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  Home  About Us State Unit Leadership Membership Information Latest News Calendar of Events Links CSPD Foundation Advocacy, Legislation and Regulatory Matters Find a Pediatric Dentist Leadership Development Members Only Online Continuing Education Professional Opportunities Contact Us of the American Academy of Pediatric Dentistry  |
 
CSPD Provides School Absence Information and Assistance
Dentists, and pediatric dentists in particular, are often challenged by parents anxious to avoid school absence, even when that absence is for the purpose of health care delivery. Although most practitioners establish scheduling policies and protocols intended to minimize pupil absence in a manner consistent with the patient’s age, the nature of the service provided, and fairness to all families in the practice, many are still confronted with school policies that seem or profess to prohibit absence from school for the delivery of dental care during school hours. As pediatric dentists, we recognize the importance of regular school attendance and the effect on education of chronic absence. We also recognize the negative financial implications to the school from the state when daily attendance is reduced. For these reasons, we have long urged our members to work with parents and with schools to minimize attendance disruption for oral health services ----- and better oral health through regular preventive care visits is one strategy for accomplishing this goal. It is not realistic, however, to expect that all pediatric and adolescent oral health care services can be delivered outside of school hours. In fact, state law [California Education Code §48205(a)(3)] specifically provides that "a pupil shall be excused from school when the absence is for the purpose of having medical, dental, optometrical, or chiropractic services rendered." In an effort to provide clarity on this issue to dentists, parents, and school educators, the California Society of Pediatric Dentistry has joined with the California Dental Association to provide a downloadable Message to Parents and School Administrators Regarding School Absence for Dental Appointments. This one-page information sheet, which contains Oral Health Facts for Children, may be downloaded from the CSPD and CDA websites for printing and distribution by dentists and their staffs. In addition, CSPD has developed a template for a School Attendance Release Form which may be downloaded from the CSPD website and customized by members for individual office printing and distribution (This is a MS Word doc file). The form contains reference to §48205(a)(3) of the Education Code. Mobile/Portable Dental Care Provider GuidelinesIn an effort to assist school districts approached by mobile/portable dental care providers, a statewide group of dental and education professionals, led by the California Dental Association and the Dental Health Foundation have developed a series of documents intended to give school decision-makers some tools and ideas to help make the best choice for a particular situation. Return to Top
California Legislature 2011-12
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| SB 694 (Padilla) | Dental Care Access - As amended, the bill would replace the current dental program within the State Department of Public Health with a Statewide Office of Oral Health, headed by a State Dental Director. It would authorize the Office to design and implement a rigorous scientific study on the safety, quality, cost-effectiveness and patient satisfaction of irreversible dental procedures performed by traditional and non-traditional providers in specified settings and levels of supervision for the purpose evaluating future decisions relating to scope of practice changes. The establishment of the Office and the scientific study are both dependent on the securement of federal and private funding. |
| CSPD Position: | Support In Principle- (unrestricted support pending development by amendment of the bill the details of the proposed scientific study and other relevant elements) |
| Comment: | CDA's Government Affairs Council has determined all provisions of SB 694 are entirely consistent with CDA policies and the 2011 House of Delegates resolutions concerning access proposals and workforce models. SB 694 neither establishes nor permits a new licensed provider; the training and performing of irreversible/surgical procedures by non-dentists may occur only within the confines and parameters of the research study. Until compelling data on the quality, safety, patient-satisfaction and cost-effectiveness of irreversible/surgical procedures performed by non-dentists is available for analysis which would indicate that this model would reduce barriers to care and meet those other criteria, CDA opposes any such scope of practice changes. |
The Dental Board of California met November 7-8, 2011, in Studio City. The following summarizes actions and issues coming before the Board pertinent to pediatric oral health.
Return to TopPathways to Dental Licensure
With the passage of legislation in 2004 that established a pathway to California dental licensure by passage of the Western Regional Examination Boards (WREB), demand for the clinical examination administered by the Dental Board of California has all but disappeared and the examination is no longer offered. Current pathways to California Licensure are listed below:In addition, all applicants must undergo a criminal background check and have a Social Security number before a license may be issued.
- WREB Clinical Examination (2004) - Applicants must have graduated from an approved dental program or have previously passed the Board's restorative technique exam and must pass the Western Regional Examination Board's clinical exam and pass the California Law and Ethics examination.
