Electronic Newsletter

The Iowa Dental Board wishes to provide clarification to licensees regarding their responsibility to comply with national standards issued by the Centers for Disease Control and Prevention (CDC) for infection control in dental offices. Recently, the Iowa Dental Association (IDA) has raised serious infection control concerns regarding the compliance of licensees with the recommendations of the CDC. The IDA has suggested that licensees may not be complying with CDC recommendations and that to do so would create a significant fiscal impact in Iowa. In light of those concerns, the Board is bringing this to the attention of licensees to clarify state law, and remind you of your responsibility to comply with recommendations of the CDC for preventing the transmission of infectious diseases. Compliance with CDC recommendations has been required in Iowa since 1993.

The CDC is the lead federal agency for disease prevention in the U.S. CDC guidelines have been issued in terms of “recommendations” because unlike other federal agencies, such as OSHA, the CDC is not a regulatory agency and cannot mandate certain practices at the federal level, but may only recommend. However, since 1993, and across the nation, CDC recommendations have been adopted at the state level as the standard for infection control.

The American Dental Association (ADA) has worked along with other leading experts in infection control to assist the CDC in developing practical evidence-based recommendations to prevent and control the spread of infectious diseases and to manage personnel health and safety concerns related to infection control. According to the ADA, although the guidelines were recently updated in December 2003, the procedures recommended in the 2003 document are “for the most part unchanged, the new document [incorporates] relevant recommendations that were previously scattered throughout several other CDC publications and contains an extensive review of the science related to dental infection control.” The ADA position statement on the CDC recommendations urges all dentists and dental personnel to employ the infection control procedures described.

Dentists are reminded that all licensees and registrants have an obligation under Iowa law to follow CDC recommendations for infection control. The Board expects all licensees to ensure compliance with any CDC “category IA, IB, or IC” recommendations; Category II CDC “suggestions” are not required in Iowa. A link to the CDC guidelines for infection control in dental settings (2003) is available on the Board’s web site at http://www.state.ia.us/dentalboard. Please review and discuss this important issue with your staff.

The Board is concerned that many licensees may have misconceptions and inaccurate information related to hiring a new dental assistant. The Board would like to take this opportunity to communicate important information regarding dental assistants.

Did you know that any high school graduate who is at least 18 years of age or older is eligible for dental assistant trainee status? In addition, certain high school students are also eligible to engage in on-the-job training in dental assisting. In short, almost everyone is eligible for dental assistant trainee status, including:

• Graduates of dental assisting schools;
• Dental students who want to work as an assistant during school breaks;
• Dental hygiene students who want to work part time as an assistant;
• High school students enrolled in a cooperative education or work-study program;
• Assistants from another state;
• Assistants with previous experience who are not already registered in Iowa; and
• Anyone who wants to train on-the-job to meet the requirements for registration.

Assistants who graduate from a dental assisting program at a community college CAN start working right away by going on trainee status, just like any other new employee. Just complete a dental assistant trainee application within seven days of employment. Graduates have up to six months to complete the required exams for registration, just like other trainees. Dental assistant trainee status allows dental assisting graduates who are waiting for the results of their national board exam (DANB) scores to begin working right away. An assistant who successfully completes the DANB exams in infection control and radiology does not need to take the state exams in infection control and radiology.

The employer dentist must notify the Board office within seven days of employment of a dental assistant trainee by completing a trainee application. Application forms are available on the Board web site at http://www.state.ia.us/dentalboard/forms.html. Once placed on trainee status, assistants have up to six months to complete the required registration exams. While optional, trainees are also encouraged to complete on-the-job training and examination in dental radiography during this time period. The curriculum in radiology was revised and updated last fall to reflect current practice. The Board’s study manual for trainees now includes the current radiology curriculum at no extra charge.

Did you also know that about 90 percent of dental assistant trainees pass the required registration exams using the Board study manual while working under the personal supervision of a licensed dentist? Since the Board initiated a change in the law to extend the time period to prepare for the exams from 60 days to 6 months, few problems have been reported with assistants being able to successfully study materials and pass the exams in the required timeframe. The exams are readily available and accessible throughout the state at 17 different community college testing sites. Most testing sites also offer convenient scheduling five days per week.

The Board has a study and reference manual available that covers all of the information needed to pass the exams. While the size of the manual may look intimidating, the actual material tested is less than one-fourth the size of the manual. The remaining material consists of practice exam questions, CDC infection control guidelines, OSHA references, and copies of state law and board rules. The Board incorporated this reference material into the manual so that it can also serve as a useful office reference after the initial training period.

For those few remaining trainees who need extra help to pass the exams, remedial education is available through eight different dental assisting community college programs. Remedial education consists of one-on-one help with a qualified dental assisting instructor to identify problem areas and provide individual instruction. In addition, it is possible for the assistant to schedule an appointment at the Board office to review questions the assistant missed on previous exams. Because of confidentiality provisions in state law, this can only be done at the Board office in Des Moines. However, it may be worth the drive for the assistant to review areas of weakness to better focus their study and training.

Dental assistant registration has now been in effect for almost three years. While there were some transition problems during the first year of registration, primarily related to the old statute that only allowed 60 days for an assistant to complete the required examinations, the Board has successfully resolved those issues. The Board has issued registration to hundreds of dental assistants who successfully completed examinations and the registration process.

