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74 Responses

  1. Dentist

    Continuing Professional Development

    Participatory Learning – It appears to be giving more weight/credits for hours spent in participatory learning, which is fine. It is good that there is no mention of requirement for a minimum of credits to be participatory, which may be more difficult for dentists in rural settings or areas with less opportunity for study clubs or hands on learning.

    Required Competencies

    Repeatedly taking these courses every 4 years is not necessary, and extremely redundant (especially for record keeping and infection control), perhaps a one-time requirement with mini courses with updates as they emerge. As for infection control guidelines, there has already been a debate on whether the guidelines are based on scientific evidence, expert opinion, or fear of public perception. Some concerns in these four categories of CDSBC online requirements is how the courses would be developed, and if they represent official college guidelines despite the subject being under debate. Similarly, SJEs will undoubtedly present a number of different approaches where the correctness of a response is not necessarily black and white.

    Objective Feedback

    I think we can all agree that most dentists do not need additional regulation beyond themselves – most are objective at self-assessment and have colleagues and specialists to turn to for feedback and advice. It seems that it is likely that the “problem” dentists in our midst would easily hide their questionable or non-ethical behavior and cases from assessment, and would not be improved. Practically, the collaborative peer groups and office visits would likely be formed by colleagues who are friends, negating the objectivity intended. I’m not sure that office visits are anything more than a time-consuming exercise, with little value to dentists, their practices, or the public.

  2. Dentist

    I echo the comments made by the colleague on November 13, 2018 at 6:31 AM fully, so I will not waste our time and space here to paraphrase.

    The current CE structure is working extremely well for our profession, apart from a need to improve access or opportunities for registrants in remote areas to earn CE hours through on-line, on-demand and/or regional modalities. It would not take a complete overhaul of the CE program, as proposed, to achieve this.

    The modalities of objective feedback and required competencies looks good on paper, but they may turn out to be costly and problematic in their implementation and enforcement.

    The crux of the question is: in the era of evidence-based practice, as applied to professional governing, is there really any strong evidence that the public is going to be better protected by implementing the proposed changes?

    I urge the College not to make decisions about the CE program based solely on ideology, but also on practicality, and most importantly, evidence.

    Thank you for the chance to provide feedback.

  3. Dentist

    I agree with the core competencies for record keeping, ethics, infection control and CPR. However I feel the objective assessments and dentist to dentist office visits are unnecessary. As every dentist I know (and their spouses) will attest to , whenever you get two dentists in a room, the conversation turns to their work and their practices. We already judge ourselves all the time and constantly strive to be better. There is no need to enforce more of that. A voluntary forum such as study clubs, PDC, courses and open discussions is much healthier and less stressful. The study clubs provide a great forum with specialist input and challenging and thoughtful cases and topics. Perhaps an alternative would be to ensure that there is a study club component versus the office visits and one on one peer review. After all, the dentist to dentist visits may be viewed very skeptically .Who decides who gets to be judge and jury for whom?

  4. Dentist

    Quality assurance:
    Just love the profession
    And all concerned will be well served
    And The College will not be perturbed.
    Dentistry has moved leaps and bounds.
    Oral care and public awareness to oral health has risen,
    That never a general public has been so well served by a profession.
    It makes sense to focus on the morale of all dental practitioners.

    Failures or mishaps are not intentional. And our successes far outweighs the negatives.

    Strange as it sounds The ideology of the profession is its elimination.
    Will the next century bring us closer to that .
    Infection control:
    How many cases of disease transmission has occurred in the last decades dating back to the 1950 ‘s from Dentists to patients or from patient to patient in a dental office.
    Where and when did this hysteria began ?
    Florida , in the early 1990’s . Ms. Kimberly Bergalis claimed that she contracted HIV from her dentist. This was the most severe blow to Dentistry ,its reputation .Mega Corp wasted no time to capitalize on this misfortunate vulnerability and sustained a most profitable sector of this industry. So much was lost, and even today the brainwashing is irreversible.Please read Dr. John Hardie ‘s articles of February 2018 and the October 2018 in the Oral Health Journal.
    There is hope that thorough brushing and sterilization of instruments is key to decrease risks.

  5. Dentist

    I would like to thank the QA Committee for the extensive work and time allotted to the proposed QA. Changes are inevitable, however the proposed changes to the QA pose various concerns. Without details misunderstandings and misinterpretations are more likely to occur with both, the Registrants and the Staff at CDSBC administering the program "subjectively".

    -How will the administrator be trained to oversee the acceptance or failure of QA? The vetting process????
    -Will there be records of how the complaints increase or decrease after implementation of the new QA?
    -Has the College ever studied:
    (a) Has the College seen spikes of complaints during certain years? -Certain administrations? And if there greater fluctuations, why is this so?
    (b) How many complaints are received and how many of those complaints need actions taken? %
    (c) Have complaints increased in proportion to the increase in number of dentists? What about number of procedures vs number of complaints?
    (d) Is this being done to keep the Ministry of Health (HPA) at bay? We have been told repeatedly that HPA expects this - can HPA be wrong on their expectations?
    (e) What is the driving force of having repetitive administration - i.e. Record retention and audit and having to do CPR, IPAC and SJE every cycle?

