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Meetings


May 12, 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

May 12, 2004 – 1:30 p.m.

Embassy Suites, San Francisco Airport,150 Anza Blvd, Burlingame, 650-342-4600

Agenda

1. Call to Order/Roll Call/Establishment of Quorum
2. Approval of January 29, 2004, 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
b. SB 1546 – Dental assisting scopes of practice

RDA Program
6. Review of RDA Educational Programs and Courses/Recommendations to Board
7. RDA Practical Examination Testable Procedures – Recommendation of Subcommittee
8. Required Coronal Polishing and Radiation Safety Courses for RDAs – Affidavit in Lieu of Certificate
9. Proposed Changes to Regulations 1014 and 1014.1 – Approval of Radiation Safety Programs
10. Appointment of New RDA Examiners
11. Appointment of Chief and Assistant Chief Examiners

EF Program
12. Proposed Restructuring of EF Subcommittee

RDH Program
13. Recommendation: Board Appointment of Subcommittee to Review RDH Law and Ethics Examination and RDHAP Law and Ethics Examination
14. Appointment of New RDH Examiners
15. Review of Necessity/Desirability of RDHAP Prescription Requirement

All Programs
16. Review of Last COMDA Strategic Plan
17. Agenda Items for Future Meetings
18. Public Comment

19. 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.

The bill 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 has passed the Assembly and the Senate, and has been enrolled, but as of April 16, 2004, had not been sent to the Governor.

b. SB1546 (Figueroa) - Dental assisting scopes of practice

SB1546 was amended April 12th to define, in statute, the scope of practice of dental assisting. Attached, along with a copy of the bill, is a fact sheet prepared by the Alliance which outlines all of the provisions of the bill. Staff has provided the sponsors and the author with suggestions and recommendations on certain portions of the proposal from an administrative point of view.

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. RDA Practical Examination Testable Procedures - Recommendation of Subcommittee

At COMDA's last meeting, it decided to ask that the RDA Practical Examination Subcommittee review the proposed new duties for RDAs (proposed changes to regulation Section 1086) and determine which, if any, duties it might be desirable/feasible to actually include on the RDA practical examination. The additional duties include:

1. Pre-positioning and curing in dentist-approved position of orthodontic brackets. 2. Taking facebow transfers and bite registrations. 3. Taking impressions for space maintaining appliances, orthodontic appliances and occlusal guards. 4. Other reversible dental procedures, not listed in regulation.

The Subcommittee recommends that none of the new duties be added to the list of testable duties, as they are impractical to test. (Note: The pass rate on the RDA practical examination has been relatively stable for some time.)

8. Required Coronal Polishing and Radiation Safety Courses for RDAs - Affidavit In Lieu of Certificate

A law enacted several years ago as part of the Legislative Sunset Review process at that time requires that all RDAs provide evidence of having completed both a radiation safety course and a coronal polishing course by January 1, 2005. Unless such evidence is received, the license of the RDA is automatically suspended. (Note: It is anticipated that legislation will be introduced this session to extend that deadline to January 1, 2006.)

COMDA has notified all RDAs of this requirement, but has heard from many that they have lost or misplaced their certificates. If they completed a course many years ago, the course provider may no longer be in business, or if they are, they may not have kept records for such a long period of time.

Members of the public have asked that COMDA consider allowing an RDA whose radiation certificate and/or coronal polishing certificate has been destroyed, lost, or misplaced, to file an affidavit of completion under penalty of perjury.

Following is the text of the law in question:

1645.1. Required completion of radiation safety and coronal polishing courses By January 1, 2005, each person who holds a registered dental assistant license shall provide evidence of having successfully completed board-approved courses in radiation safety and coronal polishing. The length and content of the courses shall be governed by applicable board regulations. Failure to comply with this section shall result in automatic suspension of the license which shall be reinstated upon the receipt of evidence that the licensee has successfully completed the required courses. Completion of the courses may be counted toward fulfillment of the continuing education requirements governed by Section 1645.

9. Proposed Changes to Regulations 1014 and 1014.1 - Approval of Radidation 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 courses.

