On Nov. 3, 2022, the Colorado Dental Board met to adopt rules for dental therapy and license portability, among other topics. Dr. Leah Schulz and Dr. Jeff Kahl testified for the CDA at the hearing. Highlights from the CDA’s comments included advocacy for:
Proposed Dental Therapy Rules
- Removing occupational portability provisions that could allow licensed dental therapists in other states to transfer licenses to Colorado without meeting full Colorado training standards, as occupational portability was specifically excluded for dental therapists in law.
- Preserving full competency demonstration for advanced procedures in any Practice Hour Waivers granted by the dental board to applicants who have previous dental therapy or dental hygiene experience.
- Delineating clear examination requirements for applicants for dental therapy licenses.
- Aligning dental therapist continuing education (CE) requirements with approved dentist CE course providers.
- Ensuring temporary licensees have full oversight by a dentist that complies with any supervision and oversight requirements.
- Removing rule language that could incorrectly imply that a dental therapist could own a practice (they cannot under current law), including clarifications to rule language on advertising.
- Streamlining local anesthesia permitting given duplicative CODA training requirements that apply to all applicants.
- Adding detail on Supervision Limit Waivers to specify how often permits must be renewed and criteria for waiver review.
Other Dental Rule Proposals
- Maintaining CODA degree conversion programs required in law for foreign-trained dentists transferring licenses to Colorado.
- Avoiding elimination of current competency demonstration for dentist license applicants transferring a license from another state.
Much of the dental board’s deliberation was taken to executive session rather than discussed on public record. The CDA was successful on nearly all its requests to the dental board.
The dental board was not fully aligned with the CDA on a few items. The dental board did not feel it had current legal authority to maintain requirements for clinical competence demonstration for dentist license applicants transferring a license from another state, nor to streamline local anesthesia permits for dental therapists. In waiving training hour requirements for dental therapists, the dental board did not adopt the level of specificity the CDA requested on case-by-case reviews, but the intent is likely to be met with the outlined process. Dental therapist references in the advertising rule were also not fully aligned to the CDA’s requested revisions, but no significant consequence is expected from the oversight. Any items that prove problematic in implementation can be further addressed by the CDA during the dental board’s upcoming Sunset Review process.
Finally, the board received a request to open rulemaking regarding non-dentist anesthesia providers. A rule will be proposed for consideration at the Jan. 11 dental board meeting to address how anesthesiologists and nurse anesthetists can assist with sedation in dental offices, as well as permit requirements for these types of providers.