California Society of Pediatric Dentists - Advocacy
American Academy of Pediatric DentistryCalifornia Society of Pediatric Dentistry


American Academy of Pediatric Dentistry
American Academy of Pediatric Dentistry

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A state unit organization
of the American Academy
of Pediatric Dentistry

American Academy of Pediatric Dentistry


capital The California Society of Pediatric Dentistry is the state's leading advocate for the optimal oral health of infants, children, and adolescents, including those with special needs. The Society serves its members and represents the specialty of Pediatric Dentistry in California to achieve excellence in practice, education, and research.

To help accomplish this mission, the CSPD Board of Directors appointed
Dr. Paul A. Reggiardo, past-president of both the CSPD and AAPD, as their first Public Policy Advocate. This page contains some of his reports to CSPD's Board of Directors and members.

The Annual Report of the Public Policy Advocate is now available for review.

CSPD Provides School Absence Information and Assistance

Topics Available
on this Page
  • Medi-Cal Information
  • Consequences of Untreated Dental Disease in Children
  • School Entrance OH Assessments
  • Bills of Interest to CSPD
    Current 2014 Session
  • Dental Board of California
    Current News
  • Letters of Support
    SB 694
  • Final Scorecards
    2006 Legislature
    2007 Legislature
    2008 Legislature
    2009 Legislature
    2010 Legislature
    2011 Legislature
    2012 Legislature
    2013 Legislature
  • Other Advocacy
    Denti-Cal News
    CA Infection Control
  • Dentists, and pediatric dentists in particular, are often challenged by parents anxious to avoid school absence, even when that absence is for the purpose of health care delivery. Although most practitioners establish scheduling policies and protocols intended to minimize pupil absence in a manner consistent with the patient’s age, the nature of the service provided, and fairness to all families in the practice, many are still confronted with school policies that seem or profess to prohibit absence from school for the delivery of dental care during school hours.

    As pediatric dentists, we recognize the importance of regular school attendance and the effect on education of chronic absence. We also recognize the negative financial implications to the school from the state when daily attendance is reduced. For these reasons, we have long urged our members to work with parents and with schools to minimize attendance disruption for oral health services ----- and better oral health through regular preventive care visits is one strategy for accomplishing this goal. It is not realistic, however, to expect that all pediatric and adolescent oral health care services can be delivered outside of school hours. In fact, state law [California Education Code §48205(a)(3)] specifically provides that "a pupil shall be excused from school when the absence is for the purpose of having medical, dental, optometrical, or chiropractic services rendered."

    In an effort to provide clarity on this issue to dentists, parents, and school educators, the California Society of Pediatric Dentistry has joined with the California Dental Association to provide a downloadable Message to Parents and School Administrators Regarding School Absence for Dental Appointments. This one-page information sheet, which contains Oral Health Facts for Children, may be downloaded from the CSPD and CDA websites for printing and distribution by dentists and their staffs.

    In addition, CSPD has developed a template for a School Attendance Release Form which may be downloaded from the CSPD website and customized by members for individual office printing and distribution (This is a MS Word doc file). The form contains reference to §48205(a)(3) of the Education Code.

    Mobile/Portable Dental Care Provider Guidelines  

    In an effort to assist school districts approached by mobile/portable dental care providers, a statewide group of dental and education professionals, led by the California Dental Association and the Dental Health Foundation have developed a series of documents intended to give school decision-makers some tools and ideas to help make the best choice for a particular situation.

    Cover memo -- Provides an introduction for school districts to the toolkit contents.

    Things to consider - This document highlights twelve items for school districts to discuss when considering entering into a contract with a mobile/dental care provider.

    Mobile Provider Guidelines - This spreadsheet outlines in more detail items and issues for school districts to discuss when considering contracting with a mobile/dental care provider.

    Sample Memorandum of Understanding (MOU) - This sample MOU is an example for school districts to use and tailor to fit their specific needs.