Attached are proposed amendments that will be presented by Vice Chair Drury-Klein. Also attached are comments on a prior version of the proposed changes received from CDA and the Alliance, as well as a 2-page sheet indicating why certain changes proposed by CDA and the Alliance were not included in the revised proposed changes.

10. Appointment of New RDA Examiners

The RDA Practical Examination Subcommittee recommends that COMDA recommend that the Board appoint the following new RDA examiners:

Kristie Nunes - North - Chico Mary Holm - North - Orland Mary Jenkins - North - Corning Sheronda Walton - South - Palmdale

11. Appointment of Chief and Assistant Chief Examiners

COMDA's RDA Practical Examination Subcommittee has appointed Charlene Flowers as Chief Examiner, and Cassandra Elston as Assistant Chief Examiner.

Pursuant to COMDA policy, the appointments are valid unless COMDA chooses to revoke the Subcommittee's decision.

12. Proposed Restructuring of EF Examination Subcommittee

The EF Examination Subcommittee, as defined by COMDA in the past, consists of a Chair, who is An EF COMDA member or other EF appointed by COMDA, a DDS COMDA member, an EF Dental Board member (if one exists), and the two Chief Examiners. The Chair also serves as the "EF Coordinator", overseeing the administration of the examination including oversight of examiner training.

Several years ago, the constitution of the Subcommittee was changed as indicated above in order to allow COMDA to appoint an EF to the Chair and Coordinator positions who is not a member of COMDA, because of the possibility that future appointments to COMDA would not include an EF licensee, which is currently the case.

Rhona Lee, RDHEF, was the immediate past Chair of COMDA, and served as such for more than two terms, and was also the EF Subcommittee Chair and EF Coordinator. The past COMDA appreciated her efforts to such an extent that they expressed their belief that it would be extremely beneficial if she were appointed by a future COMDA as the EF Subcommittee Chair and EF Coordinator (if no other EF was appointed to COMDA in the future) once she had completed the one-year mandatory period as a non-member of COMDA.

The EF Subcommittee would benefit a great deal by the guidance of an EF who has experience as a COMDA member. Rhona Lee commanded a huge amount of respect from all of the examiners and the two Chiefs, not to mention the other COMDA members and the various people with whom COMDA interacts. COMDA may want to consider appointing her as the EF Subcommittee Chair and Coordinator, with certain reporting requirements to COMDA.

13. Recommendation: Board Appointment of Subcommittee to Review RDH Law and Ethics Examinations and RDHAP Law and Ethics Examinations

Two regulatory change proposals have been approved by the Board and are under review either within the Department of Consumer Affairs or OAL: one would require that RDH applicants complete examinations in law and ethics as a condition of licensure, and the other would replace the current examination for RDHAPs with examinations in law and ethics only.

The examinations are currently being developed by COMDA staff. Staff recommends that a subcommittee, perhaps of two of the COMDA RDH members, review the final products. It is proposed that the examinations not be reviewed by the entire COMDA to assure exam security.

Staff also recommends that COMDA recommend to the Board that it also appoint a subcommittee of two Board members, one of them the RDH member, to review the examinations approved by COMDA's subcommittee, and make appropriate recommendations to the Board's Examination Committee, again, without actual review by the Examination Committee to assure the security of the examination.

14. Appointment of New RDH Examiners

The RDH Examination Subcommittee recommends that COMDA recommend that the Board appoint the following new RDH examiners:

Christine Dawson - South - La Habra Ann Havlik - North - San Luis Obispo Lisa Galasso - South - Huntington Beach Paulina Jo Attebery - South - South Pasadena

15. Review of Necessity/Desirability of RDHAP Prescription Requirement

In COMDA's October, 2002, Supplemental Report to the Joint Legislative Sunset Review Committee, COMDA recommended that the existing requirement that an RDHAP may only perform services independently upon the receipt of a prescription from a licensed dentist be eliminated. While that recommendation was not implemented by the Legislature, this newly-constituted COMDA may want to consider what position it wishes to take on the issue.

Following are excerpts from the October, 2002, Supplemental Report. References to the "report" are to the report issued on September 1, 2002, by Sjoberg & Evashenk Consulting, LLC, titled "Review of the Regulatory Structure and Scope of Practice for California's Dental Auxiliaries". Sjoberg & Evashenk were hired by the Dental Board to complete the report, which was mandated by legislation that resulted from the 2000 sunset review process.

