By: Jordan M. Brown-Burd “Law Clerk” and Michael G. Polis

On May 7, 2026, Attorney General (“AG”) Rob Bonta filed a lawsuit on behalf of the people of California alleging that Aspen Dental Management, Inc. (“ADMI”) violated California Business and Professions Code sections 17200 et seq. and 17500 et seq. The parties have since agreed to a proposed Final Judgment, which now awaits approval from a superior court judge.

Monetary Payments

For alleged violations under Business and Professions Code sections 17206 and 17536, ADMI is required to pay $2 million in civil penalties, to be wired in full to the Office of the California Attorney General no later than 15 days following entry of the Judgment.

The settlement also requires ADMI to pay $300,000 in restitution to affected patients. Beyond the dollar amounts, the agreement specifies a detailed payment timeline and places an affirmative obligation on ADMI to reach out to eligible patients. In cases where patients cannot be located after good-faith efforts, any remaining restitution funds are to be remitted to the Office of the California Attorney General for disbursement to the Victims of Corporate Fraud Compensation Fund.

Injunctive Terms

The heart of this settlement lies in its injunctive relief. Spanning 46 subsections, these terms reflect AG Bonta’s firm line on what dental support organizations can and cannot do when operating in California. The settlement includes unprecedented injunctive terms to protect California consumers and clinical staff, covering everything from clinical independence to advertising transparency. Among the key restrictions, ADMI must not:

• Replace any practice owner with a dentist of its own choosing
• Require practice owners to surrender their dental practices upon termination of their contractual relationship with ADMI
• Own the property used by any affiliated practice
• Practice dentistry, including owning or managing any dental office
• Base service fees on practice revenue, sales, or profits
• Suggest, direct, or encourage any licensed clinician, other than a practice owner,  to sell or increase revenue for any service or product
• Compensate its own employees based on practice sales or revenue
• Pay practice employees incentives tied to sales, revenue, profits, or the promotion of any particular service or product
• Enforce existing contractual provisions that restrict where licensed clinicians may practice or limit their ability to communicate with patients they have treated

ADMI is also required to register with the Dental Board of California as a Dental Group Advertising and Referral Service, provide written fee schedules for products and lab services, and clearly identify the practice owner’s name in all advertisements,  confer annually with the practice owner to negotiate the nature, scope, and service fees provided, among other provisions preserving the autonomy of practice owners over clinical and business decisions.

Compliance Provisions

Both the People and ADMI have mutually agreed to appoint an independent compliance monitor. The monitor will serve in this role for 36 months from the entry of the Judgment, the designated Oversight Period,  with all associated costs to be paid by ADMI.

Three months after entry of the Judgment, the monitor must deliver a status report to the parties. Six months following that initial report, the monitor must complete a second written report reviewing ADMI’s compliance with any remaining outstanding terms. Throughout the Oversight Period, ADMI is required to provide the monitor with reasonable access to all records and employees.

Why This Settlement Matters: The Bigger Picture for Corporate Practice of Dentistry

Prohibition on the corporate practice of dentistry, the legal principle that prohibits non-licensed entities from owning or controlling dental practices, has existed in California law for decades (Bus. & Prof. Code, § 1626). The underlying concern is straightforward: when business interests are permitted to direct clinical decision-making, patient care can suffer. Incentive structures tied to revenue, centralized operational control, and restrictions on clinician autonomy all create an environment where profit can quietly override professional judgment. A trend the state actively targeted on October 6, 2025, when Governor Gavin Newsom signed Senate Bill No. 351 to curb private equity and hedge fund ownership in healthcare. This settlement is significant because it represents California’s most aggressive enforcement of that doctrine to date, and it does so at a moment when private equity investment in dental and medical practices is at an all-time high.

Owned by private equity firms, ADMI describes itself as a dental support organization that provides business management and administrative services to dental offices. The AG’s position, however, is that ADMI crossed the line from support into control, and the breadth of the injunctive terms suggests the office intends to hold that line going forward. For other dental support organizations and management services organizations operating in California, this settlement functions as both a warning and a roadmap. The 46-subsection injunction effectively illustrates the specific practices regulators are watching for: revenue-based fee structures, clinician incentive programs, real property ownership, and other restrictive covenants designed to insert corporate control into the practice of dentistry, precisely what California has moved to prohibit in healthcare. Whether or not a given Dental Service Organization (“DSO”) ‘s operations mirror ADMI’s, this settlement signals that California is no longer content to let organizational structure alone determine the boundaries of corporate practice. What matters now is how control is exercised in practice, and the AG’s office has made clear it is paying close attention.