There is a critical need for additional training or certification for RDH's to adequately perform the duties required for remote supervison.  In my clinical experience, only about 20% of the RDHs I have hired have the diagnostic/examination skills required when seeing a patient without a licenced dentist present.

Apparently, current hygiene training programs in Virginia are failing to teach basic dental diseases, diagnoses, and treatment to their students.  Hygienists should be able to recognize decay and periapical pathosis clinically and on radiographs, know how to reconize pulpitis and cracked teeth, and easily identify an abcessed tooth through observation of a fistula or a sudden increase in a periodontal pocket from a previous visit.

My experience has found the majority of hygienists in the Commonwealth lacking in these basic skills.  Two hours of CE will not cover this lack of training.   A better idea would be a proctered online test of clinical diagnostic skills.  Therefore the RDH's that have these skills would not be penalized.  Should a hygienist fail the test, they should have their license put on probabtion until they take an 8 hour CE class at their expense and pass the proctered online test.

Dentists in Virginia have for too long had to put up with very poor performing dental hygienists that do not meet the standards of their training.  They demand top pay and fail to regularly perform periodontal exams, recognize dental problems and work with the DDS to take needed radiographs and diagnostic records, and way too many don't understand dental disease and treatment in order to educated our patients.  

Dentristry in Virginia is under extreme stress with lagging, low reimbursement from insurance companies, a severe shortage of licensed hygienists outside of the urban areas and outside of a 45 mile radius of a dental hygiene schools.  Well trained and good performing dental hygienists are vitally needed to help dentists keep their patients cared for and to help keep general practices financially viable.

I believe the Board would be surprised if they sent out a survey to general dentists about the skills and quality of the hygienists availble here in Virginia.  Having practiced 30 years in the Commonwealth, I have unfortunately seen the quality and quantity of RDH's continue to decline, forcing dentists to compromise the quality of care offered to their patients.

The 2 hour CE requirement for hygienists practicing under remote supervision guidelines is inadequate primarily due to the deficiencies in certain undergraduate training programs. Even 4 year programs offering BS and RDH degrees manifest shortcomings in: 1.understanding the concept of therapeutic endpoints in periodontal disease management, 2. communicating basic prevention concepts (understanding that one-size does not fit all), 3. critical acknowledgement as to one's limits in "hygiene therapy", which in essence should be periodontal therapy, 4. Understanding the concept of the hygienist as a co-therapist versus a substitute for a trained specialist with post graduate certification and qualifications. According to §54,1-2722F "A dental hygienist ...may continue to treat a patient for 90 days. After such 90-day period, the supervising dentist,...shall either conduct an examination of the patient or refer the patient...". However, under 18VAC60-25-60 "A licensed dentist assumes ultimate responsibility for determining with the patient or his representative the specific treatment the patient will receive...". So how does one reconcile the conflict that the dentist assumes the "ultimate responsibility" but without the requirement to assess the patient prior to delivery of treatment in the remote supervision scenario?! I would not want to place myself in that position. This perspective comes from one who has practiced for over 40 years, has served as an adjunct clinical instructor in dental hygiene programs, and serves in free clinics where remote supervision applies. To summarize, CE for remote supervision is indeed indicated and necessary, but it would need to be within a meaningful context of comprehensive education supplanting the current educational shortcomings. Two hours does not satisfy that need.

I would like to thank the Board of Dentistry for the opportunity to provide comment regarding the CE requirement for Remote Supervision.  The CE course requirements as outlined by the Board of Dentistry, intended for the clinically experienced Registered Dental Hygienist beyond initial licensure, provide appropriate guidance and information in the specific areas of:

• Intent and definitions of remote supervision; 
• Review of dental hygiene scope of practice and delegation of services;
• Administration of controlled substances;
• Patient records/documentation/risk management;
• Remote Supervision laws for dental hygienists and dentists;
• Written practice protocols; and
• Settings allowed for remote supervision.

After taking the VDHA Remote Supervision CE, I am well prepared to work together with my dentist to provide dental hygiene services under Remote Supervision.  Thank you for providing the Rules and Regulations to practice under Remote Supervision.

Many thanks to the Board of Dentistry for this opportunity to comment on the required continuing education course for dental hygienists prior to practicing under remote supervision. I am a retired dental hygienist, having worked both in the private and public sector for over forty years. The last ten years of my professional experience was spent as a program manager with the Virginia Department of Health (VDH) Dental Health Program, where I had input into the original protocol for the VDH remote supervision dental hygienists pilot program, managed the early child oral health program and supervised multiple hygienists who were practicing under VDH’s successful model of care under the remote supervision of a VDH dentist.  Although the VDH model technically requires no Continuing Education course, management provided training specific to the parameters of the new law and the early child and school remote settings. Much of the material covered, e.g. adherence to written protocols, documentation, risk management, etc. was similar in content to the Virginia Dental Hygienists' Remote Supervision CE Course. The VDHA CE course follows the parameters set forth by the Board of Dentistry, and assures that, as hygienists embark on providing care in new settings, they are fully knowledgeable regarding the laws and regulations. The two hour time period allows for sufficient and appropriate coverage of the content required by the BOD.   

On behalf of the Virginia Dental Hygienists’ Association (VDHA) that represents the 5,894 licensed dental hygienists in the Commonwealth, I would like to thank the Board of Dentistry for the opportunity to provide comment regarding the CE requirement for Remote Supervision.  We speak in support of the “no less than” 2-hour Remote Supervision Continuing Education as outlined by the Board of Dentistry. 

The specific subject areas that are covered in the Remote Supervision CE include: Intent and definitions of remote supervision; Review of dental hygiene scope of practice and delegation of services; Administration of controlled substances; Patient records/documentation/risk management; Remote Supervision laws for dental hygienists and dentists; Written practice protocols; and Settings allowed for remote supervision.

It should be noted that VDHA members developed a model Remote Supervision CE program that includes all the outlined Board of Dentistry required subject areas for the clinically experienced (minimum two (2) year clinical experience consisting of at least 2,500 hours) hygienist to take prior to practicing under Remote Supervision in collaboration with their supervising dentist.  The individuals who developed that model CE include one who has served in the Department of Health Remote Supervision program and educators from 3 of the CODA accredited Dental Hygiene programs in Virginia.  VDHA and our component organizations have provided this CE to hygienists in Virginia over the past eighteen months; it typically takes the full two hours to present and then a small period of time for question and answer discussion.

Thanks to Virginia General Assembly legislation, Virginia Department of Health dental hygienists have worked since 2009 under “remote supervision.  By 2012, the program was such a success that it was expanded throughout the Commonwealth.  When it comes to risks associated with the remote supervision model, you need look no further than the Virginia Department of Health Program.  In their 2014 Report to the Virginia General Assembly, the Virginia Department of Health reported that there have been no patient safety concerns for dental hygienists over the last seven years providing care to Virginia’s most vulnerable and any concerns about safety and efficacy should apply regardless of the income level of the recipient of care. 

In 2016 and 2017, VDHA and VDA (Virginia Dental Association) together brought forward the legislation to permit the Remote Supervision of Dental Hygienists to be extended to other hygienists who do not work in the Department of Health.  This successful collaboration resulted in legislation that extends access to dental care specifically to federally qualified health centers; charitable safety net facilities; free clinic; long-term care facilities; elementary or secondary schools; Head Start programs; or women, infants, and children (WIC) programs.