The Colorado Board of Health will meet in coming months to consider sweeping changes to the x-ray regulations that govern healthcare providers. Significant impacts for the dental profession are anticipated if the rules are adopted in current form.
The most impactful change proposed in the rule is the requirement for implementation of rectangular collimation for dental x-ray equipment by 2022. While the American Dental Association has recommended the use of rectangular collimation for years in order to reduce patient exposure, the CDA is very concerned about the process that has been used to this point to propose rectangular collimation in Colorado. The cost for each dental office to implement this requirement could be up to $2,000 per dental office on average, with an aggregate cost to the profession of between $1.5M (state estimate) and $5M (higher end estimate that includes top quality collimators and added training for dental teams). While rectangular collimation has been shown to reduce patient exposure when used correctly, some argue that there is a questionable patient benefit due to extra exposure in retakes associated with the narrower margin of error on these images. Next week, the Board of Health will determine whether the added value in patient safety outweighs the substantial aggregate cost to the dental profession to implement the requirement, especially given the lack of notice to the profession and a relatively short implementation timeline. At minimum, the CDA will argue that the implementation timeline should be extended given the lack of dental profession inclusion in review of the final proposal.
Other added requirements for the dental profession in the rule include annual inspection of protective equipment (aprons, collars, etc.) and increased quality assurance program requirements. A copy of the proposed rules can be accessed here (note: please exercise caution in printing as the document is 200 pages in length).
You are welcome to share any thoughts on this topic with the Board of Health directly by submitting written comments to cdphe.bohrequests@state.co.us. Please copy Kelsey Creehan (kelsey@cdaonline.org) at the CDA on any written comments submitted so we can make sure your comments are represented at the future hearing (date to be determined). Please submit comments by Oct. 18, 2019.