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Report of the Meeting of the Dental Board of California

August 10-11, 2017

Prepared for the California Society of Pediatric Dentistry

The Dental Board of California met August 10-11,2017, in Burlingame, California. The following report summarizes actions and issues coming before the Board pertinent to pediatric oral health


The Controlled Substance Utilization Review and Evaluation System (CURES) 2.0 is a database of Schedule II, III, and IV controlled substance and prescriptions dispensed in California. The goal of the CURES 2.0 system is the reduction of prescription drug abuse and diversion without affecting legitimate prescription practice or patient care. Legislation passed California in 2016 requires a health care practitioner to consult the CURES database to review a patient’s controlled substance history before prescribing a Schedule II, III, or IV controlled substance and at least once every 4 months thereafter if the substance remains part of the treatment of the patient.

All prescribers are required to submit a CURES application. Registration requirements are not based on dispensing, prescribing, or administering activities but, rather, only on possession of a Drug Enforcement Administration (DEA) Controlled Substance Registration Certificate. The Dental Board’s Enforcement Division will begin to include compliance with this requirement as part of its routine inspection activity when a complaint is under investigation. 

Comment: The Board reports that 24,633 California dentists are currently licensed to prescribe controlled substances under a DEA certificate. Only 7,882 have registered with CURES. A link to CURES 2.0 registration is available on the first page of Dental Board’s website (




Acting on the findings of an analysis by the Office of Professional Examination Services (OPES) of the Department of Consumer Affairs, the Dental Board in April voted to suspend administration of the Registered Dental Assistant practical examination as a condition for licensure. The analysis concluded that the practical examination failed to meet psychometric standards of reliability, test security and standardization while also questioning the practical’s necessity, accuracy and content validity. Specifically, OPES identified inconsistencies in different test site conditions, deficiencies in scoring criteria, poor calibration of examiners, and the lack of a clear definition of minimum acceptable competence. OPES estimated a low risk of harm to the public from the suspension of the examination because of other measures in place (i.e., passing a written examination and the fact that RDAs are under general or direct supervision of a licensed dentist). During the suspension of the practical examination, the Board will continue to license applicants who have not taken, or have not successfully passed, the practical examination, so long as all other requirements of licensure, including successful completion of the RDA Written Examination and the RDA Law & Ethics Examination, are met. Legislation (AB 1707) signed by the Governor in August extends the authority of the Board to suspend the practical examination to January 1, 2020, at which time a practical examination or an alternative means of measuring competency would be implemented.

Comment: The Board now needs to determine if a revised practical examination will be part of the RDA licensing process in the future (see next topic).




Acting on a request of the Dental Board of California, the Office of Professional Examination Services (OPES) conducted a comprehensive review of options to evaluate the competency of RDA candidates to perform the clinical procedures necessary for licensure. After consideration of numerous options, the OPES recommended the Board develop a licensing model that includes a combination of certified course work and dentist verification of minimal competency. The OPES was insistent that development of a valid, reliable, and legally defensible examination would be inordinately costly for both the Board and the candidate and fraught with ongoing problems. It cited the mandate from the California “Little Hoover Commission” to reduce all unnecessary barriers to licensure under the Boards and Bureaus of the Department of Consumer Affairs. The Board after lengthy discussion voted to accept the OPES recommendation to eliminate the RDA practical examination and to appoint a subcommittee to explore and develop an alternative to RDA licensure after January 1, 2020.

Comment: The OPES reported that practical examinations for dental assisting licensure are not used except in two states, one of which is California. It further asserted that reducing this “barrier to licensure” for RDA candidates would increase the likelihood of reciprocity with other states and ease the transition of RDAs trained in the military to working in civilian dental practices. It is presumed that an “on the job training” pathway will be maintained.




At its December 2016 meeting, the Dental Board and the Dental Assisting Council discussed combining the Registered Dental Assistant (RDA) general written examination and the RDA law and ethics examination into a single test to ease the path to licensure for RDA candidates. Such action was supported by the 2016 RDA Occupational Analysis by the Office of Professional Examination Services (OPES). Under a combined examination, candidates would only have to schedule and pay for one written examination instead of scheduling and paying for two such challenges. The examination plan is now available on the Board’s web site at

Comment: The Board estimates the single examination will be offered beginning May 2018. The change will not likely, in itself, increase pass rates (which are now only 62% for the RDA written exam and 65% for the RDA law and ethics exam), but at least will ease the candidate pathway.

Respectfully submitted,

Paul Reggiardo, DDS,
Public Policy Advocate, California Society of Pediatric Dentistry.

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