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    California Legislature 2013-2014
    Second Regular Session
    Bills of Interest to CSPD

    June 22, 2014

    AB 1174 (Bocanegra) This bill would expand the scope of practice of Registered Dental Assistants in Extended Functions and Registered Dental Hygienists to determine which dental radiographs to perform and to place interim therapeutic restorations pursuant to the order and supervision of a licensed dentist. The bill would authorize asynchronous transmission of information to be reviewed at a later time by a licensed dentist at a distant site as a billable encounter under Medi-Cal regulations.
    CSPD Position: Support - CSPD's Letter of Support
    Comment: Introduced at the request of The Children's Partnership, the bill would place into statute the elements of the Virtual Dental Home pilot project (Health Workforce Pilot Project #172) developed by Dr. Paul Glassman and the Pacific Center for Special Care at the Arthur A Dugoni School of Dentistry. The bill was amended 5/21/14 to require that the supervising dentist provide the patient or the patient's representative written notice including specified contact information and disclosing that the care was provided at the direction of that authorizing dentist, and would prohibit the dentist from concurrently supervising more than five such dental auxiliaries as specified in the bill.

    AB 1962 (Skinner) Dental Plans: Medical Loss Ratios - This bill would require dental benefit carriers to file annual reports with the Department of Managed Health Care or the Department of Insurance on loss experience and would express the will of the legislature that the data reported pursuant to these provisions be considered by adopting a medical loss ratio standard for dental benefit plans that would take effect no later than January 1, 2018.
    CSPD Position: Support - CSPD's Letter of Support
    CSPD's Letter of Support
    Comment: As introduced, would have required that dental plans sold in the state spend a minimum percentage of premium revenues on direct patient care and that plans failing to meet this "medical loss ratio" would be required to rebate the excess premium revenue back to enrollees. The bill now requires only data collection which would support the establishment of such a standard.

    SB 1000 (Monning) Sugar-sweetened Beverages: Safety Warnings - Requires a safety warning label on sugar-sweetened beverage containers and dispensers.
    CSPD Position: Under Consideration
    Comment: The bill defines a sugar-sweetened beverage" as any sweetened non-alcoholic beverage, carbonated or non-carbonated, that has added caloric sweeteners and contains at least 75 calories per 12 fluid ounces. Requires the safety warning to read "STATE OF CALIFORNIA SAFETY WARNING: Drinking beverages with added sugar(s) contributes to obesity, diabetes, and tooth decay"

    SB 1245 (Lieu) Dental Hygiene Committee of California: Sunset review - Extends the operation of the Dental Hygiene Committee of California within the jurisdiction of the Dental Board of California four years until January 1, 2019
    CSPD Position: Watch
    Comment: The The DHCC and the California Dental Hygienists Association have proposed an expanded authority for the Committee which would include (1) establishing the Committee as a separate Board under the jurisdiction only of the Department of Consumer Affairs and a separate Dental Hygiene Practice Act; (2) allowing the proposed Dental Hygiene Board to propose dental hygiene scope of practice changes independent of the Dental Board of California input or jurisdiction and (3) moving administration of local anesthesia and inhalation analgesia from direct to general supervision for Registered Dental Hygienists. This legislation does not include those provisions.

    SB 1416 (Block) Dental Board of California: Licensure Fees - This legislation would raise the fee charged by the Dental Board for initial dental licensure and biannual renewal from $450.00 to $525.00.
    CSPD Position: Neutral
    Comment: As introduced, the bill gave the Dental Board statutory authority to raise licensing fees. As amended, it requires immediate implementation of the $525.00 license and renewal fee. According to the Board and Department of Consumer Affairs, averting or delaying an immediate fee increase will cause the DBC to become insolvent in Budget Year 2015-2016.

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    Report of the Meeting of
    the Dental Board of California
    Prepared for the California Society of Pediatric Dentistry

    February 26-27, 2015
    Past CA Dental Board Reports
    August 2006
    November 2006
    February 2007
    August 2007
    November 2007
    January 2008
    March 2008
    May 2008
    August 2008
    April 2009
    July 2009
    November 2009
    February 2010
    May 2010
    July 2010
    November 2010
    May 2011
    November 2011
    February 2012
    May 2012
    August 2012 December 2012
    March 2013
    August 2013
    November 2013
    May 2014
    November 2014
    February 2015
    by Paul Reggiardo, DDS, Public Policy Advocate

    The Dental Board of California met February 26-27, 2015, in San Diego. The following report summarizes actions and issues coming before the Board pertinent to pediatric oral health

    While the pass rate for the RDA written examination still hovers around 65% (71% for first time candidates), the pass rate for the practical examination dropped precipitously last year from over 90% to barely over 20%. This unacceptable situation was addressed by the Board at its December 2014 meeting and a subcommittee was appointed to explore potential solutions to a realistic practical examination process.