- Licensure by Residency (LBR) (2006) - Applicants must have graduated from an American Dental Association Commission on Dental Accreditation (CODA) accredited dental program and completed at least one year of postgraduate education in an approved Advanced Education in General Dentistry or General Practice Residency and pass the California Law and Ethics examination.
- Licensure by Credential (2002) - Applicants must have been licensed in another state for at least 5 years and provide documentation of at least 5,000 hours of clinical practice in the preceding 5 of 7 years, or agree to at least a two year contract with an approved dental program in California as an instructor, or practice in a public health clinic in an underserved area as designated by Office of Statewide Health Planning and Development (OSHPD).
- A fourth pathway, Portfolio Examination, is in development for the future. The Portfolio examination will assess a California dental student's experiences within the clinic settings of his or her dental program as the measure of competence for issuance of a California dental license.
Comment: Licensing statistics for 2010 and 2011 are as follows:
At its peak, the California examination was administered to approximately1,500 candidates annually. The reduced number of candidates taking the WREB examination in California reflects the number of out-of-state candidates preferring to take the WREB exam in other states or obtain the California license by one of the alternate pathways.
Pathway Issued in 2010 Issued in 2011 Net Issued to Date Pathway Implemented California Exam 0 0 53,977 Prior to 1929 WREB Exam 558 664 4,022 2006 LBR 159 182 694 2007 LBC 131 162 2,226 2002 LBC Clinic Contract 3 4 23 2002 LBC Faculty Contact 0 0 3 2002 Licensure by Portfolio Pathway
AB 1524, passed by the legislature in 2010, creates a new format of clinical licensure examination for students enrolled in a California dental school, commonly referred to as a "portfolio examination." The Board is now charged with implementing the law by developing standardized criteria for the assessment of the applicant's competency, training and calibration of examiners, and the process by which the Board will independently monitor and audit the portfolio examination. The Board has contracted with COMIRA, a commercial testing provider, to assist in the development of the regulations and in the creation of an applicant application and candidate handbook, selection criteria for each school's competency examiners, and to ensure the process is suitable for statistical outcome analysis.As part of the process, COMIRA created six work groups (Oral Diagnosis and Treatment Planning, Endodontics, Removable Prosthodontics, Periodontics, Indirect Restorations, and Direct Restorations) recruited from each of the six California dental schools to define the purpose and testing criteria of each competency section. These representatives were selected by the Associate Dean of their respective schools and fields. The drafts of the work products of each of the groups will next be reviewed by the faculty and administration of the schools.
Comment: The Board initially indicated that the process to develop regulations would include a series of focus groups assembled by the Board to develop the specific examination criteria for each clinical area to be assessed. Instead, the Board has ceded to the process recommended by COMIRA. CSPD and other stakeholders / parties of interest will have opportunity to comment upon and influence the final product once draft regulations are released and the regulatory process initiated.
If the process runs smoothly, the first candidates for licensure by portfolio could be evaluated in 2013. A more likely date is in 2014.Registered Dental Assistant Written Examination Statistics
In July of 2009, with the dissolution of the Committee on Dental Auxiliaries (COMDA), responsibility for the licensing of Registered Dental Assistants (RDA) passed to the Dental Board of California. The 2009 pass rate for the RDA written examination barely exceeded 50%. Utilizing a new written examination, the pass rate increased last year to 61%. For 2011the pass rate for the RDA examination is as follows:
Examination Type Candidates Pass Rate RDA Written Exam First Time Candidate 1,421 77% RDA Written Exam Repeat Candidate 571 55% RDA Practical Exam First Time Candidate 1,594 88% RDA Practical Exam Repeat Candidate 310 66% Comment: The pass rate for the RDA Law & Ethics examination is very similar. The numbers for the new Orthodontic Assistant and Dental Sedation Assistant examinations (59% and 72% respectively) are too small as yet to be statistically significant.
Still to be addressed is the discrepancy between the overall pass rate of those qualifying for the RDA examination by a formal educational program (64%) and those by on-the-job training (45%). Candidates qualifying through the work experience pathway are not exposed to the same content and variety of training materials as those who go through the educational process. The Board will explore the possibility of providing feedback reports to failing candidates and posting a comprehensive RDA candidate handbook or online information bulletin.Fingerprinting Requirement for Licensees
Since July 1, all licensees for whom no fingerprint record exists at the Department of Justice (DOJ) have been required to submit evidence they have completed a Live Scan fingerprint data-entry process as a condition of license renewal. The requirement includes dentists as well as licensed auxiliary categories and is generally affects those originally licensed before 1986. The DOJ has provided the Board with a list of all licensees for whom no record of fingerprinting exists and the Board began notifying licensees in May whose pending renewals are be affected by this requirement. Information, including Frequently Asked Questions, has been placed on the Board's website.Comment: The Board estimates approximately 18,000 dentists and a like number of RDA and RDAEF licensees are affected by the requirement. Compliance by dentists has been excellent, slightly less so for dental auxiliaries.