The following is quoted from COMDA's Supplement Report, which makes reference to the "report" issued by Sjoberg & Evashenk:

The report notes: "In the existing RDHAP environment, patients must be 'of record' or first examined and diagnosed by a physician or dentist before any procedures can be delegated to a dental auxiliary….However, this requirement can present a considerable barrier in the path to providing basic preventive services to underserved populations. By definition, these are the very patients that are least likely to have access to a dentist or physician. In settings such as "dental health professionals shortage areas" or in programs seeking to provide preventive services to school children or rural farm workers, first obtaining an examination and prescription from a physician or dentist may effectively prevent an individual from obtaining dental care." {p. 35}

B&P Section 1770(h) states:

"(h) A registered dental hygienist in alternative practice may perform dental hygiene services for a patient who presents to the registered hygienist in alternative practice a written prescription for dental hygiene services issued by a dentist or physician and surgeon licensed to practice in this state who has performed a physical examination and a diagnosis of the patient prior to a prescription being provided. The prescription shall be valid for a time period based on the dentist's or physician and surgeon's professional judgment, but not to exceed 15 months from the date that it was issued."

Current law also provides that "A registered dental hygienist in alternative practice shall provide to the board documentation of an existing relationship with at least one dentist for referral, consultation, and emergency services."

Section 1090(c) of the Board's regulations also provides as follows:

"1090…(c) Independently and without the supervision of a licensed dentist, an RDHAP may, upon the prescription of a dentist or a physician and surgeon licensed in California, perform the duties assigned to a registered dental hygienist by Section 1088(c)."

COMDA concurs with the report's conclusion that "the state should consider alternatives for the prescription and patient of record requirements." {p. 35}

The report presents two different alternative models: the Physician Assistant in California, and Public Health Supervision Status for RDHs in the State of Maine. Both examples call for some type of "standing orders" or other types of supervisorial oversight by a licensed dentist.

The report also examined the State of New Mexico, which provides for a "collaborative practice dental hygienist", allowing experienced dental hygienists form an agreement with a dentist whereby standing orders are issued and all records must be forwarded to that dentist. The report notes "{New Mexico} Board officials believe that dental hygienists have found it difficult to arrange a collaborative agreement with a consulting dentist." {p. 64}

Adoption of a model similar to those described above would seem to be even more restrictive than the current requirement that a physician or dentist first examine and diagnose a patient before referring the patient to a RDHAP via a prescription.

Those models seem to focus on oversight of the practitioner's ability to provide appropriate and competent hygiene care, which is not the assumption underlying the current prescription requirement.

Rather, the current model seems to rest on the assumption that examination by a physician or dentist will identify, and address, oral health conditions that would not be recognized by the RDHAP.

However, the effectiveness of this assumption seems to be questioned by the report's previously cited finding that "first obtaining an examination and prescription from a physician or dentist may effectively prevent an individual from obtaining dental care" {p. 35} in under-served areas and for certain populations.

In fact, dental hygienists were allowed to practice independently for 16 years under two Health Manpower Pilot Projects prior to the establishment of the RDHAP license category. During those 16 years, there was no prescription requirement and there is no evidence that any public harm occurred.

COMDA received written and oral comments from 12 of the existing 21 licensed RDHAPs, all of whom indicated that the prescription requirement has been a considerable barrier to providing services to those who need them most. No evidence was presented to COMDA indicating that harm would occur if the prescription requirement were eliminated.

COMDA therefore recommends that the prescription requirement be eliminated, as proposed in Section 1775.


COMMITTEE ON DENTAL AUXILIARIES

Draft Meeting Minutes - May 12, 2004

Members Present: LaDonna Drury-Klein, RDA, Vice Chair; Linda Gipson, RDH, Secretary; Teresita Churchill, RDA; Darla Dale, RDH; Coragene Savio, DDS

Members Absent: Shanda Wallace, RDH, Kevin Biggers, public member; Marlyn Hiroto, RDA; Sonia Molina, DDS

Staff Present: Karen R. Wyant, Executive Officer; Dyna Leonard, Associate Analyst; Lori Hubble, Staff Analyst; Norine Marks, DCA Legal Counsel; Donna Kantner, Staff

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

Acting Chair Drury-Klein called the meeting to order at 1:35 p.m.; roll was called by Secretary Gipson and a quorum established.

