Fall 24 www.nvda.org 15 August 19, 2024 Page 2 therapist to diagnose dental disease. The training and education required to perform services as a dental therapist does not prepare individuals to diagnose dental disease, identify oral pathology such as oral cancer and determine an individualized treatment plan. The primary purpose of dentists delegating functions to allied dental personnel is to increase the capacity of the profession to provide patient care while retaining full responsibility for the quality of care. When delegating, the degree of supervision required to assure that treatment is appropriate and does not jeopardize the systemic or oral health of the patient varies with the nature of the procedure and the medical and dental history of the patient, as determined with evaluation and examination. In this context, the proposed model allows a dental therapist to perform services under “general supervision” defined as “the dentist is not present in the dental office or other practice setting or on the premises at the time tasks or procedures are being performed by the dental therapist, but that the tasks or procedures performed by the dental therapist are being performed with the prior knowledge and consent of the dentist”. “Prior knowledge and consent” alone, in our view, is insufficient to support diagnosis, treatment and supervision of other allied personnel. The dentist is the qualified professional to diagnose dental disease, and written standing orders are not a substitute for obtaining a diagnosis. The ADA believes that the development of any new member of the dental team be based upon determination of need, a CODA-accredited dental school or advanced dental education program, and a scope of practice that ensures the protection of the public’s oral health. Failure to specify that dental therapists must graduate from a program accredited by the Commission on Dental Accreditation (CODA), the only body in the United States tasked with evaluating dental education programs, which includes dental therapy; and failure to assure that the patient first become a patient of record examined by the dentist raise significant concerns for the ADA. The ADA believes that any patient to be treated by a dental therapist as authorized by this model legislation must first become a patient of record of a dentist. A patient of record is defined as one who: a. has been examined by the dentist; b. has had a medical and dental history completed and evaluated by the dentist; and c. has had his/her oral condition diagnosed and a treatment plan developed by the dentist. Furthermore, the stipulation around informed consent within this model states the following: “Any dentist or dental therapist who treats a patient shall inform the patient about the availability of reasonable alternate modes of treatment and about the benefits and risks of these treatments. The reasonable dentist standard is the standard for informing a patient under this section. The reasonable dentist standard requires disclosure only of information that a reasonable dentist would know and disclose under the circumstances.” This inappropriately places the burden on the dental therapist to be able to explain treatment plans and alternatives to patients to the same level as a dentist who has much more expansive education and qualifications, all while the dentist takes full responsibility for the actions of the dental therapist. In addition to our concerns expressed above, we maintain that there appears to be little appetite for dental therapy in states that have adopted authorizing legislation. Advocates have long asserted that dental therapy would address dental workforce shortages, particularly in rural areas and other areas with underserved populations. This has not come to fruition. Despite fourteen states having passed some form of dental therapy legislation, most of these states do not have a single therapist practicing or even licensed years after passage of their legislation. While pilot projects exist on tribal lands in Oregon, Washington, and Idaho, the vast majority of dental therapists continue to practice in Minnesota. A report from 2019 indicated that about 73 percent of dental therapists in Minnesota work in a metropolitan areai, and 139 total dental therapists had active licenses in Minnesota as of April 2024ii. The state of Minnesota provides detailed healthcare workforce dataiii, including work status, average hours worked, time spent providing patient care, and other metrics, for dentists, dental hygienists, and dental assistants. However, it does not track such data for dental therapists. This lack of transparency makes it virtually impossible for policymakers to determine whether dental therapists are making a measurable impact in improving access in rural and underserved areas as intended. Featured Article »
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