GOVERNMENT RELATIONS continued
Botox Injection policy statement In March 2013 , the SBOD released its draft policy statement on the administration of botulinum toxin ( botox ) and dermal fillers . This policy statement is intended to provide guidance to dentists and the general public regarding the use of these products by dentists within the scope of practice of dentistry .
The proposed policy statement stipulates that dentists may administer botox and dermal fillers so long as the following criteria are met :
• The administration of botox and dermal fillers is considered a dental procedure ( and therefore falls with the scope of dental practice ) when used for the treatment of maxillofacial trauma or dental conditions involving the human teeth , jaws or associated structures , or when administered to the jaws or structures associated with the human teeth or jaws . Any procedure performed by a dentist must be confined to the human teeth , jaws or associated structures , in accordance with the definition of the “ practice of dentistry ” in section two of the Dental Practice Act .
• The dentist is properly trained to competently administer botox and dermal fillers .
• The dentist takes a medical history , performs an examination and renders a treatment plan prior to administering botox or dermal fillers .
• The dentist discusses risks , options and benefits with the patient prior to the procedure .
• The dentist obtains written informed consent from the patient and documents such in his or her record . Date ( s ) of service and procedure ( s ) performed must be recorded in the patient ’ s record .
The SBOD ’ s Scope of Practice Committee is currently discussing how to define “ associated structures ” of the teeth and jaws , as the policy statement will most likely read that dentists should administer botox / dermal fillers in those areas only . PDA expects the committee to revise its draft policy statement before it is published as proposed rulemaking , inviting public comment and review by other governmental agencies .
Updates to existing regulations
The SBOD ’ s counsel is conducting a thorough review of the board ’ s existing regulations to determine where updates are unnecessary . At its June meeting , counsel made the following recommendations :
• Update the policy statement on use of lasers .
• Update advertising regulations to include all ADA-recognized specialties and advertising for corporations .
• Update anesthesia regulations to include newly-approved peer review organizations . The regulations should also clarify whether permits are needed to administer oral sedatives .
• Propose regulations recognizing the law requiring patient identification on most dental appliances and dentures .
• Update regulations to provide a mechanism for the board to rescind an individual ’ s radiology certificate when a violation has occurred .
• Update CE regulations to include a deadline for which individuals may apply for waivers . The board should also update the approved program sponsor list .
• Propose regulations implementing the new legislation requiring malpractice insurance .
• Consider amending regulations to allow public health dental hygienists to supervise EFDAs and dental assistants under specific circumstances .
Over the next few months , legal counsel will work with the SBOD to fine tune updates to the current regulations . Any proposed changes will be subject to public scrutiny when drafts are sent to stakeholders for initial comment , before they are published as proposed rulemaking in the Pennsylvania Bulletin .
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