structure (Bluebird’s home-state rows shown generically; use your states):

Obligation	Entity / person	Jurisdiction / payer	Due	Lead	Owner	Status
PC annual report	Bluebird Dental PC	Home-state SOS	Per state	60d	Sam	☐
Franchise tax	Bluebird DSO LLC	Formation state	Per state	30d	Sam	☐
Dental license renewal	Dr. Okafor	State dental board	Per board	60d	Dr. Okafor	☐
Hygienist license renewal	Each hygienist	State dental board	Per board	60d	Ops	☐
DEA renewal	Dr. Okafor	Federal	3 yr	60d	Dr. Okafor	☐
CAQH re-attestation	Dr. Okafor	CAQH	Rolling ~120d	14d	Biller	☐
Malpractice renewal	Bluebird Dental PC	Carrier	Annual	60d	Sam	☐
Delta recredentialing	Dr. Okafor	Delta member company	3 yr	90d	Biller	☐
Medicaid DBA revalidation	Bluebird Dental PC	State DBA	Per program	90d	Biller	☐
CDT code rollover	Both entities	PMS + clearinghouse	Jan 1	30d	Biller	☐
DSO registration renewal	Bluebird DSO LLC	e.g. Texas SOS, after expansion	Jan 31	60d	Sam	☐
X-ray equipment registration	Bluebird Dental PC	State radiation program	Per state	60d	Ops	☐
OIG/SAM screening	All staff	Federal	Monthly	Not applicable	Ops	☐
MSA review	Both entities	Counsel	Annual	30d	Sam	☐
CPOD self-audit	Both entities	Internal	Annual	30d	Sam	☐

You’ve finished the first 90 days

You now have a billing cadence, a process that separates downgrades from denials, a refund workflow, a three-way monthly reconciliation, and a calendar for credentials, registration renewals, and agreement reviews.

Next

Expanding to a second state

Reassess entity, ownership, filing, payer, and banking requirements in the new state.

Sources

1. Tex. Bus. & Com. Code ch. 73 (S.B. 519, eff. Sept. 1, 2015): annual filing by January 31 (§ 73.005); civil penalty up to $$1,000 per day (§ 73.006). § 73.001.
2. A.R.S. § 32-1213(B)–(E): registration per branch office, triennial renewal, 30-day change notifications. Statute.
3. K.S.A. 65-1470 (L. 2011, ch. 114): Kansas Dental Board registration, 30-day windows, contracts subject to board inspection. Statute.
4. NRS 631.388 (2009): practice-manager registration with the Nevada board. NRS ch. 631.
5. NMSA 1978, §§ 61-5A-5(H), 61-5A-5.1: non-dentist owner license; renewal governed by board rule. Statute.
6. ADA News, 60 changes coming to CDT Code in 2026.
7. 91 FR 14350 (March 24, 2026), compliance date May 26, 2028. Federal Register.
8. E.g., Delta Dental of Tennessee, Credentialing and recredentialing; recredentialing generally on a three-year cycle; each member company administers its own.
9. Cal. S.B. 351 (2025), effective January 1, 2026. Summary: Benesch, California Enacts SB 351.
10. KRS 313.075, effective April 13, 2026. Statute.