Thank you for the opportunity to respond to the Notice of Intended Regulatory Action (NOIRA) regarding proposed amendments to 18VAC60-21-240 and 18VAC60-25-210 to expand the type of refresher courses reinstatement applicants may take and to amend these regulations to clarify that the number of course hours required, and the amount of didactic training and clinical training required, will depend on the number of years a dentist or dental hygienist has been out of practice.

We applaud the Board for recognizing the limited menu of refresher course options available to dentists and dental hygienists applying for reinstatement or reactivation and initiating action to address that situation.

The Virginia Dental Hygienists’ Association (VDHA) advocates for continued competence, lifelong learning and ongoing professional development for dental hygienists, and we recognize that the important component of that is continuing education for license reinstatement.

We support efforts to expand the type and options of license reinstatement refresher courses. In developing standards for those courses, we encourage the Board to focus on didactic and clinical requirements necessary in demonstrating continued competency. Individual applicant assessment should establish the number of course hours needed rather than numbers stipulated by regulation.

Thank you

Catherine Berard, BSDH, RDH

VDHA Public Health and Professional Affairs Council Chair