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Your obligations as an employer to verify credentials of dental staff members

Originally appeared in the May/June 2016 issue of Dispatch

In a dental office, there are often staff members other than the dentist with different degrees of responsibility for patient care. This may include regulated health professionals who provide care independently or under a dentist’s order and non-regulated staff who provide intraoral services.

Before authorizing any staff member to perform any form of dental treatment or provide other professional services to patients, it is the dentist’s responsibility to ensure that they are qualified to do so.

While the College is not able to provide legal advice, the practice advisory service recommends that you perform due diligence to ensure that the dental staff whom you plan to authorize to perform controlled acts, such as scaling and root planning, restorative procedures, orthodontic procedures, and duties related to the administration of sedation/ anesthesia, are currently registered.

The registration status of regulated health professionals, whether dental hygienist, nurse, respiratory therapist, or denturist, can be verified by checking the online registers of their regulatory college or by calling the respective college. You might consider requiring proof of payment of registration fees from regulated health professionals annually. However, keep in mind that registration status could change at any time. That is why it may be prudent to verify the registration status of regulated professionals periodically.

You should require non-regulated staff, such as dental assistants, to provide proof of successful completion of HARP-approved courses in dental radiography. Or, if they completed their dental assisting program outside of Ontario, you need proof that their qualifications have been assessed by the Director of X-Ray Safety, X-Ray Inspection Service (XRIS) of the Ministry of Health and Long-Term Care and that they have been deemed HARP-certified. You should also ensure that level II dental assistants have successfully completed examinations for the National Dental Assisting Examining Board (NDAEB) certificate and should request this documentation when staff join the dental office and/or gain these credentials.

To verify whether a dental radiography program is HARP-approved or to obtain information about the assessment of qualifications for dental assistants who have completed programs outside Ontario, call XRIS at 416-327-7937.

Regulated health professionals – dental hygienists, registered nurses, respiratory therapists, denturists – who are not currently registered are not able to practise their professions. They must not be permitted to perform any controlled acts until they are reinstated.

You should consult with an employment lawyer about how to implement changes in the terms of employment of current staff before taking any action if it is discovered that qualifications were misrepresented or if there is a change in registration status.

It is important to note that, even if the dental services that were provided by a staff member who was not registered or did not have the necessary credentials was appropriate and performed properly, the failure of a dental services provider to have the necessary credentials could violate an implicit term of the contracts between the dental office and the patients, which would necessitate a return of dental fees for those services to the patients of the dental office.

Need to know

Dentists are responsible for ensuring that the dental staff they authorize to provide dental services are registered and/or have the necessary credentials.

Principal dentists and dentist employers may consider:

  • scheduling periodic checks of college websites for regulated health professionals;
  • requesting proof of payment of registration fees from regulated health professionals;
  • requesting periodic proof of professional standing;
  • requesting proof of completion of educational programs and examinations (i.e. NDAEB certificate) and documentation of HARP-certification for non-regulated staff.