Proposal by Pa. Dentistry Board Would Allow Dental Hygienists to Practice in Physician Offices

Last Updated: Apr 3, 2019

dental-visit-childOn March 23, 2019, the State Board of Dentistry (Board) issued proposed regulations relating to public health dental hygiene practitioner (practitioners) practice sites to implement a law – Act 60 of 2016 – that gave the Board the ability to add other locations it deemed appropriate for practitioners in addition to those enumerated by the General Assembly.  

The Board is recommending adding “an office or clinic of a physician who is licensed by the State Board of Medicine or the State Board of Osteopathic Medicine” as an acceptable location for the practice of these practitioners. The Board says it believes this additional location will expand access to oral health care and education by these practitioners and will assist patients, particularly pediatric patients, find a dental home by way of the annual referral to a dentist as required under the regulations.

PAMED to Comment, Seek Clarification

On April 3, 2019, the Pennsylvania Medical Society (PAMED) issued a comment letter to the Board. PAMED is seeking clarification on how these regulations will affect physicians and physician offices that choose to place these practitioners within the office setting. Specifically, PAMED will ask the Board to clarify the following:

  1. Is physician employment of such practitioners voluntary? 
  2. What role will the Board play in approving these arrangements or otherwise reviewing the terms or conditions between a physician or physician’s office and a public health dental hygiene practitioner?
  3. What are the responsibilities of the physician or the physician’s office to public health dental hygiene practitioners practicing in their office, i.e. must physicians provide specified oversight and to what extent?  If there will be oversight responsibilities, will those responsibilities be specified in the final-form regulations?
  4. Will the Board oversee issues that could arise in physician offices, including with physicians specifically, or will the Board refer those issues to the State Boards of Medicine and Osteopathic Medicine or another appropriate agency?

The Board will review all comments and questions submitted to it and respond accordingly. The Board has until April 22, 2021 in which to submit final-form regulations to the Independent Regulatory Review Commission for review and approval.

PAMED will continue to monitor these regulations and provide updates to its members.

How to Submit Comments

Members wishing to submit their own comments must do so by April 22, 2019 to:

Via mail or email:
Ariel O’Malley, Board Counsel
State Board of Dentistry 
P.O. Box 69523
Harrisburg, PA 17106-9523


Via email:

Comments must reference the following:

State Board of Dentistry
Proposed Regulations:  Public Health Dental Hygiene Practitioner Practice Sites
IRRC # 16A-4633

Read more about the proposed regulations here.

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