If you have questions or concerns related to hiring and training a new dental assistant, it is important that you contact the Board office to receive accurate information.

Yes. The Board has had rules in place since 1993 requiring compliance with CDC recommendations. The proposed rule change is meant only to update a change in terminology and to clarify what is required versus what is suggested. Even if the proposed rule change does not go into effect, the previous rules still would require compliance with CDC recommendations.

CDC guidelines recommend you perform a spore test on a sterilizer once a week. You should document and maintain these results in your office.

Receiving a subpoena does not mean that you are the subject of a Board investigation. It is standard procedure during the investigation of a complaint to get information from all treating dentists. The Board issues subpoenas in order to protect the licensee since they are releasing confidential patient information.

No. Jurisprudence was only required for the initial renewal in 2003. The only components of the required 20 hours are two hours in infection control, and two hours in dental radiography if you hold a current qualification in dental radiography. Keep in mind, the Board still requires that you hold a current certification in CPR, and that you have completed the training for the identification and reporting of abuse within the last 5 years.

Just as dentists are required to apply for and receive licensure after completing exams and receiving a diploma before working as a dentist, so must a dental assistant apply for registration to work as a dental assistant in the state of Iowa. All dental assistants must register with the Iowa Dental Board, or apply for dental assistant trainee status prior to working as a dental assistant in Iowa.

I've heard that the revised CDC Guidelines prohibit carpeting from being used in operatories, is this true?

No. While the CDC does "suggest" this implementation, Board rules do not require that "suggestions" be followed. Board rules only require that Category IA., IB., "recommendations", and Category IC. "requirements" be followed.

Why are we required to follow category IA., IB., and IC. Recommendations or requirements, and not category II.?

All of the recommendations in categories IA. and IB. are supported by sufficient scientific evidence and have a consensus to support their effectiveness in dental settings.

Compliance with category IC. is required by federal or state regulations. [i.e. OSHA and IOSHA]

Category II. Items are only suggestions and are only supported by suggestive clinical or epidemiological studies.

So why does the CDC only “recommend” that these practices be followed?

Unlike OSHA, which is a regulatory agency, the CDC cannot mandate certain practices, they can only recommend them. However, most dental licensing boards, including Iowa, have adopted rules establishing the CDC Guidelines as requirements in their states.

Why do the new guidelines use "standard precautions" where the previous guidelines used "universal precautions"?

The new guidelines use the broader term “standard precautions” which are protocols to protect against exposures to blood and other bodily fluids, including saliva, mucous membranes, and broken skin. The term “universal precautions” are measures intended only to prevent exposures to blood.

Board rules state, “A dentist shall maintain a patient’s dental record for a minimum of six years after the date of last examination, prescription, or treatment. Records for minors shall be maintained for a minimum of either (a) one year after the patient reaches the age of majority (18), or (b) six years, whichever is longer. Proper safeguards shall be maintained to ensure safety of records from destructive elements.”

Please contact the Board with any questions.

Please be advised of the regulations concerning the transfer of patient records. Board rules state, “Dentists shall preserve the confidentiality of patient records in a manner consistent with the protection of the welfare of the patient. Upon request of the patient or patient’s new dentist, the dentist shall furnish the dental records or copies or summaries of the records, including dental radiographs or copies of the radiographs, as will be beneficial for the future treatment of that patient. The dentist may charge a nominal fee for duplication of records, but may not refuse to transfer records for nonpayment of any fees.”

While Board rules allow a dentist to charge a fee for the duplication of a patient’s record, Board rules require that the record(s) be transferred upon the request of the patient or the patient’s new dentist, even if the fee has not been paid. If there is ever any doubt or confusion about what to transfer as a part of the patient record, or when to transfer the patient record, do not hesitate to contact the Board office directly for clarification.

The Iowa Dental Board was asked to review the Dental Diet System Behavior Modification Appliance with regard to whether dentists in the State of Iowa were authorized to participate in this program and provide this service. The Board understands that the appliance is an oral appliance similar to an orthodontic retainer that will help the patient learn to consume food at a slower rate by decreasing the size of the oral cavity and the amount of food per bite the patient can hold in his mouth. The Board concluded that Iowa dentists utilizing this system must maintain consultation with a physician who has diagnosed the need for the device. The Board has contacted Scientific Intake Corporation and asked that they advise Iowa licensees who utilize this service accordingly.

Please contact the Board with any questions or concerns.

The Iowa Dental Board was recently informed that the Drug Enforcement Administration’s (DEA), Office of Diversion Control has changed the appearance of the DEA Controlled Substance Registration Certificate. The change will go into effect October 1, 2004. The certificate will now have two parts: a certificate that you should display on the wall and another smaller wallet size. The new certificates allow for easier authentication and will deter counterfeiting.

If you are able to renew your registration on the Office of Diversion Control’s web site, you can print your Certificate of Registration once you have completed the renewal process, unless you have made changes to the registration since the last renewal.

The DEA will continue to mail certificates of registration through the U.S. Postal Service to all other registrants.

For more information, please refer to http://www.DEAdiversion.usdoj.gov.