Every dentist in New York with a cone beam CT unit has heard there’s a 2028 deadline. There is one, but it’s not the one that matters right now. A separate set of requirements took effect on July 22, 2026, and it applies to your practice today — not in two years.
Your accreditation deadline. The 90-day window was never yours — that clock applies only to new CBCT users.
From first use to initiate accreditation, then 18 months to complete it. Operational requirements apply from day one.
The part that actually deserves your attention: Accreditation is only half of Section 16.65. The other half — equipment standards, a written QA program, annual quality control testing, dose documentation, staff training — took effect on July 22, 2026, and it doesn’t come with an 18-month grace period. It’s already the law.
New York’s revised radiation regulations, 10 NYCRR Part 16, added a new section — 16.65 — that governs how dental practices in New York operate cone beam CT (CBCT) equipment. It went into effect July 22, 2026.
Buried in the coverage of this rule is a single number: 90 days. It gets repeated so often that it’s easy to assume it applies to every practice with a CBCT unit. It doesn’t.
Most practices we talk to have this backwards. They’re tracking a 2028 date and haven’t looked at what’s already due.
If your first reaction to this rule was “since when does a dental CBCT unit need hospital-grade oversight” — you weren’t alone. In July 2026, the New York State Dental Association and NYSSOMS formally opposed the accreditation mandate before it was adopted, arguing that dental CBCT isn’t the same category of equipment as hospital CT, that no other state imposes this requirement, and that accreditation programs were designed around large institutions rather than solo and small-group dental practices.
The Department of Health adopted the rule anyway, and NYSDA has said it will keep monitoring how it’s implemented. Worth knowing: your professional association raised exactly the objection you’re probably having, and the requirement landed regardless. This isn’t a memo you missed.
Scope Check: Section 16.65 as written applies specifically to CBCT installations in dental offices — general dentists, orthodontists, endodontists, periodontists, and oral surgeons. It does not extend to ENT, podiatry, chiropractic, or imaging center CT units. If you’re a dental practice with a CBCT unit in New York, this rule is about you.
This is the checklist that matters right now, not in 2028. Since July 22, 2026, every dental practice operating CBCT in New York needs each of the following in place.
Must contain:
- Your facility's NYS registration identification number
Make and model of your CBCT unit
- Documentation that staff are trained in QC testing and patient care
- Name of your NYS-licensed medical physicist
- Your most recent physicist survey
- Physicist survey records retained for three years (paper or electronic)
- Preventive maintenance and service records, including any corrective actions taken
Including diagnostic-type protective housing, activation controls in a shielded area, visible signals when x-rays are on and off, an operator control to stop a scan mid-exposure, a clearly labeled emergency shutoff, and two-way visibility and communication with the patient during the scan.
Run per the manufacturer's specifications — or, if the manufacturer hasn't published any, a program built in consultation with a NYS-licensed medical physicist. Testing requires a manufacturer-specified phantom device and documented results.
Covering acceptance testing, calibration against a NIST-traceable dosimetry system, dose measurements (DAP or KAP), image quality metrics like resolution, noise, and scan accuracy, and a scatter measurement within 30 days of installation.
A daily equipment and safety check on any day CBCT is used, weekly checks on the image viewing system, and an ongoing log of repeat and rejected images with the reasons why.
Your physicist determines the typical dose for your most common exam types, for both adult and pediatric patients, annually. That figure has to be visible at the operator console and documented in the patient's record.
Covering radiation safety basics, your specific machine model, and how to read the display. Training records — initial and annual — need to be kept for three years and produced on request. (Who can operate the unit hasn't changed: unlicensed dental assistants trained on the manufacturer's protocol, registered dental assistants, and dental hygienists can all still take CBCT scans.)
Once the operational side is squared away, accreditation is the more contained project.
January 22, 2028
One Physics is the largest national provider of outsourced medical physics — more than 4,000 clients — but the work itself is local. A New York State-licensed medical physicist visits your practice, tests your equipment against the Section 16.65 requirements, and leaves you with documentation that reflects what the state, and any accrediting body, will actually ask to see.
The regulation requires a licensed medical physicist at several specific points: acceptance testing on new equipment, testing after any repair or software change that could affect dose or output, and testing every year after that. That survey becomes part of your QA file — and part of what an accrediting body will ask to see.
We built our reputation on the “local partner” half of that description as much as the “national provider” half. Your physicist knows New York’s requirements, shows up in person, and stays reachable after the survey — not a single visit and a PDF.
From initial site assessment through active program support, a structured engagement is designed around your timeline and regulatory requirements.
No. Accreditation isn't due until January 22, 2028 for practices that were already using CBCT before July 22, 2026 — but the QA program, QC testing, equipment standards, staff training, and dose documentation requirements are already in effect. Those aren't phased in. They're active now.
If you began using CBCT after July 22, 2026, you have 18 months to complete accreditation, but you're required to initiate that application within 90 days of starting to use the unit. You're also subject to the operational requirements — QA program, QC testing, equipment standards — from day one of use.
Yes. Section 16.65 covers CBCT installations in dental offices broadly, including general dentistry, orthodontics, endodontics, periodontics, and oral surgery. It does not apply to ENT, podiatry, chiropractic, or hospital/imaging center CT units.
Yes, this hasn't changed. Unlicensed dental assistants (after manufacturer training), registered dental assistants, and dental hygienists can all operate CBCT equipment under the new rule.
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