Late last week, the Colorado Department of Regulatory Agencies (DORA) released its long-awaited report concerning the regulation of a
type of dental assistant who could practice with an expanded scope to help address the workforce needs of the dental profession in Colorado. For several reasons, detailed in the linked report below, DORA recommended, “Do not regulate oral preventative dental assistants.”
Read the full DORA report here: https://coprrr.colorado.gov/archive-of-reviews
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Background:
In June of 2023, the CDA House of Delegates (the CDA’s governing body), passed Resolution 32-23-HS directing the CDA Dental Assistant Scope of Care Task Force to complete a Sunrise Review Application through DORA to expand the dental assistant scope of care to include periodontal probing and supra and subgingival calculus removal from teeth.
The CDA task force met every other week from July to December 2023 to complete the Sunrise Review Application and corresponding Mandatory Continuing Education Application. The CDA submitted the applications to DORA at the end of December 2023. DORA accepted the application for review in early 2024.
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The Below Highlights are Direct Quotes from the DORA Report:
• The General Assembly established the sunrise review process in 1985 as a way to determine whether regulation of a certain profession or occupation is necessary before enacting laws for such regulation.
• During the sunrise review, staff from the Colorado Office of Policy, Research and Regulatory Reform performed a literature search, interviewed the sunrise applicant, contacted regulators in Colorado and other states, reviewed laws in other states and interviewed stakeholders. No states currently authorize dental assistants to probe periodontal pockets or remove tartar below the gumline.
• The Applicant [CDA] proposes creating a new type of dental provider, referred to as an “oral preventative dental assistant,” who would be authorized to perform the tasks of a dental assistant and the following dental hygiene procedures:
• Periodontal probing,
• Removing tartar above the gumline, and
• Removing tartar below the gumline.
• It should be noted, however, that the sunrise process is not geared toward evaluating workforce issues or whether a particular type of provider is needed or should be authorized. The purpose of a sunrise review is to determine whether regulation is necessary to protect the public.
Workforce Timeline/Hygiene Program Updates:
While CDA membership remains split on the issue of regulating dental assistants, a significant factor to note is that regulating a profession in Colorado takes substantial time due to the legislative and regulatory timetable, not to mention the anticipated time needed to establish a CODA accredited training program and educate providers.
If the regulation of dental assistants were further pursued and was successful, the CDA estimates that expanded functions for dental assistants would not be available any sooner than 2029. And because the hygiene workforce shortage was a primary motivating factor to pursue this expanded dental assistant scope, it is notable that the number of hygienists graduating in the state is projected to nearly triple by the year 2028.
Colorado hygiene program updates:
Metro Denver
• Concorde Dental Hygiene Associate Degree Program increased its class size from 24 to 32 in 2023. This is an 18-month program, and the students from the first increased class will graduate in 2024. Some years there are 32 graduates and some years there are 64 depending on cohorts.
• Community College of Denver Dental Hygiene Program increased its class size from 24 spots to 40 in 2023, with its first increased class of students graduating in 2025. CCD has a bachelor’s completion program, which will help equip more hygienists with bachelor’s degrees, so they are qualified to become faculty for hygiene programs.
Western Colorado
• Colorado Northwestern Community College Dental Hygiene Program in Rangely, CO has a class size of 24-26. They also added a bachelor’s completion program this year.
• Colorado Mountain College’s first dental hygiene cohort will start this month (July 2024) with a May 2026 graduation date. The class size will be 10.
• Colorado Mesa University in Grand Junction has a new hygiene program under consideration. They started their needs assessment surveys and are beginning the accreditation project.
Northern Colorado
• Front Range Community College in Fort Collins plans to accept its first class in 2025, depending on the accreditation site visit in the fall of 2024. The class size will be 20.
Southern Colorado
• Pueblo Community College Dental Hygiene Program has a class size of 24-26. PCC has a bachelor’s completion program, which will help equip more hygienists with bachelor’s degrees, so they are qualified to become faculty for hygiene programs.
• Pikes Peak Community College will soon admit 30 dental hygiene students per year and up to 36 dental assisting students per year. Their first class of students will start in the summer of 2025.
• Colorado Academy of Vocational Technology submitted their CODA accreditation application in the fall of 2023 and are waiting for a site visit date. The anticipated opening date is summer of 2025. The class size will be 20 students per cohort (with three alternating cohorts). They are expecting to graduate three cohorts per year for a total of 60 graduates per year.
Final Remarks:
In conclusion, the DORA sunrise report recommended to not regulate dental assistants. While the recommendation is not required to run future legislation, the state recommendation in the report will be used to defeat any such bill. Leadership and staff from the CDA continue to sit on several dental hygiene program advisory boards and will continue to advocate for education expansion to address workforce shortages.
