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January 29, 2004, Meeting of COMDA

Agenda
Agenda Item Information
Minutes

Agenda

Notice of PUBLIC MEETING - Notice is hereby given that a public meeting of the Committee on Dental Auxiliaries will be held as follows

January 29, 2004 - 9:00 a.m.

Sacramento Marriott Rancho Cordova, 11211 Point East Drive, Rancho Cordova - 916-638-1100

Agenda

1. Call to Order/Roll Call/Establishment of Quorum
2. Approval of November 6, 2003, Meeting Minutes
3. Report of the Chair
4. Report of the Executive Officer
5. Legislation of Interest to COMDA
     a. AB539 – 3rd and 4th year dental students applying for RDH licensure

RDA Program
6. Review of RDA Educational Programs and Courses/Recommendations to Board
7. Proposed New Regulation 1070.3 – Approval of Pit and Fissure Sealant Courses
8. Proposed Changes to Regulation 1081.1 – RDA Practical Examination Requirements
9. Proposed Changes to Business and Professions Code Section 1645.1 – Required Coronal Polishing and Radiation Safety Courses for RDAs
10. Proposed Changes to Regulations 1014 and 1014.1 – Approval of Radiation Safety Programs
11. Teaching Methodology Course for RDA Educational Program Faculty

RDHAP Program
12. Consideration of RDHAP Educational Program Application of UOP

All Programs
13. Agenda Items for Future Meetings
14. Establishment of Future Meeting Dates
15. Public Comment

16. Adjournment

The Committee may take action on any item listed on the agenda unless listed as information only. All times are approximate and subject to change. Public comments will be taken on agenda items at the time the specific item is raised. Items may be taken out of order to accommodate speakers and to maintain a quorum. The meeting may be cancelled without notice. For meeting verification, call (916) 263-2595 or access the Committee’s website at www. comda. ca.gov. The meeting is accessible to the physically disabled. A person who needs disability-related accommodations or modifications in order to participate in the meeting shall make a request to the Committee by contacting Karen Wyant at (916) 263-2300 or sending a written request to the person at the Committee on Dental Auxiliaries, 1428 Howe Avenue, Suite 58, Sacramento, CA 95825, one week prior to the day of the meeting. Contact: Karen Wyant, (916) 263-2595 or email Karen_Wyant@dca.ca.gov.


AGENDA ITEM INFORMATION

5. Legislation of Interest to COMDA

a. AB539 – 3rd and 4th year dental students applying for RDH licensure

AB539 would allow 3rd and 4th year California dental school students in good standing to apply for a Registered Dental Hygienist license, which would require completion of the National written examination and the State clinical examination. It was amended before leaving the Assembly to provide that a successful applicant may only practice in a dental practice that serves patients who are insured under Denti-Cal, the Healthy Families Program, or other governmental programs, or a dental practice that has a sliding scale fee system based on income.

However, the language is unclear as to whether the practice, for example, need only serve one person in one of the designated classes per year, or a majority of time, or exclusively.

In the Senate, the bill was amended to require that the examination fee for such applicants not exceed the actual cost of the examination.

The bill was placed on the inactive file by the author this year, and may be restored to active status as a two-year bill when the Legislature reconvenes in January. The status of the bill will be reported at the meeting.

As requested by members at the November COMDA meeting, attached is information provided by both the California Dental Association (CDA) and the California Dental Hygienists Association (CDHA) regarding the comparison between dental hygiene education received by 3rd and 4th year dental students and that received by dental hygiene program graduates.

6. Review of RDA Educational Programs and Courses

Staff and consultants have reviewed the curriculum and conducted an on-site evaluation of the following proposed full RDA educational program, and it is recommended that COMDA recommend provisional approval to the Board. COMDA staff and consultants then perform another on-site inspection of the program at a later date to assure that it is operating appropriately, and then make a recommendation as to whether the program should be granted full approval.

a. Silicon Valley College, Fremont

Any other programs or courses that are ready for consideration by the meeting date will be presented at the meeting.

7. Proposed New Regulation 1070.3 – Approval of Pit and Fissure Sealant Courses

In July, the Board voted to amend regulation section 1086 to allow RDAs to apply pit and fissure sealants if they have completed a Board-approved course.

At COMDA’s November meeting, a regulation was proposed to define the requirements that such courses must meet to obtain approval from the Board. It was decided to establish a subcommittee to review and finalize the proposal. After the meeting, it was determined that it would be more timely and save money if comments were collected informally and compiled for COMDA to consider at its next meeting.

Vice Chair Drury-Klein was designated by the Chair to coordinate this effort. Attached is the original proposal, with strike-out and underline indicating consensus changes collected from the comments submitted. Also attached are comments received from only single individuals, which are not reflected in the revised proposal.

The format generally follows the regulations that govern full RDA educational programs, which were recently substantially amended.

