PAGD Keystone Explorer Fall 2019

18 www.pagd.org Regulations Subcommittee The regular board meeting was proceeded by a meeting of the SBOD Regulations Subcommittee. Board counsel reported on the proposed regulatory package that added independent practice sites for Public Health Dental Hygiene Practitioners (PHDHPs). The draft annex that was on the agenda amended the original regulations to cross-reference sections concerning satellite locations for physicians’ offices and break up some sections for formatting reasons. The section allowing for PHDHP independent practice in places of residence was removed. A board member noted the scope of practice for a PHDHP practicing independently allowed them to take radiographs but did not allow them to read radiographs for diagnostic purposes. It was suggested that a PHDHP could refer to a dentist for radiograph interpretation. Another board member had serious concerns with a PHDHP continuing to treat patients that failed to follow through on a referral. She noted that other states require documentation that a patient had seen a dentist before allowing for continued independent hygiene treatment. She also expressed concern that the regulation did not include language indicating a PHDHP should practice in a public health setting and could “open up a free for all” and create opportunities for abuse through excessive billing. The topic generated discussion among the board members, but it was noted that this line of discussion exceeded the purpose of what the board was there to accomplish, which was to consider additional practice sites. The question was raised whether a PHDHP could bill insurance for services. It was later noted that via a MA bulletin in August 2017, PHDHPs can bill MA insurance plans and three HealthChoices plans had taken steps to implement fee schedules and procedures for PHDHP care. Helen Hawkey of the Pennsylvania Oral Health Coalition was asked to testify. She made note of the MA plans that were establishing billing protocols and described some of the PHDHP programs that were currently operating in the state. She provided statistical evidence of the follow- through rates for referrals, but many board members felt that this was a small sample size from specific programs and would not represent the entirety of the PHDHP system. Ms. Hawkey drew responses from several board members with an assertion that if someone did not follow through on a referral to a dental home, there was no harm in having someone clean their teeth without an exam. Several board members responded with oral pathology diagnoses that would make cleaning without an exam potentially hazardous. She also noted that a PHDHP has never been cited by the board for disciplinary reasons, which some board members refuted as not applicable to their qualifications to practice independently. Dr. Bernie Dishler from PDA presented a history of the addition of physicians’ offices as independent practice sites. He noted that, as more people went to physicians than dentists, physicians were encouraged to learn to do preliminary oral health screenings and fluoride varnishes. Many physicians wished to implement this but asked if a hygienist could be brought on staff to complete it. Dr. Dishler recommended limiting the practice to pediatric physicians’ offices, but that was disparaged by some board members. Dr. Angel Stout of the Pennsylvania Chapter of the American Academy of Pediatric Dentistry was called to testify. She reported that without statistics, it is impossible to know how effective PHDHP treatment is, and it should never have entered serious consideration without this evidence. She provided the board with a breakdown of where PHDHPs are located, along with dental offices and pediatric dental offices. She noted that in many rural locations of Central Pennsylvania, there are few practitioners of any type, leading to the concern that this regulation will add little relief to rural access issues. A board member asked a representative from the Pennsylvania Dental Hygienists’ Association what other State Board of Dentistry Report Meeting Summary September 13, 2019 \ advocacy