The Dental Hygiene Board of California has approved launching a formal rulemaking process to clarify registration and form requirements for mobile dental hygiene clinics and registered dental hygienists in alternative practice (RDHAPs) who use portable equipment.
Dr. Adena Petty, the board’s regulatory presenter, explained that the updates resolve conflicts between existing regulations and state law while making form instructions clearer.
Notably, the term “diagnoses” was removed and replaced with “care plan.” Forms now include a third column with an “NA” box to indicate when a requirement does not apply.
Emergency-oxygen and AED requirements are now linked to specific procedures, such as local anesthesia or soft-tissue curettage, rather than applied universally.
During committee discussions, members proposed replacing “care plan” with the more precise “dental hygiene process of care” and explicitly including “assessments.”
Revised draft language now requires that patient records document the full dental hygiene process of care, including medical history, assessments, care plans, procedures, treatment responses, consultations, and referrals.
The board approved moving the proposed rules to the Department of Consumer Affairs and the Business, Consumer Services and Housing Agency for review and authorized the executive officer to initiate the rulemaking process.
The changes aim to clarify which requirements apply to primary physical facilities versus those that only maintain portable equipment, and to tie certain safety-equipment mandates to the services actually provided.
Board staff said these updates should reduce confusion for RDHAPs and mobile clinic operators when completing registrations and forms.
Next steps include posting the proposed regulations for a 45-day public comment period. If no adverse comments or hearing requests are received, the executive officer may adopt the regulations following the Administrative Procedure Act timeline.