Posting Notice to Consumers of Licensure by the Dental Board
Senate Bill 540, signed by Governor Brown September 30, 2011, requires the Board to adopt regulations that require a licensed dentist engaged in the practice of dentistry to provide notice to each patient of the fact that he or she is licensed and regulated by the Dental Board of California and require the notice contain the Board's toll-free telephone number and Web site address. To meet this requirement, the Board instructed staff to draft regulations that would specify the notice be provided by one of the following methods:
- Prominently posted in an area visible to patients on the premises where services are provided in at least 48-point type
- Included in a written statement, signed and dated by the patient or patient's representative and retained in the patient's dental records, stating the patient understands the dentist is licensed and regulated by the Board
- Including the notice in a statement on letterhead, discharge instructions, or other document given to a patient or the patient's representative, where the notice is placed immediately above the signature line for the patient in at least 14-point type.
Comment: The statute requires that regulation be adopted by January 1, 2013.
The California Society of Pediatric Dentistry in collaboration with the California Dental Association has produced an advocacy binder dramatically illustrating The Consequences of Untreated Dental Disease in Children.
Designed for supporting CDA and CSPD efforts in promoting legislation and public policy which improve children’s oral health, the binder contains introductory information on the progressive and largely preventable nature of dental disease, full color illustrations of untreated pediatric dental conditions, and a Children’s Oral Health Fact Sheet
The binder is available for viewing and for downloading by CSPD members. (PDF Document, 1.2 MB)
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Groundbreaking legislation effective January 1, 2007 requires children entering public school for the first time in either kindergarten or first grade to present proof by May 31 of the school year of having obtained an oral health assessment. That assessment may be completed during the first year of school or any time in the 12 months prior to school enrollment.
CSPD, working with the California Dental Association, has long sought such regulation as a means of identifying children in need of oral health services and promoting the importance of oral health as an integral component of school readiness and ability to learn.
Dentists should be aware of the following provisions of the bill:
It is important for dentists to understand the difference between a dental examination, which can be performed only by a licensed dentist, and an oral health assessment, which can be performed by a range of licensed dental professionals. An oral health assessment identifies obvious or suspected oral health conditions that require, or might require, examination by a dentist. A dental examination diagnoses dental conditions and forms the basis for treatment recommendations.
A dental examination conducted in a dental office during the first school year or in the 12 months prior to school enrollment more than meets the minimum standards of the assessment requirement.
The goal of this legislation is to establish a regular source of dental care (a dental home) for every child. The program will also identify children in need of further examination and dental treatment and will help in the identification of barriers to the delivery of dental care.
For additional information all located on this page, please use the appropriate links:
Questions concerning California Oral Health Assessments may be directed to CSPD Public Policy Advocate, Dr. Paul Reggiardo, at Reggiardo@prodigy.net or by phone at 714-848-0234.
Return to TopWhat Does the Law Require?
What is an Oral Health Assessment?
The assessment, or evaluation, can be met in many ways. It can be a complete examination and treatment plan performed by a dentist, or it can be a more basic oral health evaluation, such as a screening, which can be performed by a dentist, hygienist or a registered dental assistant with supervision.
How should an office respond when a parent calls requesting the required "oral health assessment" for their child?
If the child is already a patient of record, it should be a routine matter to schedule a dental examination for the child. The oral health assessment requirement is not intended to alter your usual office protocol with regard to new or recall examinations. The only "new" part of the visit is completion of the required "assessment form." The form is simply a data collection tool and requires information on the following four items:
How should an office respond when the parent of a new patient calls making the same request?
As with all new patients, the child ideally should receive a comprehensive examination. In some instances, however, it may be a multi-step process before a child receives the desired exam. It is therefore important to develop a protocol when the parent questions the need to make an appointment for an examination, citing the request for "just an assessment."