____________

Proposed New Regulation 1070.3: Approval of Pit and Fissure Sealant Courses

1070.3 Approval of Pit and Fissure Sealant Courses.

The following minimum criteria shall be met for a course in the application of pit and fissure sealants to secure and maintain approval by the Board.
   (a) Educational Setting. The course shall be established at the post-secondary educational level.
   (b) Prerequisites. Each student must possess the necessary requirements for application for RDA licensure or currently possess an RDA license. Each student must have already completed a Board-approved course in coronal polishing.
   (c) Administration/Faculty. Adequate provision for the supervision and operation of the course shall be made.
       (1) The course director and each faculty member shall possess a valid, active, and current RDAEF, RDH, RDHEF, RDHAP, or dentist license issued by the Board, or an RDA license issued by the Board if the person has completed Board-approved courses in coronal polishing and the application of pit and fissure sealants. All faculty shall have been licensed for a minimum of two years. All faculty shall have the educational, background, and occupational experience and/or teaching expertise necessary to teach, place, and evaluate the application of pit and fissure sealants. All faculty responsible for clinical evaluation shall have completed a two hour methodology course in clinical evaluation.
       (2) The course director must have the education, background, and occupational experience necessary to understand and fulfill the course goals. He/she shall actively participate in and be responsible for the day-to-day administration of the course including the following:
            (A) Providing daily guidance of didactic, laboratory and clinical assignments.
            (B) Maintaining for a period of not less than 5 years:
                 (1) Copies of curricula, course outlines, objectives, and grading criteria.
                 (2) Copies of faculty credentials, licenses, and certifications.
                 (3) Individual student records, including those necessary to establish satisfactory completion of the course.
            (C) Informing the Board of any changes to the course content, physical facilities, and/or faculty, within 10 days of such changes.
   (d) Length of Course. The program shall be of sufficient duration for the student to develop minimum competence in the application of pit and fissure sealants, but shall in no event be less than 16 clock hours, including at least 4 hours of didactic training, at least 4 hours of laboratory training, and at least 8 hours of clinical training.
   (e) Evidence of Completion. A certificate or other evidence of completion shall be issued to each student who successfully completes the course.
   (f) Facilities and Resources. Facilities and class scheduling shall provide each student with sufficient opportunity, with instructor supervision, to develop minimum competency in applying pit and fissure sealants. Such facilities shall include safe, adequate and educationally conducive:
      (1) Lecture classrooms. Classroom size and equipment shall accommodate the number of students enrolled.
      (2) Operatories. Operatories shall be sufficient in number to allow a ratio of at least one operatory for every five students at any one time.
          (A) Each operatory shall replicate a modern dental office containing functional equipment including: a power-operated chair for treating patients in a supine position; operator and assistant stools; air-water syringe; adjustable light; oral evacuation equipment; work surface; hand-washing sink; curing light, and all other armamentarium required to instruct in the application of pit and fissure sealants.
          (B) Each operatory must be of sufficient size to accommodate a practitioner, a student, an instructor, and a patient at one time.
      (3) Laboratories. The location and number of general use equipment shall assure that each student has the access necessary to develop minimum competency in the application of pit and fissure sealants. Protective eyewear is required for each piece of equipment.
      (4) Infection Control. The program shall establish written clinical and laboratory protocols to ensure adequate asepsis, infection and hazard control, and disposal of hazardous wastes, which shall comply with the board's regulations and other Federal, State, and local requirements. The program shall provide such protocols to all students, faculty, and appropriate staff to assure compliance with such protocols. Adequate space shall be provided for preparing and sterilizing all armamentarium.
      (5) Emergency Materials/Basic Life Support.
           (A) A written policy on managing emergency situations must be made available to all students, faculty, and staff.
           (B) All students, faculty, and staff involved in the direct provision of patient care must be certified in basic life support procedures, including cardiopulmonary resuscitation. Re-certification intervals may not exceed two years. The program must document, monitor, and ensure compliance by such students, faculty, and staff.
   (g) Program Content.
       (1) Sufficient time shall be available for all students to obtain laboratory and clinical experience to achieve minimum competence in the various protocols used in the application of pit and fissure sealants.
       (2) A detailed course outline shall be provided to the board which clearly states curriculum subject matter and specific instruction hours in the individual areas of didactic, laboratory, and clinical instruction.
       (3) General program objectives and specific instructional unit objectives shall be stated in writing, and shall include theoretical aspects of each subject as well as practical application. The theoretical aspects of the program shall provide the content necessary for students to make judgments regarding the application of pit and fissure sealants. The course shall assure that students who successfully complete the course can apply pit and fissure sealants with minimum competence.
       (4) Objective evaluation criteria shall be used for measuring student progress toward attainment of specific course objectives. Students shall be provided with specific unit objectives and the evaluation criteria that will be used for all aspects of the curriculum including written and practical examinations. The program shall establish a standard of performance that states the minimum number of satisfactory performances that are required for each procedure.
       (5) Areas of instruction shall include at least the following as they relate to pit and fissure sealants:

(A) Dental Science - Oral Anatomy, Histology, Physiology, Oral Pathology, Normal/Abnormal Anatomical and Physiological Tooth Descriptions
(B) Morphology and Microbiology
(C) Dental Materials and Pharmacology
(D)Sealant Basics

i. Legal requirements
ii. Description and goals of sealants
iii. Indications and contraindications
iv. Role in preventive programs

(E) Sealant Materials

i. Etchant and/or etchant/bond combination material composition, process, storage and handling
ii. Sealant material composition, polymerization type, process, storage and handling
iii. Armamentaria for etching and sealant application
iv. Problem solving for etchant and sealant material placement/manipulation

(F) Sealant Criteria

i. Areas of application
ii. Patient selection factors
iii. Other indication factors

(G) Preparation Factors

i. Moisture control protocol
ii. Tooth/teeth preparation procedures prior to etching or etchant/bond

(H) Acid Etching or Etchant/Bond Combination

i. Material preparation
ii. Application areas
iii. Application time factors
iv. Armamentaria
v. Procedure
vi. Etchant or etchant/bond evaluation criteria

(I) Sealant Application

i. Application areas
ii. Application time factors
iii. Armamentaria
iv. Procedure for chemical cure and light cure techniques
v. Sealant evaluation criteria
vi. Sealant adjustment techniques

