DOH Releases Their Final Recommendations for the Denturist Scope of Practice Sunrise Review
The Department of Health (DOH) has released their final recommendations for the Denturist Scope of Practice Sunrise Review. Last session, the legislature had asked DOH to review a potential expansion of the scope of practice of licensed denturists to include “making, placing, constructing, altering, reproducing, or repairing all other “non-orthodontic removable devices” and “teeth whitening using bleaching solutions of twenty percent or less." A complete copy of the DOH findings and original report can be found here.
DOH had released their preliminary recommendations in September following a public hearing in which they reviewed materials submitted by WSDA, the Dental Quality Assurance Commission (DQAC), dentists, denturists, and others. Following the second rebuttal period which concluded on September 20, 2012, DOH was tasked with providing the legislature with the final report which they released in mid-January.
In the final report, DOH found that the sunrise criteria have not been met with the proposal as written and therefore recommended that the language in the bill NOT be adopted into law. The rationale being:
The department finds substantial risk of patient harm if the broad definition of “nonorthodontic removable devices” proposed in House Bill 2815 is adopted:
Rationale: Allowing the broad use of “non-orthodontic removable oral devices” opens up the scope of practice for denturists to work with obstructive sleep apnea, which requires specialized training, even for fitting and follow up for the devices. If not properly diagnosed and treated, obstructive sleep apnea can lead to cardiac disease, hypertension, and stroke. In addition, the devices can lead to adverse effects such as dental crown damage, tooth, mouth, and jaw damage, skeletal changes, and Temporomandibular Disorder (TMD).
The DOH opinion is consistent arguments made by WSDA and DQAC. WSDA’s comments can be found here and DQAC’s comments can be found here.
Though DOH did not support adoption of this specific denturist expansion language, DOH has provided more limited legislative language that could be used by the Legislature to expand denturist scope of practice. These recommendations are as follows:
The following services could possibly be added to the denturist scope of practice if additional safeguards and assurances are included:
1. Allow denturists to fabricate and fit bruxism (grinding and clenching of teeth) devices and sports mouth guards only if:
- The definition of "non-orthodontic removable oral devices" is narrowed to only bruxism devices and sports mouth guards.
- Training requirements are set in law or required in rule to ensure currently licensed denturists have the necessary skill to create and fit these devices.
- Language is added for bruxism devices to require the patient to be examined by a dentist for diagnosis and selection of the appropriate device and to snure there is no TMD or other issues present before a denturist proceeds with fabrication of the device.
- Language is added for bruxism devices to require the denturist to refere the patietn to a dentists for follow up examinations.
- Written instructions are provided to the patient encouraging regular dental checkups to identify any adverse effects of bruxism or from the device.
Rationale: These devices are not a high risk to the public as long as denturists have received appropriate training, consult with a dentist as needed, and encourage regular dental checkups.
2. Allow denturists to provide teeth whitening trays and over-the-counter solutions for the patient’s use at home if they also provide written instructions encouraging regular dental checkups.
Rationale: Opponents did not provide evidence that allowing denturists to provide this service would be a high risk to the public. Fabrication of the trays includes similar processes used in making dentures, such as taking impressions casts and vacuum forming the trays. Teeth-whitening trays do not move the teeth or jaw and the whitening gel is the same strength currently available over-the-counter.
3. Allow denturists to provide cosmetic appliances, such as the Snap-on-Smile, regardless of whether the patient is missing teeth.
Rationale: This is a patented cosmetic appliance that covers the teeth and is removable. It simply requires an impression of the teeth be sent to the manufacturer for fabrication, followed by a fitting. There does not appear to be a risk to the public, and this fits in with the work denturists already do.
On January 22, following DOH’s release of their final recommendations, House Bill 1271 was introduced by the legislature. The bill language in HB 1271 is more a restrictive expansion of scope than initially proposed and would not allow denturists to fabricate nonorthodonic removable devices intended to treat sleep apnea or TMD. HB 1271 would expand the scope of denturism to:
Making, placing, constructing, altering, reproducing, or repairing all other nonorthodontic removable oral devices, excluding devices intended to treat obstructive sleep apnea or to treat tempural mandibular joint dysfunction; and
Providing teeth whitening services, including making whitening trays and providing whitening solutions determined to be safe for public use.
Prior to providing the above services, a licensed denturist must provide documentation to the board that he or she received training on providing the services. HB 1271 has been referred to the House Health Care & Wellness Committee. A complete copy bill can be found here.
WSDA opposes HB 1271 as written and will continue to monitor all denturist scope expansion bills during the 2013 Legislative Session. Please address all questions and comments to Bracken Killpack, Director of Government Affairs, at firstname.lastname@example.org or 800-448-3368.