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Washington State Dental Association

DQAC Update: 5/3/16

On Friday, April 22nd, the Dental Quality Assurance Commission (DQAC) held a public meeting to discuss ongoing business. Here are some of the meeting highlights:

The Commission held a rules hearing for the proposed WAC 246-817-120: Examination content. The proposed rule modifies the existing examination content rule by adding examination subject content required to obtain a dentist license and indicates other states and Canada clinical examinations are acceptable. After reviewing public commentary, the rule was passed unanimously and will enter the final phase of rulemaking. 
The following rules are currently under review or have been recently approved by the Commission: 

  • WAC 246-817-304, 305, 310 & 315: Dental treatment records – Effective as of April 17, 2016, Washington law will require licensed dentists to maintain patient records for a minimum of six years from the date of last treatment. Additionally, if requested as part of an investigation authorized by the Secretary of Health, a licensed dentist must provide business documents including, but not limited to, contracts or agreements governing the dental practice business relationships with co-owners, partners, and associations.
  • WAC 246-817-160: Graduates of non-accredited schools – The Commission is considering amendments to education requirements for graduates of non-accredited dental schools to clarify the clinical education and examination eligibility process. The proposed rule requires that predoctoral or postdoctoral education must include clinical training and be accredited by CODA beginning July 1, 2018. The proposal is currently in the second of three rulemaking phases. 
  • WAC 246-817-510, 520, 525, 540 and 545: Dentist delegation of duties to dental assistants and expanded function dental auxiliaries (EFDAs) – The proposed rule amendments update the scope of practice (listing of allowable and prohibited tasks that may and may not be performed) for registered dental assistants and licensed expanded function dental auxiliaries. The scope of practice (list of allowable and prohibited tasks) has been an area of confusion for licensed dentists, registered dental assistants, and licensed EFDAs. A rules hearing is expected to take place on June 3, 2016.
  • WAC 246-817-130, 135 & 140: Licensure without examination – The proposed amendments detail license without examination eligibility and application requirements in a single existing rule. The proposal would remove unnecessary license requirements and application procedures and eliminate conflicts within the current statute. A public hearing is scheduled for Friday, June 3, 2016 at the Department of Health offices in Tumwater, WA. All comments must be submitted no later than May 27, 2016.
  • WAC 246-817-550 and 560: Acts that may be performed by dental hygienists – The Commission reviewed stakeholder comments and elected to move the proposed hygiene delegation rules to the second phase of rulemaking. The proposed amendments would allow dental hygienists to:
    • Administer of head and neck examinations under general supervision
    • Administer of injections of local anesthetic under general supervision
    • Deliver oral antibiotic prophylaxis under general supervision
    • Take impressions, bite registrations, or digital scans under general supervision
  • WAC 246-817-760: Moderate sedation with parenteral agents – The Commission opened rulemaking related to pediatric sedation monitoring requirements. The Washington State Academy of Pediatric Dentistry was opposed to previously proposed monitoring and equipment requirements because the rules did not provide alternatives or exceptions for sedating pediatric patients as this is a specialty. The new rules are expected to include specific requirements and exceptions for dentists when sedating pediatric patients consistent with the AAPD 2011 “Guideline for Monitoring and Management of Pediatric Patients During and After Sedation for Diagnostic and Therapeutic Procedures.” The Department of Health will be sending the proposed rules to stakeholders for public comment over the next several weeks.

More information on these rule changes can be found online on the Department of Health’s website. All public comments should be submitted to DQAC Program Manager, Jennifer Santiago at Should you have any additional questions regarding legal and regulatory issues, please contact Michael Walsh at or by phone at (206) 448-1914

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