(J) Infection control protocol

(K) Clinical re-call re-evaluation protocols

       (6) There shall be no more than 14 students per instructor during laboratory instruction. Laboratory instruction may be conducted on a typodont, a simulated model, and/or mounted extracted teeth. Sufficient time shall be available for all students to obtain laboratory experience to achieve minimum competence in pit and fissure sealant application prior to the performance of procedures on patients.
       (7) Clinical instruction shall be of sufficient duration to allow the procedures to be performed to clinical proficiency. There shall be no more than 6 students per instructor during clinical instruction. Clinical instruction shall include clinical experience on four patients with two of the four patients used for the clinical examination. Each clinical patient must have a minimum of four (4) virgin, non-restored, natural teeth, sufficiently erupted so that a dry field can be maintained, for application of the etching, or etchant/bond combination, and sealant materials. Such clinical instruction shall include teeth in all four quadrants among the four patients. for each patient.
   (h) Externship Instruction.
       (1) If an extramural clinical facility is utilized, students shall, as part of an organized program of instruction, be provided with planned, supervised clinical instruction in the application of pit and fissure sealants.
       (2) The program director/coordinator or a dental faculty member shall be responsible for selecting extern clinical sites and evaluating student competence in performing procedures both before and after the clinical assignment.
       (3) Objective evaluation criteria shall be used by the program faculty and clinic personnel.
       (4) Dentists who intend to provide extramural clinical practices shall be oriented by the program director/coordinator or a dental faculty member prior to the student assignment. Orientation shall include the objectives of the course, the preparation the student has had for the clinical assignment, and a review of procedures and criteria to be used by the dentist in evaluating the student during the assignment.
       (5) There shall be a written contract of affiliation with each extramural clinical facility utilized by the program. Such contract shall describe the settings in which the clinical training will be received, affirm that the clinical facility has the necessary equipment and armamentarium appropriate for the procedures to be performed, and affirm that such equipment and armamentarium are in safe operating condition.

   (i) Evaluation and Examination.
       (1) Upon completion of the course, each student must be able to:

(A) Identify the major characteristics of oral anatomy, histology, physiology, oral pathology, normal/abnormal anatomical and physiological tooth descriptions, morphology and microbiology as they relate to pit and fissure application.

                (B) Explain the procedure to patients.

                (C) Recognize decalcification, caries and fracture lines.

                (D) Identify the indications and contraindications for sealants.

                (E) Identify the characteristics of self curing and light cured sealant material.

(F) Define the appropriate patient selection factors and indication factors for sealant application.

                (G) Utilize proper armamentaria in an organized sequence.

(H) Maintain appropriate moisture control protocol before and during application of etchant and sealant material.

(I) Demonstrate the proper technique for teeth preparation prior to etching.

               (J) Select and dispense the proper amount of etchant and sealant material.

               (K) Demonstrate the proper techniques for application of the etchant and sealant material.

               (L) Implement problem solving techniques associated with pit and fissure sealants.

               (M) Evaluate the etchant and sealant placement techniques according to appropriate criteria.

               (N) Check the occlusion and proximal contact for appropriate placement techniques.

               (O) Adjust occlusion and proximal contact of sealant when indicated.

              (P) Maintain aseptic techniques including disposal of contaminated material.
        (2) Each student shall pass a written examination which reflects the entire curriculum content.
        (3) Each student shall pass a clinical examination in which the student successfully completes the application of pit and fissure sealants on two of the four clinical patients required for clinical instruction. The examination shall include teeth in all four quadrants.
Note: Authority cited: Section 1614, Business and Professions Code. Reference: Section 1754, Business and Professions Code.

8. Proposed Changes to Regulation 1081.1 – RDA Practical Examination Requirements

In July, the Board voted to amend regulation section 1086 to allow RDAs to perform a number of new duties. While the regulation is currently on hold pursuant to the Governor’s Executive Order S2-03, the regulation defining what procedures should be included on the RDA practical examination may need to be changed.

Attached is a list of the proposed new duties, followed by a copy of the current regulation. COMDA may wish to discuss which duties, if any, should be added to the list of testable duties contained in Regulation section 1081.1, so that a proposal can be finalized at COMDA’s March meeting, and presented to the Board at that time.

The current regulation lists many duties that MAY be tested; COMDA’s RDA Examination Subcommittee then chooses two procedures to actually be tested. One alternative that COMDA may want to consider would be to add all, or nearly all, of the new procedures to the list of duties that can potentially be tested, then ask for feedback from the RDA Examination Subcommittee on the feasibility and/or desirability of testing each procedure.

RDA Examination Requirements

New duties contained in proposed changes to Regulation 1086:

1. Size, fit, adjust, pre-position, cure in dentist-approved position of, and remove orthodontic bands and brackets (currently allowed to size bands, remove bands, and place and ligate arch wires).

2. Take facebow transfers and bite registrations (bite registrations currently must be for diagnostic study models only)

3. Take impressions for space maintaining appliances, orthodontic appliances, and occlusal guards.

1081.1. RDA Practical Examination-Requirements.
(a) In addition to the written examination, each applicant for licensure as an RDA shall also take a practical examination consisting of any or all of the procedures listed below. The specific procedures will be assigned by an RDA examination committee appointed by the board. The procedures shall be performed on a full articulated maxillary and mandibular typodont secured with a bench clamp and shall be graded by examiners appointed by the board for that purpose. Each applicant shall furnish the required materials necessary to complete all of the following procedures.

(1) Placement of a rubber dam;
(2) Placement of a matrix band for amalgam preparation;
(3) Placement of a base into a prepared tooth (For purposes of the examination, "prepared tooth" means a tooth from which material has been removed so as to simulate the surgical excision of dental caries);
(4) Placement of a liner into a prepared tooth;
(5) Placement of orthodontic separators;
(6) Placement of a periodontal dressing;
(7) Placement of a temporary sedative dressing into a prepared tooth.
(8) Sizing and placement of a temporary crown.
(9) Temporary cementation of a temporary crown.
(10) Removal of excess cement from supragingival surfaces with a hand instrument or floss.
Note Authority cited: Section 1614, Business and Professions Code. Reference: Sections 1614 and 1753, Business and Professions Code.

