For more than a year, PDA expressed opposition to expanding PHDHP site locations, believing it is inconsistent with the SBOD’ s charge to protect the public and ensure the same standard of care for all Pennsylvanians. PDA opposed the regulations over concerns about patient safety and the need to ensure that patients receive comprehensive diagnoses and treatment from dentists.
With the practice sites currently listed in regulation, the common denominator is that there are other health care providers on staff to provide assistance in case of a medical emergency while the hygienist is treating patients. That safety net would not exist if PHDHPs practiced in childcare and private settings of hospice and homebound patients, the definitions of which are too loosely defined.
PDA is also concerned that there would be nothing prohibiting physicians from hiring any number of PHDHPs and offering routine dental hygiene services void of any further examination by a dentist.
Though permitted by law in a physician’ s scope of practice, this practice could lead to removing the dentist from the dental care provided to these patients. Physicians’ limited training of oral disease and dental care would jeopardize the safety of these patients, many of whom might mistakenly believe they have received comprehensive oral health care by PHDHPs in physicians’ offices. The ability of physicians or the PHDHP to bill for these services could further deter the patient from seeking additional examination by a dentist due to limitations of insurance coverage or the additional costs of an added tier of professional services.
Despite opposition from PDA and other key stakeholders such as the Pennsylvania Academy of General Dentistry, the SBOD voted to draft regulations expanding PDHDP site locations to include the above, and released an“ exposure draft” to stakeholders in May, requesting initial comments within 30 days. PDA engaged members and lobbied consistently against the exposure draft over the summer months.
On September 15, the State Board voted 6-4 to proceed with regulations expanding Public Health Dental Hygiene Practitioner( PHDHP) practice site locations to include childcare settings, physician offices, and residences of homebound and hospice patients. Log on the Advocacy section of PDA’ s website at www. padental. org, for a summary of the SBOD’ s discussion and vote on the regulations.
Prior to the SBOD meeting, PDA’ s lobbyist and staff met with staff for the House Professional Licensure Committee( HPLC) to discuss concerns about expanding practice locations for PHDHPs. The HPLC, along with the Governor’ s Policy Office and Independent Review Commission( IRRC), are tasked with reviewing licensing boards’ regulations. They all play an instrumental role before regulations are finalized and enacted. HPLC staff took note of PDA’ s concerns about the PHDHP referral process with dentists, as well as the need for dentists to exam and diagnose in order for patients to receive comprehensive care. PDA will continue to lobby HPLC members and staff, as well as the SBOD, Governor’ s Policy Office and IRRC as the regulations move through the regulatory process.
It may take two or more years before regulations are enacted, so PDA will use every opportunity to amend the draft, with particular attention paid to the referral process, scope of practice in these settings, the role of physicians and liability. PDA’ s Government Relations Committee and Access to Oral Health Advisory Group will also review the adequacy of current educational and training requirements for PHDHPs to determine whether additional requirements are needed to ensure patient safety and appropriate standards of care.
Please contact PDA’ s government relations staff at( 800) 223-0016, or mss @ padental. org, with any questions or concerns.
NOVEMBER / DECEMBER 2017 | PENNSYLVANIA DENTAL JOURNAL 37