Many factors may contribute to the parent's decision to schedule the recommended examination, including available insurance coverage, the parents' understanding of the difference between an assessment and an examination, and the parents' expectation that an assessment, or basic screening, is all the child needs. An office protocol should include a clear explanation of the differences between a basic screening and a comprehensive examination, so that the parent can make an informed decision.
If, after explaining the value of a comprehensive dental examination, the caller still requests only a screening assessment to meet the basic requirements of law, how might the office proceed?
When a dental examination is not feasible, the child will still benefit from the simple assessment intended to identify obvious unmet oral health needs and to provide a data collection tool for state-wide oral health planning. Therefore, CSPD encourages members to consider offering to screen the child and complete the mandated assessment form in the office without charge.
Under legislation long sought by CSPD and effective January 1 of this year, children enrolled in their first year of public school in either kindergarten or first grade are now required to obtain an assessment of their oral health as part of school readiness preparation. For children who already see a dentist and have established a dental home, compliance will be as simple as calling the office and requesting that the dentist fill-out and return the data collection form sent home by the school. Any dental examination conducted in the 12 months prior to the beginning of the school year will meet the assessment requirement, although dentists may wish to recommend a more recent examination when indicated in the best interests of the child. Parents have until May 31st to return the State’s data collection form to the school. While many schools districts are placing school information at the top of the form, dentists and parents may download and use the form available from the California Department of Education. A link to the California Department of Education website and a direct link to downloadable English and Spanish versions of the form are now available on the CSPD website (www.cspd).
For children who have not received a dental examination in the twelve months prior to school entrance, parents have several options. They may schedule a dental examination with a licensed dentist, they may arrange an oral assessment or screening evaluation by any licensed dental professional (a dentist, dental hygienist, or registered dental assistant under the direct supervision of the dentist), or they may request a waiver of the requirement. CSPD members have the opportunity to play a critical role in which decision is made by the parent.
The best decision for the child, and a significant intent of the legislation, is the establishment of a dental home through the scheduling of a comprehensive dental examination. When this is not possible or feasible, CSPD urges its members to consider providing a screening assessment in their office as a public service. It is important for both dentists and parents to understand the difference between a dental examination, which is a billable service and establishes the dental home, and a screening assessment which is not considered a billable service and only (1) collects the data required by the state concerning the incidence of treated and untreated dental caries and (2) identifies obvious or suspected conditions which require, or might require, examination and treatment by a dentist.
If a screening evaluation is conducted in the dental office it does not establish a dentist-patient relationship. Patients receiving such assessments do not become a patient-of-record and should not be expected to complete health histories or other office forms. To assist members providing these assessments, CSPD and CDA have developed a Consent and Recommendation Form for use in the dental office. The form provides for the consent of the parent or caregiver, explains the limitations and differences between an oral assessment and a comprehensive oral/dental examination, and provides a section in which the dentist can make recommendations concerning the child’s oral health. The form, in multiple languages, is downloadable from the CSPD website (www.cspd). It should be given to the parent or caregiver, along with the State data collection form, and a copy kept in the office for a period of one year. Oral evaluations performed in the dental office help parents meet the school requirement and serve as an introduction to the dental delivery system.
CSPD anticipates may school districts, especially those most impacted by oral health disparities, will work with local dentists and local component dental societies to establish school-based and school-linked oral health screenings to ensure pupils receive these assessments. Such screenings will provide an additional opportunity to create effective systems of triage and referral of children whose families experience barriers to dental care and the establishment of a dental home. CSPD encourages the participation of its members in these activities as well as in providing in-office assessments.
Ultimately, the success and survival of school-entrance oral health examinations and assessments will be judged by public compliance with the legislation. Parents may receive a waiver of the requirement by indicating the assessment poses an undue financial burden, cannot be completed because they are unable to locate a dental professional to perform the assessment, or by simply withholding consent. By facilitating the examination and assessment process, CSPD members make it less likely a parent will choose to use the waiver.
Paul Reggiardo, DDS
Public Policy Advocate
California Society of Pediatric Dentistry
February, 2007
| CSPD/CDA Developed In-Office Consent for Assessment and Recommendations |
State Required Oral Health Assessment-Waiver Forms |
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The state-required oral assessment form to be returned to the school is a simple data collection tool that requires the following four pieces of information.
The California Department of Health Care Services has announced by the enclosed Notice of Proposed Rulemaking intention to adopt the 2009-10 CDT procedure code set for Denti-Cal claims processing, replacing the outdated 2002 CDT 4 code set used now. This "administrative simplification" will make Denti-Cal claims processing compatible with current dental practice management systems.