9. Proposed Changes to Business and Professions Code Section 1645.1 – Required Coronal Polishing and Radiation Safety Courses for RDAs

During a previous review by the Joint Legislative Sunset Review Committee (JLSRC), COMDA and the Board recommended that all RDAs, who had not already done so, should be required to complete Board-approved courses in radiation safety and coronal polishing.

The JLSRC agreed and sponsored successful legislation placing such a requirement in statute (section 1645.1). The law provides that on and after January 1, 2005, all RDA licensees who have not complied will be automatically suspended until certification of completion is received.

Two issues have resulted:

1. COMDA is still in the process of mailing notices to all affected licenses (about 27,000), and considerable staff resources have had to be devoted to answering inquiries regarding the new requirement, processing certificates, and searching the Board x-ray records that existed prior to 1985. At the meeting, staff will provide COMDA with the number of RDAs who have still not completed the requirements.

If the number is large, COMDA may want to consider seeking an amendment to the law extending the date by one year, so that affected RDAs have sufficient time to comply, and to assure that the workload is extended another year for a very limited COMDA staff.

2. The revised law did not make an exception for RDAs who have placed their licenses on inactive statue. An RDA can place his or her license on inactive status at any time, which means the licensee has to pay the renewal fee every two years, but does not have to complete any CE requirements until he or she requests that the license be reactivated.

Staff has received many complaints from inactive licensees about the new radiation safety and coronal polishing requirement. COMDA may want to consider seeking an amendment to require that proof of completion of the two courses be submitted by inactive licensees only when and if they seek to re-activate their licenses.

10. Proposed Changes to Regulations 1014 and 1014.1 – Approval of Radiation Safety Programs

Regulation sections 1014 and 1014.1 define the requirements that providers must meet to obtain and maintain Board approval to offer radiation safety programs.

Attached are proposed amendments that will be presented by Vice Chair Drury-Klein.

1014. Approval of Radiation Safety Courses.
   (a) A radiation safety course is one which has as its primary purpose providing theory and clinical application in radiographic techniques. A single standard of care shall be maintained and the board shall approve only those courses which continuously maintain a high quality standard of instruction.
   (b) A radiation safety course applying for approval shall submit to the board an application and other required documents and information on forms prescribed by the board. The board may approve or deny approval of any such course. Approval may be granted after an on-site evaluation of all components of the course has been performed and the report of such evaluation indicates that the course meets the board's requirements. The board may, in lieu of conducting its own investigation, accept the findings of any commission or accreditation agency approved by the board and adopt those findings as its own.
   (c) The board may withdraw its approval of a course at any time, after giving the course provider written notice setting forth its reason for withdrawal and after affording a reasonable opportunity to respond. Approval may be withdrawn for failure to comply with the board's standards or for fraud, misrepresentation or violation of any applicable federal or state laws relating to the operation of radiographic equipment.
   (d) The processing times for radiation safety course approval are set forth in Section 1061.
Note Authority cited: Sections 1614 and 1656, Business and Professions Code. Reference: Section 1656 Business and Professions Code; and Section 15376, Government Code.

1014.1. Requirements for Radiation Safety Courses.
A radiation safety course shall comply with the requirements set forth below in order to secure and maintain approval by the board. The course of instruction in radiation safety and radiography techniques offered by a school or program approved by the board for instruction in dentistry, dental hygiene or dental assisting shall be deemed to be an approved radiation safety course if the school or program has submitted evidence satisfactory to the board that it meets all the requirements set forth below.
   (a) Educational Level. The course shall be established at the postsecondary educational level or a level deemed equivalent thereto by the board.
   (b) Program Director. The program director, who may also be an instructor, shall actively participate in and be responsible for at least all of the following:
       (1) Providing daily guidance of didactic, laboratory and clinical assignments;
       (2) Maintaining all necessary records, including but not limited to the following:
          (A) Copies of current curriculum, course outline and objectives;
          (B) Faculty credentials;
          (C) Individual student records to include pre-clinical and clinical evaluations, examinations and copies of all successfully completed radiographic series used toward course completion. Records are to be maintained for at least five years from the date of course completion.
       (3) Issuing certificates to each student who has successfully completed the course and maintaining a record of each certificate for at least five years from the date of its issuance;
       (4) Transmitting to the board on a form prescribed by the board the name, address social security number and, where applicable, license number of each student who has successfully completed the course;
       (5) Informing the board of any significant revisions to the curriculum or course outlines.
   (c) Faculty. The faculty shall be adequate in number, qualifications and composition and shall be suitably qualified through academic preparation, professional expertise, and/or appropriate training, as provided herein. Each faculty member shall possess the following qualifications:
       (1) Hold a valid special permit or valid license as a dentist, registered dental hygienist or registered dental assistant issued by the board;
       (2) Have background in and current knowledge of dental radiography techniques;
       (3) Shall have either passed the radiation safety examination administered by the board or equivalent licensing examination as a dentist, registered dental assistant,or dental hygienist or, on or after January 1, 1985, shall have successfully completed a board approved radiation safety course.
   (d) Facilities. There shall be a sufficient number of safe, adequate, and educationally conducive lecture classrooms, radiography operatories, darkrooms, and viewing spaces for mounting, viewing and evaluating radiographs. Adequate sterilizing facilities shall be provided and all disinfection and sterilization procedures shall be followed according to the Board’s Infection Control Regulations.
       (1) A radiographic operatory shall be deemed adequate if it fully complies with the California Radiation Control Regulations (Title 17, Cal. Code Regs., commencing with section 30100), is properly equipped with supplies and equipment for practical work and includes for every seven students at least one functioning radiography machine which is adequately filtered and collimated in compliance with Department of Health Services regulations and which is equipped with the appropriate position-indicating devices for each technique being taught.
       (2) The darkroom shall be deemed adequate if it is of sufficient size, based upon the number of students, to accommodate students' needs in learning various processing procedures and is properly equipped with supplies and equipment for practical work using either manual or automatic equipment.
       (3) X-ray areas shall provide protection to patients, students, faculty and observers in full compliance with applicable statutes and regulations.
   (e) Didactic Instruction and Demonstration. Sufficient classroom instruction shall be provided in at least the following subjects to provide the educational foundation necessary for the laboratory and clinical phases of the program:
       (1) Radiation physics and biology
       (2) Radiation protection and safety
       (3) Film exposure and processing techniques using either manual or automatic methods
       (4) Film mounting and viewing
       (5) Intraoral techniques and holding devices
       (6) Use of cylindrical and rectangular collimation
       (7) Supplemental techniques including the optional use of Computerized Digital Radiography
       (8) Infection control in Dental Radiographic procedures.

