I applaud the BOD for clarifying the requirements for refresher courses, however, see no significant detail in the NOIRA documentation upon which to comment.  These courses are few and far between and difficult to find.  I would suggest that a complete listing of possible courses that meet requirements be developed to be sure that potential licensees have access to an appropriate courses.

I am writing on behalf of the Virginia Dental Association in response to the Virginia Board of Dentistry’s proposal to amend 18VAC60-21-240 and 18VAC60-25-210 to expand the types of refresher courses reinstatement applicants may take.

The NOIRA states the Board is also proposing 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. Without spelling out the specifics of that proposal, it is difficult to comment on their appropriateness.

As many licensed dentists, dental hygienists and expanded functions dental assistants had careers put on hold in the past five years, we believe that it is particularly important at this time to have a clearly defined path to reinstating a lapsed license that is not unnecessarily burdensome in demonstrating continued competence.

As of this writing, the VDA is aware of only one refresher course for dentists and dental hygienists offered in Virginia that meets the criteria adopted in December 2, 2022 in Guidance Document 60-12 and is aware of no currently offered refresher courses that meet the criteria for a dental assistant II whose license has lapsed.

A nurse in Virginia, by comparison, whose license has lapsed for more than a year, has nine different options to demonstrate continued competency, certified by upwards of 13 providers.

The current guidance document for reinstatement of a license for a dentist, dental hygienist or dental assistant II requires that the refresher course be offered by a CODA-accredited program. However, CODA does not accredit refresher courses themselves and, in the case of dental assistant II’s, CODA also does not accredit that educational program.

The physical space in which a refresher course is offered is not indicative of its quality, and the board accepts more than fifteen sponsors of continuing education for purposes of annual licensure renewal for oral healthcare professionals.

The VDA supports the Board of Dentistry’s stated proposal to expand the type of refresher courses reinstatement applicants may take and asks the Board to limit its requirements to what is necessary to demonstrate continued competency.

Dustin Reynolds, DDS

President, Virginia Dental Association

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