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Catalyst For Change

The American Dental Hygienists’ Association holds a leadership role in the development and implementation of new workforce models.

The American Dental Hygienists’ Association (ADHA) has actively been involved in increasing organized dental hygiene’s involvement in the development of new workforce models.1 To date, Minnesota and Maine have authorized the creation of new providers—dental therapists (DTs) and advanced dental therapists (ADTs) in Minnesota and dental hygiene therapists (DHTs) in Maine. In Minnesota, one of the two schools that offer this new dental therapy education program requires that applicants be registered dental hygienists as a prerequisite to entering the program. As such, graduates have dual licensure as DTs and registered dental hygienists. In Maine, state statute dictates that applicants must be registered dental hygienists for entry into the program. Graduates have dual licensure as DHTs and registered dental hygienists.


The Commission on Dental Accreditation (CODA) is the governing body in the United States that accredits dental schools, as well as advanced dental education programs and allied dental education programs. CODA’s mission is to “[serve] the oral health care needs of the public through the development and administration of standards that foster continuous quality improvement of dental and dental-related educational programs.”2 Following passage of legislation in Minnesota in 2009, the ADHA and others encouraged CODA to fully develop accreditation standards to reflect the progress and current practice of dental therapy education programs.

The draft standards circulated by CODA in early 2013 did not include a dental hygiene-based track. The ADHA led the effort to implore CODA to consider modification of the proposed dental therapy education standards to provide for a dental hygiene-based dental therapy track.

The ADHA’s methodical, strategic, and detailed advocacy efforts led to a meeting with the United States Federal Trade Commission (FTC), whose mission is to “prevent business practices that are anticompetitive or deceptive or unfair to consumers; to enhance informed consumer choice and public understanding of the competitive process; and to accomplish this without unduly burdening legitimate business activity.”3 FTC Chairwoman Edith Ramirez and FTC staff met with ADHA Chief Executive Officer Ann Battrell, MSDH, and ADHA staff. The FTC has a long history of providing comments on competition and consumer protection affairs and showed interest in innovative workforce models relative to their impact on competition in the workforce.

The ADHA advocacy efforts with the FTC culminated in a 15-page letter to CODA about the proposed standards for dental therapy education programs. The letter conveyed concerns to CODA—namely, “FTC staff urges the American Dental Association and CODA to avoid exercising their current authority in a way that could impede the development of this potentially valuable and innovative model of dental care delivery.” The letter further stated, “The standards’ effectiveness may be limited, however, by unnecessary statements on supervision, evaluation, and treatment planning. We respectfully suggest that CODA consider dropping such statements.”4

In February 2014, CODA adopted dental therapy education standards but fell short of implementing them. A revised version of dental therapy education standards was simultaneously circulated. The ADHA was delighted that all references to supervision and scope of practice limitations had been eliminated in this draft. Further, accommodation was provided for a dental hygiene-based model to include advanced standing for dental hygienists who may choose to enter such programs.

Again, the FTC responded, stating that it “supports CODA’s efforts to facilitate the creation of new dental therapy education programs and to expand the supply of dental therapists because these initiatives are likely to increase the output of basic dental services, enhance competition, reduce costs, and expand access to dental care.” The FTC further encouraged CODA to “expeditiously” adopt the proposed accreditation standards.5

In conjunction with the release of the standards’ second draft, CODA requested additional information based on the “CODA Evaluation & Operational Policies & Procedures.”2 The document “The Principles and Criteria Eligibility of Allied Dental Programs for Accreditation by CODA” outlines the criteria that must be met for new allied dental education areas or disciplines. The criteria that required further comment were:

  • Has the allied dental education area been in operation for a sufficient period of time to establish benchmarks and adequately measure performance?
  • Is there evidence of need and support from the public and professional communities to sustain educational programs in the discipline?

CODA, at its August 2015 meeting, determined that the criteria had been satisfied, and its members voted to implement the accreditation process for dental therapy education programs. “The adoption and implementation of dental therapy education standards is a significant milestone. These new providers will address the unmet oral health needs of the public and create a new career path for dental hygienists,” remarked ADHA President and Dimensions of Dental Hygiene Editor in Chief Jill Rethman, RDH, BA.


The transformation of the dental hygiene profession is well underway, and new dental hygiene-based innovative models are emerging throughout the country. Through the ADHA’s advocacy efforts, which consisted of engaging educators, dental hygienists, dental hygiene students, oral health stakeholders, and the FTC, CODA revised the proposed standards to accommodate much-needed changes.

Following are highlights from the approved dental therapy education standards:6

Program length: The educational program must include at least 3 academic years of full-time instruction or its equivalent at the post-secondary level. This is considered the minimum amount of time required to educate a dental therapist. A specific academic degree is not identified.

Advanced standing: The program may grant credit for prior coursework toward completion of the dental therapy program. This credit may be given to dental assistants, expanded function dental assistants, and dental hygienists who are moving into a dental therapy program. Program prerequisites and other allied dental program coursework are part of the years of full-time study.

Supervision: The dental therapist provides care with supervision at a level specified by the state practice act.

Scope of practice: Dental therapy’s minimal scope of practice is outlined in the standards by listing the competencies required within the dental therapy curriculum. Some of the assessment skills such as evaluation, charting, patient referral, and radiographs are listed. Preventive functions include but are not limited to subgingival scaling and dental prophylaxis, application of preventive agents, and dispensing and administration of non-narcotic medications via oral or topical routes as prescribed by a licensed health care provider based on state laws. Competencies also include restorative/surgical procedures such as simple extractions of primary teeth, fabrication of temporary crowns, pulp capping, and preparation and placement of direct restorations.

Relation to state statutes: All authorized functions of a dental therapist in the state in which they practice must be included in the curriculum at the level, depth, and scope required by the state.

Program director: The dental therapy program director must be a licensed dentist or a licensed dental therapist who possesses a master’s or higher degree and must have a full-time administrative appointment as defined by the institution. A dental hygienist who is also a dental therapist would be qualified to serve as the program director.

The ADHA remains steadfast in its commitment to advancing opportunities for dental hygienists. It continues to advocate leveraging the educated, licensed workforce that dental hygienists offer to best meet the oral and overall health care needs of the public.


  1. American Dental Hygienists’ Association. American Dental Hygienists’ Association Strategic Plan. Available at: Accessed September 17, 2015.
  2. American Dental Association. Commission of Dental Accreditation. Evaluation & Operational Policies & Procedures. Available at: Accessed September 17, 2015.
  3. United States Federal Trade Commission. About the FTC. Available at: Accessed September 17, 2015.
  4. United States Federal Trade Commission. Response-FTC Staff Comment on the Commission of Dental Accreditation Concerning Proposed Accreditation Standards. Available at: Accessed September 17, 2015.
  5. United States Federal Trade Commission. Response-FTC Staff Comment on the Commission of Dental Accreditation Concerning Proposed Accreditation Standards. Available at: Accessed September 17, 2015.
  6. American Dental Association. Commission on Dental Accreditation. Accreditation Standards for Dental Therapy Education Programs. Available at: Accessed September 17, 2015.

From Perspectives on the Midlevel Practitioner, a supplement to Dimensions of Dental HygieneOctober 2015;12(10):32–34.

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