Students may be given the opportunity to obtain credit by the use of challenge examinations and other methods of evaluation.
   (f) Laboratory Instruction. Sufficient hours of laboratory instruction shall be provided to ensure that a student successfully completes on a manikin at least the procedures set forth below. A procedure has been successfully completed only if each film is of diagnostic quality as defined by the American Association of Dental Schools' 1978 Position Paper on Dental Radiography.
       (1) Two full mouth periapical surveys, consisting of at least 18 films each, 4 of which must be bitewings; no more than one set may be completed using Computer Digital Radiographic equipment;
       (2) Two bitewing surveys, consisting of at least 4 films each;
       (3) Developing and/or processing, and mounting of exposed radiographs;
       (4) Student and instructor written evaluation of radiographs.
   (g) Clinical Experience. The course of instruction shall include sufficient clinical experience, as part of an organized program of instruction, to obtain clinical competency in radiographic techniques. Clinical experience shall include:
       (1) Successful completion of a minimum of four full mouth periapical surveys, consisting of at least 18 films each, 4 of which must be bitewings. No more than three sets may be completed using Computer Digital Radiographic equipment. Such films shall be of diagnostic quality as defined by the American Association of Dental Schools' 1978 Position Paper on Dental Radiography. All exposures made on human subjects shall only be made for diagnostic purposes. All clinical instruction procedures on human subjects shall be performed under the supervision prescription of a licensed dentist in accordance with sections 25661(h) and 25672(b) of the Health and Safety Code and under the clinical supervision/instruction of a licensed dentist, registered dental assistant, or registered dental hygienist.
       (2) Developing and/or processing, and mounting of exposed human subject radiographs;
      
(3) Student and instructor written evaluation of radiographs.
   There shall be a written contract of affiliation with each clinical facility utilized by a course. Such contract shall describe the settings in which the clinical training will be received and shall provide that the clinical facility has the necessary equipment and accessories appropriate for the procedures to be performed and that such equipment and accessories are in safe operating condition.
   (h) Certificates. A certificate shall be issued to each student who successfully completes the course. A student shall be deemed to have successfully completed the course if the student has met all the course requirements and has obtained passing scores on both written and clinical examinations.
Note Authority cited: Sections 1614 and 1656, Business and Professions Code. Reference: Section 1656, Business and Professions Code.

11. Teaching Methodology Course for RDA Educational Program Faculty

May 30, 2003 changes to the regulations governing the approval of RDA educational program provide that:

1070.2 (c)….(2) Effective two years after the effective date of this regulation, each faculty member shall have received a certificate of completion of an COMDA approved course in teaching methodology of at least 60 hours at a post-secondary institution prior to student instruction.

This requirement will be effective on and after May 30, 2005.

COMDA needs to determine how it wishes to implement this requirement. Following are two alternatives:

1. Review and approve each course on a case-by-case basis. There would be no requirement that a separate regulation defining the standards that each course must meet, as long as COMDA does not establish any "standards" or "requirements" that each program must meet for approval. Initially, at least, this may be the best solution since (a) courses may be presented in a variety of different formats that would be difficult to govern by one regulation, and (b) COMDA may not have enough expertise initially to define the standards that each course must meet.

2. Develop a regulation that will define all of the standards and requirements that each course must meet. The drawbacks to doing so would be that (a) courses may be presented in a variety of different formats that would be difficult to govern by one regulation, and (b) COMDA may not have enough expertise at this time to define the standards that each course must meet.

In addition, COMDA should determine if a "course" must be one given by one provider in a continuous format, or if multiple courses, perhaps given by different providers, would be sufficient.

12. Consideration of RDHAP Educational Program Application of UOP

The University of the Pacific (UOP) has submitted an application for approval of a proposed RDHAP educational program (there is currently only one approved program – West Los Angeles College). The application has been reviewed by two COMDA educational consultants in conjunction with a COMDA subcommittee composed of Shanda Wallace and Darla Dale.

The Subcommittee will make its recommendation at the meeting.

Following is the text of the Board regulations governing the approval of such programs.

1073.2 Approval of RDHAP Educational Programs.
(a) The Board shall approve only those educational programs for registered dental hygienists in alternative practice (RDHAPs) which continuously maintain a high quality standard of instruction. The requirements contained in this article are designed to that end and govern the approval of educational programs for RDHAPs. Continuation of approval will be contingent upon compliance with these requirements.
(b) An educational program for RDHAPs is one which has as its primary purpose providing college level education including, but not limited to, dental hygiene technique and theory, which shall include gerontology, medical emergencies, business administration and practice management as they pertain to RDHAPs. The program shall be given by a college or institution of higher education that is accredited by a national agency recognized by the Council for Higher Education Accreditation.
(c) Any program for RDHAPs shall apply for and receive approval prior to operation. The Board may approve, provisionally approve, or deny approval of any such program. Provisional approval shall not be granted for a period which exceeds the length of the program and in no event for more than 30 days. When the Board provisionally approves a program, it shall state the reasons therefor. Provisional approval shall be limited to those programs which substantially comply with all existing standards for full approval. A program given provisional approval shall immediately notify each student of such status. The Board's maximum processing time for an application for an RDHAP educational program shall not exceed ten days to notify the applicant in writing that the application is complete and accepted for consideration by the Board or, that the application is deficient and what specific information is required. The Board's maximum time to approve, provisionally approve, or deny approval of the RDHAP educational program shall not exceed 90 days upon the filing of a completed application.
The Board may, in lieu of conducting its own investigation, accept the findings of any national agency recognized by the Council for Higher Education Accreditation and adopt those findings as its own. If the Board denies approval of a program, the specific reasons therefor shall be provided by the Board in writing within 90 days after denial.
Note Authority cited: Section 1614, Business and Professions Code. Reference: Section 1768, Business and Professions Code.
History: Amendment of subsections (b) and (c) filed 5-22-2003; operative 6-21-2003.