    From that subcommittee came the recommendation, which the Board accepted, for an updated occupational analysis of the RDA and RDAEF professions. According to Department of Consumer Affairs policy, an occupational analysis and confirmation that the licensing examination for that profession reflects the tasks performed, and the abilities required to perform these tasks, should be performed at no less than a five year interval. The last RDA, RDAEF occupational analyses were conducted in 2009, when the RDA and RDAEF professions were brought under the umbrella of the Board. An updated occupational analysis would lay the foundation for a revised practical examination process that still aligns with the Board's mission of public protection.

    Comment: There appeared to be consensus at the December 2014 meeting of the Board that the largest contributing factor to the increased failure rate was the result of greater examiner calibration and resultant attention to clinical (typodont) performance. In other words, lack of minimal competency in tested clinical performance that was being overlooked in the past, is no longer being missed or ignored. A revised practical examination / practical examination process appears the best way to address this problem.

    As part of the license renewal process, the Dental Board conducts random audits of continuing education (CE) compliance. Dentists are required to certify under penalty of perjury that they have completed the requisite number of continuing education hours, including any mandatory courses, since their last renewal on the licensure application. Licensees are required to maintain documentation of successful completion of eligible coursework for no fewer than three renewal periods and, if audited, they are required to provide that documentation to the Board upon request. A dentist who is not able to provide proof of the required CE hours may be issued a citation with a fine. The citation also includes an abatement condition requiring the licensee to complete the deficient number of credits within a specified time period. These units are in addition to the credits required for the next renewal cycle. A licensee who fails to pay the fine or comply with the citation's abatement may be referred for discipline and his/her license may be suspended or revoked. The Board audits about 5% of the license renewal requests.

    On January 1, 2015, Board staff began conducting random continuing education audits of its dental licensees three months prior to their renewal expiration date. To avoid a hold being placed on the license renewal, licensees must submit CE certificates for the previous three renewal cycles as required under the California Code of Regulations. Since the inception of the program, Board staff identified the following problems:

    • Licensees are failing to keep records for three renewal periods.
    • Licensees are claiming classes that do not qualify for CE credit under Dental Board regulations and were never issued valid certificates of course completion.

    Conducting the CE audits has also permitted the Board to review how Continuing Education Providers are maintaining their records and compliance with the issuance of certificates as follows:

    • Continuing Education Providers are not always in compliance with the requirements of certificates they issue. Items such as the course number, licensee name and license/ permit number, the number of units earned, and the eleven digit course registration number are often missing.
    • Continuing Education Providers are not always in compliance with the requirements of certificates they issue. Items such as the course number, licensee name and license/ permit number, the number of units earned, and the eleven digit course registration number are often missing.
    • Providers are not submitting to the Board biennial reports as required.
    • Mandatory courses, Infection Control and Dental Practice Act, are not always current with the new Laws and Regulations.
    • Per the California Code of Regulations, eight units are the maximum continuing education credits that may granted in one day. Providers who provide home study courses often use the date they receive the materials from the licensee as the date of attendance on the certificate, often for multiple courses. As a result, licensees have submitted CE certificates showing that they are attending more than 8 hours per day.

    As a result, the Board directed staff to begin conducting random audits of Continuing Education Registered Providers for compliance with all regulations required under their permits.

    Comment: AAPD, as a Registered California Continuing Education Provider, has been in full compliance with the regulations.

    California's Licensure by Credential pathway provides that a dentist holding a current dental license in another state that is not revoked, suspended or otherwise restricted, and meeting certain practice experience requirements, may be granted a California dental license. In recent years, the Board has come under pressure from the dental schools to grant a California license to dentists holding a specialty license in another state and a full-time faculty appointment. Under current statute, a specialty license is considered a "restricted license," which disqualifies the applicant from the Licensure by Credential pathway.