2. Approval of January 29, 2004 Meeting Minutes

Minutes of the January 29, 2004 COMDA meeting were accepted with the following changes: Page 2, next to last paragraph should read "JoAnn Galliano, CDHA". Page 4, Item 10, Chair Drury-Klein noted that there was public comment regarding those regulations that were heard and recorded at that time and asked that those statements be referred to staff to add as appropriate. Page 4, Final paragraph, should read "Drury-Klein noted that CDAA and others would also be asked for their input", not CDHA.

Page 5, Item #14 should read " 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. She asked that the Board recognize and acknowledge the move of the meeting to ensure that there would be no conflict. Drury-Klein offered to apprise the Board and Board's staff of the change."

3. Report of the Chair

The Chair's report was deferred by Acting Chair Drury-Klein due to the absence of Chair Wallace.

4. Report of the Executive Officer

Executive Officer Wyant reported that she had met with new Department of Consumer Affairs Director Charlene Zettel, who is an RDH, and Agency Secretary Fred Aguiar noting that there seemed to be support for specially funded agencies such as COMDA being treated differently than general fund agencies as far as funding and staffing.

Wyant reported that Director Zettel would be recusing herself from reviewing any dental-related matters, due to her background in the field, noting that while Boards are autonomous, certain powers still lie within the Department through the regulatory and budget process.

She reported that the EF and RDHAP examinations were being held this weekend. She noted that in the future, the RDHAP will be a Law and Ethics examination only, as a regulation change will become effective sometime in June. She noted that there had been 58 RDHs licensed through licensure by credential, with 15 pending.

She also reported that the budget will be very tight, as COMDA will come within $1,000 of expending its entire $1.3 million budget, noting that the budget had been reduced by $60,000 as the result of a mandatory statewide budget reduction. She reported that there is currently a bill by Senator Figueroa to codify that special funds be treated differently than general funds.

Wyant further reported that regulation 1079.3 has been approved, and all other regulations are in the Department awaiting approval. She noted that she continues to receive calls, so they are being actively reviewed, adding that 1072.1, the regulation regarding RDH Educational programs, will be heard by the Board on Friday.

Wyant noted that updated Examination statistics are in the packet for COMDA's review. Member Savio asked what is the expense of reviewing the RDH Licensure by Credential candidates. Wyant indicated that staff member Lori Hubble performs in-house review of all LBC applications, so there is no additional cost associated with that program. JoAnn Galliano asked if the Law and Ethics examination that will be given to RDHAPs will be the same one given to RDHs, and Wyant noted that it would not.

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 been enrolled, but has not yet been sent to the Governor for consideration.

b. SB136 (Figueroa) - Delays Requirement for Radiation Safety and Coronal Polishing Certification for RDA licensure for one year

Wyant noted that this is an omnibus bill, and the item of interest to COMDA is that it will delay the requirement that all currently licensed RDAs show proof of completion of Radiation Safety and Coronal Polishing certification for one year, as well as only require inactive RDAs to show proof of certification when they reactivate their licenses. She indicated that this is an urgency bill which will be effective upon signature by the Governor, rather than January 1st as is true of most bills.

c. SB1546 (Figueroa) - Scope of Practice for Dental Assisting

Wyant drew COMDA's attention to the Amendments Summary provided by The Alliance included in the packet, noting that a recent amendment of the bill has entirely stricken Sections 24 and 27. She explained that essentially the bill would create three areas of certification - Restorative, Orthodontic or Surgical. She explained that applicants would be required to take Dental Board approved courses to become certified in each of these areas, and that the RDA practical and written examinations would be eliminated. The bill would also require dental assistants to complete Board approved courses in Infection Control and California law.

Tim Hart, CDA, noted that Wyant had proposed some changes to the legislation that they were reviewing, but he foresaw no problems since the issues were mostly technical. In response to a question from Chair Drury-Klein regarding the effective date of the legislation, Hart advised that it would take effect as of January 1, 2007, with the exception of RDAs being allowed to do pit and fissure sealants in public health settings, which would be effective January 1, 2005.

