Legislative Update

Dear Utah Dental Hygiene Community,

The Division of Professional Licensing, Dentist and Dental Hygienists’ Board are reviewing a proposed rule change for licensure by endorsement for a dentist from another jurisdiction to be licensed as either a dentist OR a dental hygienist. This would include foreign trained dentists who do not have current licenses in the United States. The Notice is provided below and the document is attached. (See pages 1-3).

The Utah Dental Hygienists’ Association (UDHA) supports pathways for qualified individuals to practice dental hygiene in the state of Utah. To be a qualified individual, one should be able to demonstrate comparable competency to what is required of those obtaining an initial dental hygiene license in our state or endorsement through an existing dental hygiene license in another state. 

The UDHA respectfully requests the following changes be considered and reflected in the proposed rule additions:

• R156-69-302# Qualifications for Dentist Licensure by Endorsement as a Dental Hygienist (1)(a) and (1)(b), are not comparable to demonstrate competency as a dental hygienist. 

  • The UDHA requests (1)(a) not be an option. For example, the ADEX/CDCA clinical periodontics section of the dental board requires removal of 12 surfaces of calculus that have been identified for the applicant. Whereas, the ADEX/CDCA clinical dental hygiene exam includes calculus detection, probing, and removal of unidentified calculus in an entire quadrant.

• R156-69-302# Qualifications for Dentist Licensure by Endorsement as a Dental Hygienist (2)(c)(ii) and (2)(d)(ii)

  • The current language of this draft states that the candidate for licensure would have “successful completion (and satisfactory documentation, respectively) of not less than 2,000 hours of practice as a dentist, which may include clinical hours of practice as a dental student.” There is no mention of clinical hours providing dental hygiene services.

  • Current Commission of Dental Accreditation (CODA) standards for Dental Hygiene education requires at a minimum: “The preclinical course should have at least six hours of clinical practice per week.  As the first-year students begin providing dental hygiene services for patients, each student should be scheduled for at least eight to twelve hours of direct patient care per week.  In the final prelicensure year of the curriculum, each student should be scheduled for at least twelve to sixteen hours of direct patient care per week in the dental hygiene clinic.” These standards equal a minimum of 480 hours of direct DENTAL HYGIENE patient care during the education of a dental hygienist. 

  • The UDHA BOT requests that the proposed R156-69-302# Qualifications for Dentist Licensure by Endorsement as a Dental Hygienist (2)(c)(ii) and (2)(d)(ii) be changed to reflect the minimum clinical standards expected of a dental hygiene student at a CODA accredited institution. In addition, these hours should be the two years immediately preceding the date of application for licensure as stated in current statute 58-69-302 (4)(c).

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In addition, in regards to both new proposed pathways, individuals who have attended and graduated from a Commission on Dental Accreditation (CODA) program have been taught Center for Disease Control (CDC) guidelines for infection control to protect the public, Health Insurance Portability and Accountability Act (HIPAA) compliance to protect the public, and Occupational and Safety Health Act (OSHA) standards to protect their employees. What is being proposed to demonstrate applicant’s knowledge in these areas?

We invite members of the Dental Hygiene Community to attend the public hearing on the proposed draft or provide written comments as outlined in the below announcement.

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Thank you,

UDHA Board of Trustees

DOPL to hold a public hearing to receive verbal comments on these proposed DRAFT rules:

Tuesday, 10/24/2023, 9 a.m.

North Conference Room, 1st Floor, Heber M. Wells Building, 

160 E 300 S, Salt Lake City, Utah.

Virtual option: Google Meet joining information:

Video call link: https://meet.google.com/kwf-rzjo-ojr

Or dial: (US) +1 336-790-8803 PIN: 204 105 408#

More phone numbers: https://tel.meet/kwf-rzjo-ojr?pin=7727666888398

Written comments on these proposed DRAFT rules will be accepted by the DOPL from the publication date through Friday, 11/03/2023. 

Comments may be directed to the contact person:

Deborah Blackburn, Assistant Division Director, at

deborahblackburn@utah.gov.

Notice of Draft Proposed Rules and Hearing Information for the Division of Professional Licensing

The public, interest groups, and governmental agencies are invited to review and comment on the following DRAFT proposed

rules for the Division of Professional Licensing (DOPL).

These DRAFT proposed rules are published only for review and comment purposes; they will not be made effective without

subsequent filing and publication:

New Section R156-69-302#. Qualifications for Licensure by Endorsement for a Dentist.

(Dentist from another jurisdiction may apply to meet time-based endorsement requirements through certain methods demonstrating competency.)

New Section R156-69-302#. Qualifications for Dentist Licensure by Endorsement for a Dental Hygienist.

(Dentist from another jurisdiction may apply to meet time-based dental hygienist endorsement requirements through certain methods demonstrating competency.) (See pages 1-3 of attached document for full DRAFT language)

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Document Attached HERE.