    In an effort to accommodate the schools, which contend that the lack of a licensure by credential pathway hampers faculty recruitment, the Board last August began investigation of potential solution that would satisfy the schools and maintain public protection. Finding the issue mired in both regulatory and statutory constraints, the Board moved to appoint a subcommittee to work with staff to look at whether to pursue clarification of the Licensure by Credential Application requirements by statute, regulations, or both.

    Comment: The issue is potentially explosive in that it could open consideration of specialty dental licensure in California, something long opposed by CSPD (and AAPD).

    In response to what is generally acknowledged as a national epidemic of prescription drug abuse, the Dental Board continues exploring what actions it might take to address the problem as it pertains to California's dental prescribers. In a related action, in October the Medical Board of California approved revision of its Guidelines for Prescribing Controlled Substances for Pain for release to medical licensees. After reviewing the medical guidelines, the Prescription Drug Abuse Committee voted to appoint a subcommittee to draft guidelines for Prescribing Controlled Substances in Dental Practice for consideration of the Board.

    Comment: In California, most licensed physicians are required to take, as a one-time requirement, 12 hours of Continuing Education (CE) on pain management and the appropriate care and treatment of the terminally ill. At present, the Dental Board has no similar requirement, but the Board may consider a CE option in the future.

    In December 2014, the Dental Hygiene Committee of California (DHCC) voted to initiate a rulemaking process relative to definitions of dental hygiene terms. Statute requires that recommendations made by the DHCC regarding scope of practice issues must be approved, modified, or rejected by the Dental Board of California. Upon receipt of notification of the proposed language, the Board appointed a subcommittee to review the modified definitions. The subcommittee subsequently recommended four changes, which the Board moved to accept.

    Comment: CDA contends that Board's actions must be accepted by the DHCC and not treated as an advisory opinion. In short, this becomes a jurisdictional issue. The DHCC contends that it has the authority to modify the definitions and CDA contends that all authority of dental hygiene scope of practice rests with the Dental Board of California. This issue has yet to be resolved.

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    The Consequences of Untreated Dental Disease in Children

    Advocacy BinderThe California Society of Pediatric Dentistry in collaboration with the California Dental Association has produced an advocacy binder dramatically illustrating The Consequences of Untreated Dental Disease in Children.

    Designed for supporting CDA and CSPD efforts in promoting legislation and public policy which improve children’s oral health, the binder contains introductory information on the progressive and largely preventable nature of dental disease, full color illustrations of untreated pediatric dental conditions, and a Children’s Oral Health Fact Sheet.

    The binder is available for viewing and for downloading by CSPD members. (PDF Document, 1.2 MB)

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    School House

    School Entrance Oral Health Assessments

    Groundbreaking legislation effective January 1, 2007 requires children entering public school for the first time in either kindergarten or first grade to present proof by May 31 of the school year of having obtained an oral health assessment.
    School Entrance OH Assessments">Get all the information and forms at this link!

    Other Advocacy News

    Denti-Cal's Notice of Intention to Adopt CDT 2009-10 Procedure Codes

    The California Department of Health Care Services has announced by the enclosed Notice of Proposed Rulemaking intention to adopt the 2009-10 CDT procedure code set for Denti-Cal claims processing, replacing the outdated 2002 CDT 4 code set used now. This "administrative simplification" will make Denti-Cal claims processing compatible with current dental practice management systems.

    Download this Notice of Proposed Rulemaking.

    CSPD Opposes Elimination of the Adult Denti-Cal Program

    Denti-CalThe California Society of Pediatric Dentistry joins with other state health care and patient advocacy organizations in opposing elimination of adult dental services under the state Medi-Cal program. Oral health is integral to general health and not an optional health service. Eliminating adult dental care will have a profound adverse effect on low-income adults, will immediately increase the cost of emergency medical services delivered in hospitals and physician's offices, and will ultimately result in greater future obligations to the state's general fund as oral conditions worsen without appropriate care. Children served by Medi-Cal will be affected as well:

    • When parents do not maintain at least one annual dental visit, children in their household are 13 times less likely to visit a dentist the same year. Numerous studies confirm that children not receiving annual dental visits, early diagnosis of dental problems, and regular preventive care services such as topical fluoride application and placement of dental sealants (all covered benefits under the Federally-mandated Medicaid childrens program) will experience greater future oral health problems and greater future state funding.
    • There is a demonstrable direct linkage between maternal oral health and the incidence of early childhood dental decay because of the transmissible and communicable nature of the oral bacteria responsible for dental decay.