Executive Officer Wyant reported that for future discussion, it came out of the meeting with the Director that some other agencies find it more cost-effective to renew licenses every four years. Wyant noted that with the low cost of the renewal fee, $35 for the two-year renewal, perhaps COMDA would wish to explore this option in the future.

Linda Madden, Dental Board, reported that after discussion this morning in the Business and Professions Committee, SB 1239, which extended the sunset dates for COMDA and the Dental Board appears dead, so the extension of sunset dates will be addressed in SB 1546.

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

It was M/S/P(Savio/Gipson) to recommend provisional approval to the Dental Board for the Dental Assisting program at Silicon Valley College in Fremont.

7. RDA Practical Exam Testable Procedures - Recommendation of Subcommittee

Executive Officer Wyant noted that the Subcommittee had reviewed all of the potential new RDA duties contained in the pending regulatory changes, and recommended that they not be tested at it is not feasible or practical for these particular procedures.

It was M/S/P (Gipson/Savio) to accept the Subcommittee's recommendation.

8. Required Coronal Polishing and Radiation Safety Courses for RDAs - Affidavit in Lieu of Certificate

Executive Officer Wyant noted that the statute requires "proof of completion", however many licensees have lost their documents or they have been destroyed, and they are unable to obtain duplicates because their school has closed. She reported that she had been approached regarding an affidavit being sworn under penalty of perjury and asked if COMDA would wish to pursue something along that line.

Lana Wright, educator, noted that she had taught at a school who is no longer in business, so if a person can prove graduation from a program that required Coronal Polishing and Radiation Safety as a component, then that should be considered. Tim Hart felt that CDA would most likely support an affidavit in hardship circumstances, with penalties for falsification.

Wyant noted that staff could delineate some recommendations to bring back to the next meeting. Drury-Klein offered to assist staff in this matter. Wyant noted that if the deadline is extended to January 1, 2006 by legislation, there will not be such urgency to the issue. It was M/S/P (Savio/Gipson) to defer to next meeting, when staff will present recommendations.

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

Executive Officer Wyant noted that included in the packet were proposed changes developed by Chair Drury-Klein, along with The Alliance's and CDA's proposed changes. Tim Hart, CDA, supported adoption of the proposed regulations, noting one of the changes suggests using a term more flexible than "darkroom". He reported that of 47 internship sites, 46 have digital equipment and the 47th is upgrading. He encouraged COMDA to adopt the proposed changes. It was M/S/P(Churchill/Dale) to accept the proposal with the changes and recommend that the proposed changes be set for hearing by the Dental Board.

10. Appointment of New RDA Examiners

Drury-Klein noted that the Subcommittee recommends approval of Kristie Nunes, Mary Holm, and Mary Jenkins (North) and Sheronda Walton (South) as new RDA Examiners. It was M/S/P(Savio/Gipson) to approve, and recommend approval by the Dental Board.

11. Appointment of Chief and Assistant Chief Examiners

Wyant noted that the RDH Subcommittee has made the selection of Chief and Assistant Chief, which only requires action if COMDA wishes to revoke the Subcommittee's action. COMDA approved the Subcommittee's action.

12. Proposed Restructuring of EF Examination Committee

Chair Drury-Klein noted that Executive Officer Wyant had given an excellent history and reasons for the proposal. Member Savio asked if Rhona Lee's proposed appointment as Chairperson would continue indefinitely with no term imposed. She asked if COMDA wants the coordinator to be an EF or a Dentist , believing that this is a stopgap measure. She asked who has been performing these duties during the past year. Wyant noted that staff and the EF Examiners have been handling the functions in the interim that there were no COMDA EF members, explaining that expertise in the process is required.

It was M/S/P(Savio/Gipson) that Ms. Lee be appointed for a four-year term, with the specification that training of a subsequent Committee Chair be directed.

