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Proposed Clearinghouse Rule Lowers Standard of Care for State’s Children

WEST ALLIS, Wisconsin – The 2,900-member Wisconsin Dental Association (WDA) opposes Clearinghouse Rule 05-033 (CR 05-033) that would allow dental hygienists to obtain state government reimbursement for services without an examination of the patient, diagnosis and prescription for care by a licensed dentist. This proposal will lower the standard of oral health care for Wisconsin children and siphon dollars from a critically under-funded dental Medicaid (MA) program.

The proposed rule, which comes before the Legislature’s Joint Committee on Review and Administrative Rules (JCRAR) on June 8, would allow dental hygienists to provide services in a variety of settings without clarifying that those services should follow a dentist’s exam and diagnosis.

Dental diagnosis is at the heart of the eight years of education and training required for a doctorate in dental surgery (DDS). Graduates of two-year dental hygiene programs are not capable of performing a dental diagnosis which is necessary to treat patients independently.

Access to a “dental home” and a professional dental exam is critical to delivery of dental services. For example, overall health factors like heart disease must be taken into consideration prior to providing services like scaling and root planing to patients with gum disease; these patients need a dentist’s expertise and diagnosis prior to treatment or a variety of medical complications could arise. The inappropriate application of sealants without a dentist’s exam can lead to a young patient needing extensive and expensive dental treatment and restoration.

Local sealant program managers have an open invitation to contact the WDA, which represents more than 80 percent of all licensed dentists in the state, if they need help recruiting volunteer dentists to provide professional diagnosis for school-based efforts at no additional cost to the programs.

“The WDA is concerned about some individuals dismissing the need for a dental diagnosis in determining the appropriateness, necessity and safety of specific dental treatments,” says Milwaukee general dentist and WDA Vice President Dr. Monica Hebl. “The WDA believes this rule could be manipulated to advance a political agenda which seeks, for the sake of convenience, to dismiss the crucial patient safeguards provided by a dentist’s diagnosis and treatment plan.”

Wisconsin does not allow for independent billing of MA services by physicians assistants or advanced practice nurse prescribers unless they have a collaborative arrangement with or follow a protocol that includes coordination with a licensed physician. CR 05-033 would allow for independent billing of services by dental hygienists who have much less education than either of these two groups of medical professionals.

Of the 10 states that allow independent billing by dental hygienists, all require some type of identification or collaborative practice with a dentist, strictly limit the types of services that can be billed and/or require additional training and certification as a public health or alternative practice dental hygienist. Rarely have there been more than 20 dental hygienists actively billing the dental MA program for services in these states.

“Allowing hygienists to bill an already financially-strapped Wisconsin MA program for services that have not been determined to be necessary or appropriate by a dentist will lower the overall standard of dental care across Wisconsin, jeopardize the long-term oral health care of some of our most vulnerable residents and provide one more excuse for the Legislature to avoid a long-term oral health commitment to the state’s MA program,” explains Hebl.

Furthermore, notes Hebl, the state already funds five part-time hygienists for sealant initiatives, along with $120,000 for additional hygiene services and materials.

The Wisconsin Hospital Association appears to support this proposal, because its members want to end emergency room visits by MA patients seeking relief from dental pain.

“We understand that problem and the dental community wants to find a real solution, but sealants will not keep people out of emergency rooms,” Hebl stresses.

A 2001-2002 “Make Your Smile Count Survey” by the Wisconsin Department of Health and Family Services reports 81 percent of Native Americans have a history of childhood cavities, despite having the highest percent (66 percent) of sealants placed.

“Patients need a ‘dental home’, where they can receive appropriate preventive services as part of a life-long comprehensive approach to good oral health which also includes education in personal oral hygiene, routine dental exams and early restorative care,” says Hebl.

Hospitals have been able to see MA patients by cost-shifting the financial burden on to private-pay patients. However, extensive cost-shifting within the medical model has clearly created problems of its own.

Dentists don’t cost shift. If dentists were to shift costs from the under-funded MA program to the private sector, dental care costs would increase to a level where private-pay patients would have trouble justifying expenditure of their discretionary dollars for services until the need for care became urgent. This would ultimately lead either to uncontrolled cost increases or to the collapse of a system unable to sustain itself primarily on payments from private-pay patients in need of emergency dental care.

Prevention is, and always will be, at the core of oral health care, but it cannot be truly successful unless the patient has access to a dental home. Dentistry’s historical emphasis on fluoridation, properly placed sealants, routine dental exams and early restorative care has created important barriers to the development of dental disease. While preventive efforts cannot eliminate dental disease, they must follow a dentist’s diagnosis and treatment plan in order to truly be successful in reducing the demand for more expensive dental treatment.

“Dental hygienists are important members of the oral health care team, but they don’t have the education or training necessary to provide the most crucial aspect of oral health care – the dental diagnosis. It is imperative that oral health care services provided to all patients be appropriate, necessary and safe and determined through scientific-based diagnosis by licensed dentists,” Hebl says. “The state must avoid yet another ‘feel good’ program that will do little to improve oral health care across our state.”

SOURCE: Wisconsin Dental Association

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