NDA Journal 14 August 19, 2024 American Legislative Exchange Council Board of Directors Alexandria, VA RE: ALEC Model Policy on Dental Therapy Dear Members of the ALEC Board of Directors, As America’s leading advocate for oral health, the American Dental Association is committed to advancing access to quality oral health care for all. This includes workforce innovations that allow for dentists to delegate procedures to appropriately educated and trained practitioners, thereby increasing access to care. However, central to this belief is the conviction that in the best interests of the public, only dentists, equipped with comprehensive education and training, are the qualified professionals to diagnose dental disease, identify oral pathology such as oral cancer, perform surgical and irreversible procedures and supervise procedures by allied dental team members. On July 26, 2024, the ALEC Health and Human Services Task force approved, by a vote of 10-9, a model legislation on dental therapy that falls short of meaningfully increasing access to care in an appropriate, timely, and economically feasible way. Therefore, the ADA opposes adoption of this model and asks that you not support its final approval. The dentist is ultimately responsible, ethically and legally, for patient care as acknowledged by the proposed model legislation -- “A supervising dentist shall accept responsibility for all services performed by a dental therapist pursuant to a collaborative management agreement.” The weight of this responsibility requires that the dentist be the healthcare provider that performs examinations/evaluations; diagnoses; treatment planning; and surgical/ irreversible procedures; prescribes work authorizations; prescribes drugs and other medications; and administers enteral, parenteral or inhalational sedation, or general anesthesia. Although the model proposed by the taskforce places the “responsibility of all services performed by a dental therapist” on the dentist, it allows the therapist to: • Conduct an oral evaluation and assessment of dental disease and formulation of an individualized treatment plan. • Evaluate radiographic images. • Administer nitrous oxide. • Perform services such as suture placement, pulpotomy on primary teeth, tooth reimplantation and stabilization, etc. • Perform a nonsurgical extraction of periodontally diseased permanent teeth with tooth mobility. • Directly supervise a dental hygienist and authorize them to perform procedures as well as supervise unlicensed individuals who are allowed to perform “remediable” procedures in accordance with a treatment plan approved by the therapist. We note that “oral evaluation” as defined by the Code on Dental Procedures and Nomenclature (CDT Code) includes a thorough evaluation and recording of the extraoral and intraoral hard and soft tissues including an evaluation for oral cancer, the evaluation and recording of the patient’s dental and medical history and a general health assessment. It may require interpretation of information acquired through additional diagnostic procedures. The purpose of these activities is to reach a fully informed diagnosis and individualized treatment plan for each patient. Given this definition, this model allows a dental Featured Article
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