1073.3. Requirements for Approval of RDHAP Educational Programs.
(a) Requirements of Students: All students must possess a valid, active registered dental hygienist license issued by the Board and hold a current CPR certification in order to be eligible for admission to the program.
(b) Administration. Each program shall provide the resources necessary to accomplish education of RDHAPs as specified in this section.
(c) Facilities and Equipment. Physical facilities and equipment shall be maintained and replaced in a manner designed to provide students with an educationally optimal environment.
(d) Curriculum Organization/Learning Resources.
(1) The organization of the curriculum for RDHAPs shall be flexible, creating opportunities for adjustments to and research of advances in the practice of registered dental hygiene in alternative practice. In addition each program shall establish and maintain qualitative standards for proficiency and accomplishment.
(2) Students shall have access to dental/medical reference texts, current journals, audiovisual materials and other relevant resources to ensure they achieve and maintain the proficiency standards established by the program.
(e) Curriculum Content. Curriculum must include content designed to prepare the student to assess, plan, implement, and evaluate dental hygiene services as an independent practitioner as specified and in accordance with Business and Professions Code Section 1770. The curriculum content shall include, at least the following:
(1) Dental Hygiene Technique and Theory, including:
(A) Oral pathology;
(B) Pharmacology;
(C) Sociology, psychology, and treatment of special populations, including:
1. Geriatric
2. Medically compromised
3. Developmentally disabled
4. Pediatric
(D) Evaluation of Dental Hygiene status and Dental Hygiene treatment planning;
(E) Medical histories/terminology;
(F) Dental/Medical emergencies.
(G) Apply pit, resin or composite fissure sealants
At least 75% of instructional hours shall be devoted to the subjects specified in this subsection.
(2) Business Administration and Practice Management.
(f) Length of Program. The program shall be not less than 150 hours in length.
Note Authority cited: Section 1614, Business and Professions Code. Reference: Section 1768, Business and Professions Code.

14. Establishment of Future Meeting Dates

COMDA needs to decide whether it wishes to continue meeting in conjunction with the Dental Board, or to meet separately. Following are the benefits of each (the drawbacks would be the opposite for each option):

Meet with Board

1. Opportunity for COMDA members to view Board meetings, and Board members to view COMDA meetings

2. Opportunity for COMDA and Board members to become better acquainted.

3. The COMDA Chair, the two members who serve on both COMDA and the Board, COMDA and the Board’s legal counsel, and COMDA staff attend both COMDA and Board meetings – travel time and costs would perhaps be less than having two separate meetings.

4. Interested parties may save time and money by attending both meetings over a span of 2 to 3 days, rather than having two separate meetings.

Meet 2 to 4 weeks Before the Board Meeting

1. COMDA meeting dates would be more certain, rather than potential changes at the last minute to fit into the Board’s meeting schedule.

2. If COMDA makes changes to agenda items that are going before the Board, there is time to make appropriate changes so that they are not handed out to the Board members the same afternoon or the next day, which can result in the tabling of an item.

3. If the COMDA meeting goes longer than expected (and it is very difficult to predict the length of any particular meeting), the COMDA members who also serve on the Board may have to leave to conduct Board business. Their input will be lost, and there is the potential that a quorum would be lost as well.

4. If the COMDA meeting goes longer than expected, COMDA’s legal counsel (who is also legal counsel to the Board) may have to leave to attend the Board meeting.

Board Meeting Dates

Following are the dates that have been set by the Dental Board for 2004:

March 11-12 – San Diego

May 13-14 – San Francisco

August 19-20 – Los Angeles

November 4-5 - Sacramento


COMMITTEE ON DENTAL AUXILIARIES

Draft Meeting Minutes - January 29, 2004

Members Present: Shanda Wallace, RDH, Chairperson; LaDonna Drury-Klein, RDA, Vice Chair; Linda Gipson, RDH, Secretary; Kevin Biggers, Public Member; Teresita Churchill, RDA; Darla Dale, RDH; Marlyn Hiroto, RDA; Sonia Molina, DDS

Members Absent: Coragene Savio, DDS

Staff Present: Karen R. Wyant, Executive Officer; Dyna Leonard, Associate Analyst; Bob Miller, DCA Legal Counsel; Donna Kantner, Staff

1. Call to Order/ Roll Call/ Establishment of Quorum

Chairperson Wallace called the meeting to order at 9:05 am; roll was called by Secretary Gipson and a quorum established. New member Kevin Biggers was introduced and gave a brief biography.

2. Approval of November 6, 2003 Meeting Minutes

Minutes of the November 6, 2003, COMDA meeting were accepted with no changes.

3. Report of the Chair

Chairperson Wallace reported that over the last few months she has been working with the Executive Officer to keep abreast of changes and made appointments to COMDA's various Subcommittees. She indicated that notices are going out regarding Subcommittee appointments.

