Dear Distinguished Members of the Virginia Board of Dentistry:

I am writing on behalf of the Dental Assisting National Board, Inc. (DANB) in connection with the petition for rulemaking to amend requirements for a Dental Assistant II that is currently the subject of a public comment period ending December 31, 2020.

As you may know, DANB is the ADA-recognized national certification board for dental assistants and administers the nationally recognized Certified Dental Assistant™ (CDA^®) certification program and four other certification programs for oral healthcare workers, including the Certified Restorative Functions Dental Assistant (CRFDA^®) certification. DANB’s CDA certification is required for registration as a Dental Assistant II in Virginia. DANB’s mission is to promote the public good by providing credentialing services to the dental community; as part of that mission, DANB collects and compiles information about dental assisting laws and regulations across the country and serves as a resource to stakeholders seeking information about dental assisting practice in any of the states.

About DANB Certification Eligibility Requirements

The petitioner has asked the Virginia Board of Dentistry “to amend regulations to create a pathway for dental assistants with 5-10 years of experience to take the Certified Restorative Functions Dental Assistant exam and have the employing dentist observe and approve of their capabilities to be a dental assistant II.”

The wording of the petition seems to indicate that the petitioner believes the Virginia Board of Dentistry has the authority to alter or amend the DANB CRFDA certification eligibility requirements. Although we know the Board is aware it does not have such authority, for the benefit of all stakeholders participating in this discussion, we would like to explain that CRFDA certification is a private certification program developed and administered by DANB, and only DANB’s Board of Directors may make changes to certification eligibility requirements. Individual states may recognize or require one or more component exams that make up CRFDA certification to earn a state-specific license, registration or certificate, or states may require that an applicant for a state credential earn CRFDA certification, but states do not determine the content of the exams or the certification eligibility requirements.

Having said that, however, we would also like the Board and stakeholders to be aware that DANB does consider input from stakeholders about certification eligibility requirements when those requirements are periodically reviewed, and that any feedback about DANB certification may be submitted via email to Dr. Johnna Gueorguieva, DANB’s Chief Credentialing and Research Officer, at jgueorguieva@danb.org.

About CRFDA Certification

If the Board is interested in establishing a pathway to the Virginia Dental Assistant II credential that includes successful performance on the CRFDA certification exam as one of the requirements, allow me to provide the following summary of CRFDA certification eligibility pathways:

Pathway I

1.   Current or former DANB CDA certificant whose certification lapsed for no more than two years.

2.   Current hands-on CPR, BLS or ACLS from a DANB-accepted provider.

Pathway II

1.    Graduation from a Commission on Dental Accreditation (CODA)-accredited dental assisting or hygiene program, or Registered Dental Hygienist (RDH) status (from any state except Alabama).

2.    Current hands-on CPR, BLS or ACLS from a DANB-accepted provider

Pathway III

1.    Completion of an Expanded Functions Dental Auxiliary (EFDA) or restorative course/program offered by an institution with a CODA-accredited dental assisting, dental hygiene or dental program. Each function does not have to be listed separately, but the documentation must indicate that expanded functions/duties or restorative functions/duties were included in the course curriculum.

2.    Minimum of 3,500 hours work experience as a dental assistant, accrued during the previous two to four years; employment must be verified by a licensed dentist.

3.    Current hands-on CPR, BLS or ACLS from a DANB-accepted provider

I have also sent a copy of this letter to the Board via email. That email message includes an attachment (Attachment 1) containing exam outlines for each of the four component exams that make up the CRFDA certification.

As the Board considers the petitioner’s proposal, we direct your attention to Pathway I above, which is the only pathway that would allow an individual who has not completed formal education to qualify for CRFDA certification. Candidates for DANB’s CDA certification must either graduate from a CODA-accredited dental assisting program or complete 3,500 hours of work experience over a two- to four-year period to meet CDA eligibility requirements. (There is also a third CDA eligibility pathway for dentists trained outside the U.S. or Canada who wish to earn the CDA certification.) The only way an individual who has not completed formal education could qualify for CRFDA certification would be to first earn the CDA certification through the work-experience pathway, and then qualify for CRFDA through Pathway I above.

Restorative Functions Requirements in Other States

The scope of practice for Virginia Dental Assistants II includes functions that are considered expanded functions in those states where they may be performed by some level of dental assistant. Although the scopes of practice for Expanded Functions Dental Assistants (EFDAs) and equivalent levels of dental assistant roles vary from state to state, performance of restorative functions – that is, placing and finishing amalgam and composite restorations – is the cornerstone and common denominator of EFDA practice.

For your reference, we have provided, via email, a chart (Attachment 2) that shows the states where some level of dental assistant may perform placement and finishing of direct restorations, the level of dental assistant permitted to perform the function, and the requirements to attain that level in each state. We hope these data will aid you in your consideration of the current rule petition.

DANB thanks the Board for the opportunity to comment on this petition for rulemaking. If there are any questions about the foregoing or any of the attachments, please don’t hesitate to contact me at klandsberg@danb.org.