13. Recommendation: Board Appointment of Subcommittee to Review RDH Law and Ethics Examinations and RDHAP Law and Ethics Examinations

Executive Officer Wyant felt that a two-member Subcommittee could be established to review the proposed Law and Ethics Examination developed by staff and that their recommendation be reviewed by a two-member committee appointed by the Board's Examination Committee Chair. JoAnn Galliano, CDHA, asked if an RDH COMDA Member appointed to this review Subcommittee becomes an RDHAP, would that compromise exam security. Wyant noted that there will be a bank of items that will be rotated, but the intent of the exam is not necessarily to test knowledge, but also for the candidate to gain knowledge and be aware of the law and ethical practice. She indicated that there are not the usual exam security issues.

It was M/S/P(Savio/Dale) that the Chair appoint a two-person Subcommittee to review the examination, and that it be recommended to the Board that its Examination Committee Chair appoint a two-person committee to review their recommendation. .

14. Appointment of New RDH Examiners

The RDH Examination Subcommittee recommended that Christine Dawson, Lisa Galasso, and Paulina Jo Attebery (South) and Ann Havlik (North) be appointed as new RDH Examiners. It was M/S/P(Churchill/Savio) to approve and to refer the matter to the Dental Board for approval..

15. Review of Necessity/Desirability of RDHAP Prescription Requirement

Executive Officer Wyant asked if the new COMDA wished to review this issue, as during the review of duties and Sunset Review process it was recommended by the COMDA that existed at that time that this requirement be eliminated. Wyant continued that the Consultant stated in their report to the Legislature that the prescription requirement should be changed, however COMDA at that time disagreed with the Consultant's proposed options, considering them to be even more restrictive than a prescription requirement. Wyant noted that this issue is before COMDA for its consideration.

Member Savio saw no need for change. Member Dale disagreed, noting that she lives in a rural area where it is a very large barrier to care, and felt that the entire oral health condition is evaluated by the hygienist. Member Savio felt that the prescription was necessary, as a dentist would also evaluate the patient and that way the patient would be informed twice of any conditions that should be addressed.

JoAnn Galliano, CDHA, noted that the initial Health Manpower Projects leading up to the legislation did not require a prescription, adding that studies showed that rather than seeing less dental care, more dental care was sought by patients seen by RDHAPs. She stated that the prescription requirement was something that simply had to be agreed to at the time for the bill to be enacted. She noted that RDHAPs working in nursing homes have difficulty getting a prescription, and liability insurance is sometimes an issue. She felt that the requirement definitely restricted access for some and was simply unnecessary, since there is no proven harm to the consumer.

Member Savio noted that physicians are on staff at all nursing homes, so it should be easy to obtain a prescription. JoAnn Galliano agreed that some facilities have an on-site physician, but not all do, and some have no dentist on staff at all. Tim Hart, CDA, noted that other policy issues are at play here. He stated that this change would require legislative action, and a better goal would be to improve access to care. He offered CDA's collaboration on any evidence that the prescription requirement is a barrier to care.

Chair Drury-Klein asked to defer this issue until the next COMDA meeting, and asked that any information on this item be sent to Executive Officer Wyant by the end of June. Wyant noted that she would bring the information from the Health Manpower Pilot Projects and the Sunset Review process to the next meeting.

Member Dale noted that she is in an extremely rural area where clinics have a waiting list of 6 to 8 months to see a physician. She stated that in such areas where care is the most needed, it is the least available, and this is where the prescription requirement is a noticeable barrier to care.

16. Review of Last COMDA Strategic Plan

Executive Officer Wyant noted that the Plan is outdated, as it was coming up for review when a quorum of COMDA was lost, then the new board was appointed. She indicated that this is an important working document, since funding requests are always predicated with "Where is this in your Strategic Plan?". She noted that this item is informational, no motion is necessary, but asked that members seriously read and consider what changes should be made during the August or November COMDA meeting.

17. Agenda Items for Future Meetings

Chair Drury-Klein asked that the course approval requirements be reviewed for Coronal Polishing and Ultrasonic Scaling along the same vein as was done for pit and fissure sealants.

Executive Officer Wyant noted that the changes in duties that have been held up in the regulation moratorium will have major impacts to the EF programs and examination, and these should be discussed at COMDA's next meeting.

18. Public Comment

None.

19. Adjournment

The meeting adjourned at 2:45 p.m.

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