4. Report of the Executive Officer

Executive Officer Wyant reported that examination statistics are contained in the packet, along with budget information, noting that the budget will once again be tight this year. In response to a question regarding exam costs from Chair Wallace, Wyant noted that budget projections are sometimes not related to actual line item expenditures, monies are pulled from other items as necessary. She explained that this is not unusual, and to pursue a budget realignment would involve a great deal of work, taking staff away from other projects.

She reported that there is currently a moratorium on regulations, however COMDA is moving forward on regulations that have previously been approved. Bob Miller, DCA Legal Counsel, noted that this is a six-month moratorium. Wyant stated that there are several regulations in the pipeline that will continue, but if the one-year maximum processing time expires, the regulatory process must begin all over again with new hearings.

Tim Hart, CDA, noted that they had obtained an explanation from the Governor's order indicating that regulations that were pending at the time of the Executive Order would be decided at the Cabinet level on a case-by-case basis as to whether they would proceed. He felt that the regulations should continue to move forward on this basis. Wyant noted that this had been COMDA's intent. Miller noted that at least one Department has received an exemption to the Order, although he did not know how difficult this would be. Hart believed that the Agency Secretary would be the person to determine this. Wyant noted that the process would still need to go through the Department's Legal Office and the Director of DCA as a matter of course.

5. Legislation of Interest to COMDA a. AB539 - 3rd and 4th Year Dental Students applying for RDH licensure

Executive Officer Wyant reported that AB539 has begun to move forward in the Legislature. She will continue to express COMDA's wishes, however she indicated that the bill is moving forward at this time.

6. Review of RDA Educational Programs and Courses/ Recommendations to the Board

This item was tabled.

7. Proposed New Regulation 1070.3 - Approval of Pit and Fissure Sealant Courses

Vice Chair Drury-Klein reported that all interested parties were asked to submit their comments by the end of December. She noted that it was decided that she would be the one contact point for the dissemination of information. She reported that she had consolidated all information that she had received and that the last page is a compilation of single or individual comments that were the only comments of their kind. All other comments were consolidated by consensus. Chair Wallace noted the difficulty of compiling all the information received and thanked Drury-Klein for her efforts.

Member Hiroto asked that the characteristics and safe use of curing lights be added to page 4, Item (5) (I). Barbara Blade, educator, noted that this was addressed on page 3, Item (I). Earl Johnson, California Association of Orthodontists felt that assistants should not be adjusting occlusion at all. He noted that he was referring to page 4, item (O). Barbara Blade responded that as Program Coordinator for UCLA, that the scope of that program was learning to apply pit and fissure sealants. She noted that at that time, since 1987, the Dental Board has approved this duty as part of the sealant process. She reported that adjustment of sealants is minor, the amount of adjustment is approximately 3%, and done by means of a slow-speed handpiece. She felt that if this program is approved, the person would be considered trained to perform the procedure, indicating that there has been no report of patient harm occurring.

Drury-Klein asked if Item (i) O should include the usage of the slow- speed handpiece. With an affirmation from Blade, it was moved (Drury-Klein/Churchill) to add "by the use of a slow speed handpiece" to that language. Member Hiroto asked if this would exclude other means such as floss or strips. Wyant noted that the language under consideration relates to course curriculum, and if the intent is to prevent the use of high speed handpieces in practice, this language change would not accomplish that. The regulation allowing RDAs to perform the duty would have to be amended.

Joanne Galliano, CDHEA, felt it unnecessary to specify what device is to be used, believing the language should be retained as is. She felt that educational institutions will not be teaching duties that are not within the standard of care of the community.

Member Molina asked if it is usual that the dentist checks occlusion. Drury-Klein responded that yes, as a directly supervised duty the dentist must check the procedure. Member Molina indicated that she was comfortable with assistants adjusting occlusion. Joan Greenfield, RDA educator, suggested that the language be left as is, noting that in the past changes had to be made because language was too specific. Earl Johnson noted that occlusion is not that simple, sometimes requiring the use of a burr, which is beyond the scope of assistants. Chair Wallace clarified that this is a directly supervised duty. A motion to add slow-speed handpiece to the language failed.

Member Molina asked to move to strike Item O. There was no second to the motion. Executive Officer Wyant reiterated that this regulation does not control what duties can be performed, simply what is contained in the curriculum of the course. She noted that Section 1086 would need to be amended to address how the duty is actually performed. Chair Wallace asked if there were any other motions. It was M/S/P (Drury-Klein/Hiroto) not to specify devices in the language, simply stating "adjust occlusion and evaluate or correct proximal areas when indicated".

Member Molina noted that as an endodontist, many times occlusal misadjustment is not taken into account as seriously as it might be. Drury-Klein noted that this is a directly supervised procedure, and as such the dentist may choose not to delegate the duty if they wish. Member Molina responded that then there would not be any need for regulations. Chair Wallace noted that in the absence of any further motions, the indication is to accept the language as it stands. Earl Johnson still felt that this was changing the fabric of the scope of practice. Joan Greenfield noted that we are talking about 896 EF assistants adjusting minimally with rubber cups and points.

Barbara Blade added that there is another area that does not appear in the comments, and speaking for the Alliance, she asked that COMDA to consider adding that the RDA educator have specific clinical competence requirements or hours of practice. She noted that by simply requiring that they take the course they could conceivably take the course on Friday and teach it on Saturday. Drury-Klein apologized for not reflecting that issue in the compilation.

Barbara Blade noted that it is difficult to specify a number of experiences, but felt there should be a period of time before evaluations were allowed. Greenfield felt that Item (1) specified sufficient faculty requirements that would cover this area. Wyant noted that this does not address any time period that the person has been placing sealants. Greenfield noted that the Alliance had discussed that perhaps additional training in evaluation should be required rather than more time placing sealants, adding that CADAT would offer such a course to educators. She indicated that the course could be open to dentists, RDH, EF or whomever would need additional education and training in evaluation. There were no further motions to change the language of (c)(1).

