Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Dentistry
 
chapter
Regulations Governing the Practice of Dental Assistants [18 VAC 60 ‑ 30]
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12/30/20  11:27 pm
Commenter: Marlene Rhodes CDA, BSDH, RDH

Opposed to DAII OJT
 

There are multiple reasons this petition should not be considered, the top two for me are training and liability.

As adjunct faculty at a CODA accredited dental assisting program the training and clinical aspects of expanded function education is of upmost importance.  Educators are well trained, faculty/staff undergo a calibration of sorts to produce graduates who can all pass the same extensive testing and board examinations.  This is true of all dental schools, hygiene programs and assisting programs who are accredited.  When you think back on your education, remember all of the different clinical faculty and the vast differences between them and expectations they each placed on you as a student.  Also remember the multiple patients and learned techniques used to become the efficient practitioners you are now.  Once graduating you each found your own preferred way to practice.  Each doctor has their own way of completing treatment.  Once completing a program where they learn the basic skills, assistants are on the job trained by whom they work for the specifics of that doctor’s four handed technique.  This is standard because the assistant is doing just that, assisting.  Restorative general dentistry takes years to become proficient in even with the benefit of faculty/staff who can truly take the time to “teach” skills.  I cannot imagine there are many practicing dentists who have the time, calibrated education training or willing patient base to accomplish proficiency for expanded function criteria.  To have an assistant be on the job trained for expanded function assisting is simply not a beneficial way to achieve the required quality clinical skills set by CODA accredited programs.

On to liability.  Once an assistant has completed an accredited program for expanded function and has passed the clinical exam as well a written exam he/she is responsible for his/her own liability and treatment outcomes.  If on the job trained, who will ultimately be liable for subpar treatment?  This alone should deter this moving forward.  I fear the assistant could deflect liability based on training if there is not a clear standard set forth such as in a CODA accredited program. 

As a former assistant who would have met the years criteria in the petition I can promise, based on the multiple practitioners with whom I have worked, there is no way this type of on the job training would come close to meeting the necessary training for an assistant to be as proficient as required by the state of Virginia and it’s licensing board.

Thank you for your consideration of my opposing this petition,

Marlene Rhodes CDA, BSDH, RDH

Adjunct Faculty J Sargeant Reynolds Community College

VDHA 02 Component Chair, VHyPAC Director, Legislative Chair

CommentID: 87904