    Members interested in CSPD's public policy stance may view the letters sent to Senate President proTem Darrell Steinberg and Speaker of the Assembly Karen Bass during state budget negotiations.

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    Denti-Cal Claims Submissions

    Alternate Code for Limited Oral Evaluation (D0140)


    On March 1 of this year, the California Department of Health Care Services (DHCS) implemented mandatory CDT-4 coding for all treatment authorization requests and claims submissions. CSPD member Jose Polido of Children's Hospital Los Angeles contacted CSPD recently to ask why CDT code D0140, defined by the ADA as a Limited Oral Evaluation -- Problem Focused, for situations of "emergency and trauma," is routinely denied by Denti-Cal when used for this purpose.

    As indicated in the Medi-Cal Dental Program Provider Handbook (March 2008), Denti-Cal uses D0140 not for the broad range of problem-focused cases as specified by the ADA code, but instead, for payment of an initial orthodontic evaluation by a Medi-Cal Dental Program certified orthodontist.

    According to a representative of the Department of Health Care Services, because orthodontic services are not generally a benefit of the Denti-Cal program, unless required by the Early Periodic Screening, Diagnosis, and Treatment (EPSDT) medical necessity provisions of the Medicaid act (such as in the delivery of care for cleft lip and palate), the Department needed a CDT-4 diagnostic code for assessing such qualification. They choose D0140.

    When asked, therefore, what code was appropriate and payable when a limited oral evaluation of emergency or trauma was provided [and other evaluation codes such as that for comprehensive oral evaluation (D0150) or periodic oral evaluation (D0120) were either inappropriate or unavailable], the DHCS representative suggested that for "problem focused" evaluations, providers should use D9430, which is defined in the Handbook as a catch-all, general "observation" code during regularly scheduled office hours in which no other services are performed (other than necessary radiographs and/or photographs)

    Members should be aware, however, that Denti-Cal billing for D9430 requires "written documentation for payment" that "shall include the tooth/area, the chief complaint and the non-clinical treatment taken."

    If, under the above DHCS guidelines, members experience claim denials, they are requested to contact CSPD's Public Policy Advocate, Paul Reggiardo, at 714-848-0234 or at with the detail.

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    Regulatory Matters

    Coronal Polishing and Oral Prophylaxis

    When is coronal polishing considered an oral prophylaxis? The answer, of course, under the California Dental Practice Act, is never.

    Section 1086 of the California Code of Regulations permits a Registered Dental Assistant to perform coronal polishing subject to certain conditions. One of these conditions is that the procedure must be performed under the direct supervision of a licensed dentist and only pursuant to the order, control and full professional responsibility of that supervising dentist. Under the provisions of direct supervision, the procedure must be checked and approved by the dentist prior to dismissal of the patient from the office. The Act states that "this procedure shall not be intended or interpreted as a complete oral prophylaxis (a procedure which can be performed only by a licensed dentist or registered dental hygienist)" and that the licensed dentist or a registered dental hygienist "shall determine that the teeth to be polished are free of calculus or other extraneous material prior to coronal polishing."

    Section 1067 defines coronal polishing as a "procedure limited to the removal of plaque and stain from exposed tooth surfaces, utilizing an appropriate rotary instrument with rubber cup or brush and a polishing agent."

    An oral prophylaxis is defined in the same section as "preventive dental procedures including complete removal of explorer-detectable calculus, soft deposits, plaque, stains, and the smoothing of unattached tooth surfaces. The objective of this treatment shall be creation of an environment in which hard and soft tissues can be maintained in good health by the patient."

    Only a currently-licensed Registered Dental Assistant (RDA) may perform coronal polishing, which is considered part of an oral prophylaxis. Since January 1, 2006, all Registered Dental Assistants have been required to have completed an approved course in coronal polishing to obtain or renew their licenses.

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