I m p ressio n s
An Incomplete Decision
by Dr. Stephen T. Radack III, Editor
I was planning to go to Harrisburg on
Friday, September 15 for a production
meeting for this publication and noted
that the Pennsylvania State Board of
Dentistry was meeting that day as well.
This was going to be a very important
meeting since the board would be voting to move forward with
adding practice locations for the Pennsylvania Health Dental
Hygiene Practitioners (PHDHP). I had only been to a handful of
state board meetings in the past, even when I was PDA
president. It is a long haul from Erie for half-day meeting, and I
was always fortunate to have colleagues and PDA staff who I
could count on to attend and represent PDA. But I was planning
to be in Harrisburg for this journal meeting and decided I would
just adjust my schedule and drive in Thursday night so I could
attend the SBOD meeting Friday morning.
As many of you may know, this PHDHP issue has been debated
by your PDA Board of Trustees and the Government Relations
Advisory Group since the “exposure draft” to change in practice
locations was first brought forward. There has been good
discussion both for and against adding additional locations, but
the PDA BOT voted to oppose physicians’ offices. The SBOD also
allowed written comments to be submitted prior to this
meeting but did not allow any testimony at the meeting. The
board received several letters, including one from your PDA
president, Dr. Bruce Terry, in opposition to the changes, as well a
petition from PAGD with over 600 signatures on it.
The meeting was standing room only, and in fact, an overflow
room with a live audio and video stream had to be set up for
the attendees once the main meeting room was filled. It was a
pleasure to attend with Dr. Terry, past president Dr. Bernie
Dishler and current PDA trustees, Dr. Matt Zale (Third District)
and Dr. Maria Tacelosky (Fourth District). When the discussion of
the PHDHP came up on the agenda, the board chair, Dr. Jack
Erhard, was very clear and straight forward in explaining the
issue, where it had been and what would happen going
forward depending on the vote. He allowed all board members
in attendance to speak and explain their position on the issue.
What was surprising, actually appalling, to me and several other
dentists in attendance was that there were three board
members not in attendance, two dentists and the Expanded
Function Dental Assistant (EFDA) representative. There were
also two dentist vacancies on the board at this meeting. The
SBOD is made up of 15 members: 8 dentists, 1 dental hygienist,
1 EFDA, 1 Consumer protection representative (currently from
the office of the Attorney General), a representative from the
Department of Health (currently a physician), 2 public members
and the Commissioner of Professional and Occupational Affairs.
So a vote to move forward with a major change in regulations
for the PHDHP by the State Board of DENTISTRY was taken with
4 dentists present and in the minority of those 10 who were
present to vote that day. How does that make sense? The chair
would have preferred to wait to take such an important vote to
have all members in attendance, but the decision was
ultimately to have this issue voted on that day with those in
attendance. The vote to approve the “exposure draft” regulations
to add practice locations for PHDHPs to include: a) private
settings of hospice and homebound patients, b) primary care
settings, and c) childcare settings, were approved by those
board members in attendance 6-4, with 3 dentists and the
Attorney General Office representative voting no.
The changes will now enter the regulatory process, which
requires review by the Governor’s and Attorney General’s offices,
public comment (which PDA will submit), and comments from
the standing licensure committees of the General Assembly and
the Independent Regulatory Review Commission, and a fiscal
note. All of these will be taken into consideration by the SBOD
before issuing the regulations as final.
I am not going to use the power of my position to debate the
changes in the regulation, but am going to express my concern
that this board moved forward with this vote with three
members absent, two of them dentists. Would having those
three members present have changed the outcome of the
vote? I can’t say, but with such an important issue on the table
would it not been prudent to postpone the vote until the
board’s next meeting?
An even bigger concern to me is why there were two vacant
dentist positions on the board. Don’t the dentists, licensed
dental professionals and the public deserve a full complement
of board members on a professional licensing board, especially
when discussing regulations and licensure issues? I don’t know
the process on how a board member is selected or why it
appears that it takes so long to fill a vacancy, but I do know that
your PDA has submitted a slate of dentist candidates to the
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