    While reviewing the proposed changes, I noticed that the committee expressed numerous times that the changes were evidence based. I am not confident that the 90 hrs continuing education in 3 years; and the 300 hr of continuous practice per year, were evidence bases. Wonder if these were arbitrarily chosen years ago? Does CDSBC have evidence on number of hours quoted?

    Also the concern of administration of "peer to peer" and "office visits" and "SJE" without clearly defining the details of how the College will administer the program is disconcerting. Until the terms of reference are clearly defined, this whole process appears to be a 'non-starter'. Situational Judgment Exercise will change based on various factors i.e patient to dentist ratio, different modality of treatment recommended by dentists (specially when patients now seek 2nd and 3rd opinions along with google education and are totally confused as to what they want. Corporations are increasing, so they are able to give patients better offers due to bulk buying, in house labs etc..

    As for Collaborative peer groups, aren't study clubs a fine example of collaborative study with our peers? Most people part-take in Study Clubs for support and sharing cases and problems arising in our office settings. We totally values study clubs, so get members to join them. That would resolve several issues - peer to peer, collaborative peer groups etc..

    That brings me to Record Retention and Audit, we have a sign in sheet for all study clubs and other courses. These signed sheets are then directly sent to the College. That leaves us with PDC - why can't the College scan us in and out of the courses? We confirm on line, along with letter/certificate of attendance for the course taken. Why burden all with more administration i.e. Registrants and the College Staff? If you have a bad apple, then by all means, take that Registrant to task. But in this era, why increase paperwork for all?

    Most dentists I have spoken to, strongly recommend that dentists could take CPR/BLS (basic life support) once in 5/6 years. Some dentists I have spoken to have claimed that they did CPR update 15 year after graduating and passed with over 90%.

    IPAC/SJE can be taken by all new registrants and should be available on line for all to reference. "The Bridge" that BCDA puts out situational judgment issues and problems that occur in dental offices and staff issues; the information on how to avoid problems is greatly appreciated. Could CDSBC and BCDA put all their SJE issues in "The Bridge", as and when issues come up? These could also be posted on CDSBC site as well as information on SJ.

    It would be helpful if we work together to avoid complaints and encourage colleagues to contact one another and resolve issues to serve the public better. I miss the old day, we used to pick up a tool called the "PHONE" and resolved the issues amongst ourselves to help our patients .
    Finally, without clearly defined and written expectations, we could erode our relationships with each other and with our Institutions.

  6. Dentist

    I have a number of concerns regarding peer reviews. Some of these concerns have already been raised by other members.

    A) Logistics: How does it work for dentists located in remote or isolated communities? How about associates and locums who do not work in a regular location on a regular basis? How about members who work or volunteer sporadically, especially those who choose to go overseas?

    B) I feel many in the profession would not want to be fully transparent or revealing of their own best business practices.

    C) I also imagine many dentists would be hesitant to report their peers to the CDSBC as soon as their peer review discovers something not up to par.

    D) What will the CDSBC gain from these peer review reports? Who will read the reviews? What actions will be taken as a result? What evidence is there to demonstrate that such a review process will improve patient care?

    E) If the CDSBC really wants to audit dental practices (similar to what the CDA on Nov 6 commented), I would rather they have a team of trained auditors and select 10% of dentists to audit each year. There will be an objective list of criteria to audit. Problems discovered will not result in automatic suspension, but the member will be notified of these issues and a timeline given for correction and follow-up.

    F) On similar lines, I have a concern about the complaint investigation process too. It seems like dentists are not investigated until there is an official complaint. But when a complaint is filed, the CDSBC will do a very thorough investigation that reaches far beyond the complaint itself to the point most dentists will be found negligent or guilty of some other issue. How is this fair for dentists who received a complaint versus those who did not? Why not just investigate the complaint? Or else why not audit all dentists from time to time? Is the peer review a means of "filing a complaint" on each other?

  7. Dentist

    I believe in continued professional development and in setting a standard that befits the profession, but I also believe that dentists should be able to choose how they wish to learn. I believe that is part of being a health care professional. As such, I’m a supporter of the CPD changes, but have some concerns regarding the compulsory Required Competencies and Objective Feedback.

    In any profession or trade, there are some that are a credit to the profession, some that are less so, and the vast majority who are skilled, capable, conscientious, and caring of the people they treat. Dentistry is no exception. And the concern is that the some of the changes being proposed in the CPD program, in trying to be inclusive, end up making no distinction between practitioners that may be vastly different in how they learn, what they want to learn, how much they want to learn, and how much they care. Does a dentist who gives courses on infection control and has committed substantial time and resources to become an expert in infection control actually need to take an infection control course once every 6 years? Does a skilled dentist who learns best taking didactic courses need to be forced to join a collaborative peer group? Does a dentist who has never had a complaint made about them by a patient need an ethics course? There are also those of us that wouldn’t want to be responsible for giving feedback to one of our colleagues on how to run their practice, given the vast differences between how we all run our practices, and given the differences to what we have all focused our learning on over the years.