With regard to the language of (c)(1), Tim Hart, CDA, noted that there is no such thing as DDS, the term has gone back to dentist in the DPA. There was a consensus to modify the language accordingly.

Melody Randolph, RDA educator, Western Career College, noted that their program is modular, and it may be difficult to implement a pit and fissure component with coronal polishing as a prerequisite. She indicated the difficulty of getting patients, asking that perhaps testing of both procedures be concurrent on one patient. Greenfield noted that courses that teach sealants require coronal polishing, it is a sequence of events and coronal polishing is a precursor to pit and fissure sealants. Blade felt coronal polishing must be a prerequisite to any pit and fissure sealant course. Melody Randolph noted that she was not suggesting that the courses be combined, only that final evaluation and testing be done concurrently.

Tim Hart, CDA, recommended that in item (f)(3), protective eyewear should be required for each student rather than each piece of equipment, to which members agreed.

It was M/S/P (Drury-Klein/Molina) to accept the language as amended and move the regulation to the Board for approval. Motion passed unanimously.

8. Proposed Changes to Regulation 1081.1 - RDA Practical Examination Requirements

Wyant noted that at some point the list of testable procedures needs to be considered in light of the new duties that a pending change to the regulations would allow. It was M/S/P (Drury-Klein/Churchill) to add all of the new duties to the list of testable procedures, authorized the Executive Officer to take the proposed regulatory change directly to the Board when finalized, and referred the issue of which duties should actually be tested in the future to the RDA practical examination subcommittee.

9. Proposed Changes to Business and Professions Code Section 1645.1 - Required Coronal Polishing and Radiation Safety Courses for RDAs

Executive Officer Wyant reported that in implementing the new law requiring RDAs to become certified in radiation safety and coronal polishing by January 1, 2005, COMDA staff has mailed out several thousand notices to RDAs regarding the requirements, which has put a tremendous workload on staff. She also noted that she has received many letters from RDAs protesting the new requirements. She asked that COMDA consider extending the deadline one year, noting that any changes would not be implemented until October or November, but that it may still affect thousands of RDAs who had not become certified by that point in time.

She further indicated that there are a large number of inactive licensees that feel they should be exempt from this requirement since they are not currently working, and should only have to take the courses when they wish to activate their license. She asked if some accommodation could be made for inactive licensees. Tim Hart, CDA, noted CDA would be happy to work with COMDA staff to pursue such both proposed legislative changes. It was M/S/P (Drury-Klein/Molina) to pursue such changes.

10. Proposed Changes to Regulations 1014 and 1014.1 - Approval of Radiation Safety Programs

Vice Chair Drury-Klein noted that she had made proposed changes, and had sent them to all concerned, however some apparently did not receive the material. She indicated her willingness to table the issue until every interested party has the opportunity to formulate their comments. Wyant noted that perhaps there are people here who wish to make their comments at this time. Member Biggers noted that there were comments received at the meeting this morning that he would appreciate the opportunity to read and digest and then consider the changes at the next meeting. It was M/S/P (Drury-Klein/Biggers) to table the item to the next meeting.

11. Teaching Methodology Course for RDA Educational Program Faculty

Executive Officer Wyant noted the regulation that mandated this requirement went into effect about a year ago, reporting that discussions as to how to implement this have been less than productive up to this point. She noted the difficulty of writing a regulation that would encompass all teaching methodologies. Wyant indicated that this can be determined on a case by case basis if standards are not set by regulation, but this requires staff review time.

Barbara Blade, CADAT, stated that CADAT has given this matter a great deal of thought, noting that vocational education courses have existed for a long time. The problem is that without regulation, any course can be approved. There are many aspects of teaching methodology that is not appropriate to an RDA course.

Vice Chair Drury-Klein noted that in the absence of the ability to fund a Subcommittee, she felt that CADAT has done the groundwork in this area and this could be brought forward to COMDA for their review and comments. Member Biggers asked if other organizations than CADAT could provide input. Drury-Klein noted that CDHA and others would also be asked for their input. Drury-Klein suggested starting the process now, notwithstanding how much time it takes to implement due to the moratorium on regulations. Wyant noted that if COMDA wishes, some sort of provisional approval may be given prior to the regulatory implementation. JoAnn Galliano, RDH educator, noted that RDH faculty must have teaching methodology courses. Member Molina noted that in dental schools it is a requirement.

Staff was directed to work with interested parties to develop a proposal.

12. Consideration of RDHAP Educational Program Application of UOP

Chair Wallace noted that the application was presented for a distance-learning course to be given by UOP. It was M/S/P (Subcommittee) to recommend approval of the program and move it forward to the Board.

13. Agenda Items for Future Meetings

Proposed Changes to Regulations 1014 and 1014.1 - Approval of Radiation Safety Programs

Teaching Methodology Course for RDA Educational Program Faculty

14. Establishment of Future Meeting Dates

Chair Wallace preferred to meet in conjunction with the Board. Member Molina noted that it is also an opportunity to converse with Board members regarding issues. Vice Chair Drury-Klein noted that meeting on Thursday may cause conflicts in meetings for members who are on both Boards, suggesting meeting on Wednesday rather than Thursday. Wyant noted that this would increase costs for staff and those members required to stay for the Dental Board meetings while there would be little contact with Board members, who would not be arriving until Thursday. JoAnn Galliano, CDHA, noted that COMDA's meetings have taken place on Wednesdays and sometimes the Board has Subcommittee meetings on Wednesday as well, so this may or may not resolve those conflicts.

It was a consensus that COMDA meet on Wednesdays at 1:30pm, setting the next meeting for Wednesday, March 10.

15. Public Comment

None.

16. Adjournment

The meeting adjourned at 11:55am.

 

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