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CA Dental Board Report February 2015
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The Dental Board of California met February 26-27, 2015, in San Diego. The following report summarizes actions and issues coming before the Board pertinent  to pediatric oral health. CSPD is represented at each meeting of the Den- tal Board and updated  reports are posted in the Advocacy, Legislation and Regulatory Matters (ALARM) section of the CSPD  Website. Members having questions or comments should  contact  CSPD’s  Public  Policy  Advocate,  Dr. Paul Reggiardo, at


While the pass rate for the RDA written examination still hovers around 65 percent (71 percent for first time candidates), the pass rate for the practical examination dropped precipitously last year from over 90 percent to barely over 20 percent. This unacceptable situation was addressed by the Board at its December 2014 meeting and a subcommittee was appointed to explore potential solutions to a realistic practical examination process.
From that subcommittee came the recommendation, which the Board accepted, for an updated occupational analysis of the RDA and RDAEF professions. According to Department of Consumer Affairs policy, an occupational analysis and confirmation that the licensing examination for that profession reflects the tasks performed, and the abilities required to perform these tasks, should be performed at no less than a five year interval. The last RDA, RDAEF occupational analyses were conducted in 2009, when the RDA and RDAEF professions were brought under the umbrella of the Board. An updated occupational analysis would lay the foundation for a revised practical examination process that still aligns with the Board’s mission of public protection.

Comment: There appeared to be consensus at the December 2014 meeting of the Board that the largest contributing factor to the increased failure rate was the result of greater examiner calibration and resultant attention to clinical (typodont) performance. In other words, lack of minimal competency in tested clinical performance that was being overlooked in the past, is no longer being missed or ignored. A revised practical examination / practical examination process appears the best way to address this problem.

As part of the license renewal process, the Dental Board conducts random audits of continuing education (CE) compliance. Dentists are required to certify under penalty of perjury that they have completed the requisite number of continuing education hours, including any mandatory courses, since their last renewal on the licensure application. Licensees are required to maintain documentation of successful completion of eligible coursework for no fewer than three renewal periods and, if audited, they are required to provide that documentation to the Board upon request. A dentist who is not able to provide proof of the required CE hours may be issued a citation with a fine. The citation also includes an abatement condition requiring the licensee to complete the deficient number of credits within a specified time period. These units are in addition to the credits required for the next renewal cycle. A licensee who fails to pay the fine or comply with the citation’s abatement may be referred for discipline and his/her license may be suspended or revoked. The Board audits about five percent of the license renewal requests.

On January 1, 2015, Board staff began conducting random continuing education audits of its dental licensees three months prior to their renewal expiration date. To avoid a hold being placed on the license renewal, licensees must submit CE certificates for the previous three renewal cycles as required under the California Code of Regulations. Since the inception of the program, Board staff identified the following problems:
• Licensees are failing to keep records for three renewal periods.
• Licensees are claiming classes that do not qualify for CE credit under Dental Board regulations and were never issued valid certificates of course completion.
Conducting the CE audits has also permitted the Board to review how Continuing Education Providers are maintaining their records and compliance with the issuance of certificates as follows:
• Continuing Education Providers are not always in compliance with the requirements of certificates they issue. Items such as the course number, licensee name and license/ permit number, the number of units earned, and the eleven digit course registration number are often missing.
• Providers are not submitting to the Board biennial reports as required.
• Mandatory courses, Infection Control and Dental Practice Act, are not always current with the new Laws and Regulations.
• Per the California Code of Regulations, eight units are the maximum continuing education credits that may granted in one day. Providers who provide home study courses often use the date they receive the materials from the licensee as the date of attendance on the certificate, often for multiple courses. As a result, licensees have submitted CE certificates showing that they are attending more than eight hours per day.

As a result, the Board directed staff to begin conducting random audits of Continuing Education Registered Providers for compliance with all regulations required under their permits.

Comment: AAPD, as a Registered California Continuing Education Provider, has been in full compliance with the regulations.

California’s Licensure by Credential pathway provides that a dentist holding a current dental license in another state that is not revoked, suspended or otherwise restricted, and meeting certain practice experience requirements, may be granted a California dental license. In recent years, the Board has come under pressure from the dental schools to grant a California license to dentists holding a specialty license in another state and a full-time faculty appointment. Under current statute, a specialty license is considered a “restricted license,” which disqualifies the applicant from the Licensure by Credential pathway.

In an effort to accommodate the schools, which contend that the lack of a licensure by credential pathway hampers faculty recruitment, the Board last August began investigation of potential solution that would satisfy the schools and maintain public protection. Finding the issue mired in both regulatory and statutory constraints, the Board moved to appoint a subcommittee to work with staff to look at whether to pursue clarification of the Licensure by Credential Application requirements by statute, regulations, or both.

Comment: The issue is potentially explosive in that it could open consideration of specialty dental licensure in California, something opposed by CSPD (and AAPD).

In response to what is generally acknowledged as a national epidemic of prescription drug abuse, the Dental Board continues exploring what actions it might take to address the problem as it pertains to California’s dental prescribers. In a related action, in October the Medical Board of California approved revision of its Guidelines for Prescribing Controlled Substances for Pain for release to medical licensees. After reviewing the medical guidelines, the Prescription Drug Abuse Committee voted to appoint a subcommittee to draft guidelines for Prescribing Controlled Substances in Dental Practice for consideration of the Board.

Comment: In California, most licensed physicians are required to take, as a one-time requirement, 12 hours of Continuing Education (CE) on pain management and the appropriate care and treatment of the terminally ill. At present, the Dental Board has no similar requirement, but the Board may consider a CE option in the future.

In December 2014, the Dental Hygiene Committee of California (DHCC) voted to initiate a rulemaking process relative to definitions of dental hygiene terms. Statute requires that recommendations made by the DHCC regarding scope of practice issues must be approved, modified, or rejected by the Dental Board of California. Upon receipt of notification of the proposed language, the Board appointed a subcommittee to review the modified definitions. The subcommittee subsequently recommended four changes, which the Board moved to accept.

Comment: CDA contends that Board’s actions must be accepted by the DHCC and not treated as an advisory opinion. In short, this becomes a jurisdictional issue. The DHCC contends that it has the authority to modify the definitions and CDA contends that all authority of dental hygiene scope of practice rests with the Dental Board of California. This issue has yet to be resolved.

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