Download this Notice of Proposed Rulemaking.
The California Society of Pediatric Dentistry joins with other state health care and patient advocacy organizations in opposing elimination of adult dental services under the state Medi-Cal program. Oral health is integral to general health and not an optional health service. Eliminating adult dental care will have a profound adverse effect on low-income adults, will immediately increase the cost of emergency medical services delivered in hospitals and physician's offices, and will ultimately result in greater future obligations to the state's general fund as oral conditions worsen without appropriate care. Children served by Medi-Cal will be affected as well:
Members interested in CSPD's public policy stance may view the letters sent to Senate President proTem Darrell Steinberg and Speaker of the Assembly Karen Bass during state budget negotiations.
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On March 1 of this year, the California Department of Health Care Services (DHCS) implemented mandatory CDT-4 coding for all treatment authorization requests and claims submissions. CSPD member Jose Polido of Children's Hospital Los Angeles contacted CSPD recently to ask why CDT code D0140, defined by the ADA as a Limited Oral Evaluation -- Problem Focused, for situations of "emergency and trauma," is routinely denied by Denti-Cal when used for this purpose.
As indicated in the Medi-Cal Dental Program Provider Handbook (March 2008), Denti-Cal uses D0140 not for the broad range of problem-focused cases as specified by the ADA code, but instead, for payment of an initial orthodontic evaluation by a Medi-Cal Dental Program certified orthodontist.
According to a representative of the Department of Health Care Services, because orthodontic services are not generally a benefit of the Denti-Cal program, unless required by the Early Periodic Screening, Diagnosis, and Treatment (EPSDT) medical necessity provisions of the Medicaid act (such as in the delivery of care for cleft lip and palate), the Department needed a CDT-4 diagnostic code for assessing such qualification. They choose D0140.
When asked, therefore, what code was appropriate and payable when a limited oral evaluation of emergency or trauma was provided [and other evaluation codes such as that for comprehensive oral evaluation (D0150) or periodic oral evaluation (D0120) were either inappropriate or unavailable], the DHCS representative suggested that for "problem focused" evaluations, providers should use D9430, which is defined in the Handbook as a catch-all, general "observation" code during regularly scheduled office hours in which no other services are performed (other than necessary radiographs and/or photographs).
Members should be aware, however, that Denti-Cal billing for D9430 requires "written documentation for payment" that "shall include the tooth/area, the chief complaint and the non-clinical treatment taken."
If, under the above DHCS guidelines, members experience claim denials, they are requested to contact CSPD's Public Policy Advocate, Paul Reggiardo, at 714-848-0234 or at Reggiardo@prodigy.net with the detail.
Return to TopWhen is coronal polishing considered an oral prophylaxis? The answer, of course, under the California Dental Practice Act, is never.
Section 1086 of the California Code of Regulations permits a Registered Dental Assistant to perform coronal polishing subject to certain conditions. One of these conditions is that the procedure must be performed under the direct supervision of a licensed dentist and only pursuant to the order, control and full professional responsibility of that supervising dentist. Under the provisions of direct supervision, the procedure must be checked and approved by the dentist prior to dismissal of the patient from the office. The Act states that "this procedure shall not be intended or interpreted as a complete oral prophylaxis (a procedure which can be performed only by a licensed dentist or registered dental hygienist)" and that the licensed dentist or a registered dental hygienist "shall determine that the teeth to be polished are free of calculus or other extraneous material prior to coronal polishing."
Section 1067 defines coronal polishing as a "procedure limited to the removal of plaque and stain from exposed tooth surfaces, utilizing an appropriate rotary instrument with rubber cup or brush and a polishing agent."
An oral prophylaxis is defined in the same section as "preventive dental procedures including complete removal of explorer-detectable calculus, soft deposits, plaque, stains, and the smoothing of unattached tooth surfaces. The objective of this treatment shall be creation of an environment in which hard and soft tissues can be maintained in good health by the patient."
Only a currently-licensed Registered Dental Assistant (RDA) may perform coronal polishing, which is considered part of an oral prophylaxis. Since January 1, 2006, all Registered Dental Assistants have been required to have completed an approved course in coronal polishing to obtain or renew their licenses.
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The California Society of Pediatric Dentistry is the state's leading advocate for the optimal oral health of infants, children, and adolescents, including those with special needs. The Society serves its members and represents the specialty of Pediatric Dentistry in California to achieve excellence in practice, education, and research.