    I understand the need for the College to serve and protect the public. But seeing as the vast majority of us aren’t harmful to the public, my thought would be that some of these changes need not be made compulsory for all dentists, but rather are available as a resource to those that need it, or who have shown themselves over time to have philosophies of care that invite complaints from their patients.

    Thanks for allowing for feedback from practitioners prior to implementing such widespread changes.

  8. Dentist

    I have read the reviews, and agree with many that echo a similar concern. I totally understand the purpose for QA and how it has been adopted by so many healthcare professionals. Many that I have talked to that are diligent with their CE, find it redundant and of no use when discussing scenarios of treatment options. If the public has lost trust in our profession, it is the 5% of bad apples that make it look bad for everyone else. We will be generating a huge expense for training that is needed by the 5% that maybe minimally getting their credits. The College knows who these individuals are, as I am sure they are repeat offenders. Can you not focus on these individuals without dragging the passionate dentists in? I personally get several 100 more CE credits every cycle from an enormous amount of courses as well as 2 ongoing study clubs. We constantly discuss treatments with specialists and other peers. We already do this QA in our own way. I have 30 years experience with 2 College complaints. I don't think this is that bad. Please don't make an expensive system that looks good on paper but really only is needed for 5% of professionals. All the QA that we do in our study clubs and courses is 10 times more than the College is proposing. Please create a system that targets the problem doctors.

  9. Dentist

    I would like to thank the QA Committee for the extensive work and time allotted to the proposed QA. Changes are inevitable, however the proposed changes to the QA raise various concerns. Without details, misunderstandings and misinterpretations are more likely to occur with both the Registrants and the Staff at CDSBC administering the program "subjectively".

    -How will the administrators be trained to oversee the acceptance or failure of QA?
    -Will there be records of how the complaints increase or decrease after implementation of the new QA?
    -Has the College ever studied:
    (a) Spikes of complaints during certain years? -Certain administrations?
    (b) How many complaints are received and how many of those complaints need actions taken?
    (c) Have complaints increased in proportion to the increase in number of dentists?
    (d) Is this being done to keep the Ministry of Health (HPA) at bay? We have been repeatedly told at AGMs, that we need to abide by what HPA wants. Could the HPA be wrong at times?
    (e) What is the driving force of having repetitive administration - i.e. Record retention and audit and having to do CPR, IPAC and SJE every cycle? Will this better our delivery at chair-side and decrease complaints?

    While reviewing the proposed changes, I noticed that the committee expressed numerous times that the changes were evidence based. I am not confident that the 90 hrs continuing education in 3 years and the 300 hr of continuous practice per year, were evidence based. Wonder if these were arbitrarily chosen years ago? Does CDSBC have evidence on number of hours quoted?

    Also the concern of administration of "peer to peer" and "office visits" and "SJE" without clearly defining the details of how the College will administer the program is disconcerting. Until the terms of reference are clearly defined, this whole process appears to be a 'non-starter'. Situational Judgment Exercise will change based on various factors i.e patient to dentist ratio, different modality of treatment recommended by dentists (specially when patients now seek 2nd and 3rd opinions along with google education and are totally confused as to what they want. Corporations are increasing, so they are able to give patients better offers due to bulk buying, in house labs etc..

    As for Collaborative peer groups, aren't study clubs a fine example of collaborative study with our peers? Most people part-take in Study Clubs for support and sharing cases and problems arising in our office settings. We totally values study clubs, so get members to join them. That would resolve several issues - peer to peer, collaborative peer groups.

    That brings me to Record Retention and Audit, we have a sign in sheet for all study clubs and other courses. These signed sheets are then directly sent to the College. That leaves us with PDC - why can't the College scan us in and out of the courses? We confirm on line, along with letter/certificate of attendance for the course taken. Why burden all with more administration i.e. Registrants and the College Staff? If you have a bad apple, then by all means, take that Registrant to task. But in this era, why increase paperwork for all?

    Most dentists I have spoken to, strongly recommend that dentists could take CPR/BLS (basic life support) once in 5/6 years. Some dentists I have spoken to have claimed that they did CPR update 15 year after graduating and passed with over 90%.

    IPAC/SJE can be taken by all new registrants and should be available on line for all to reference. "The Bridge" that BCDA puts out, often has situational judgment issues and problems that occur in dental offices and staff issues; the information on how to avoid issues is greatly appreciated. Could CDSBC and BCDA put all their SJE issues in "The Bridge", as issues come up that effect us all? These could also be posted on CDSBC site. Complaint issues diminish our profession, we should all work towards serving the public better. It would be helpful if we work together to avoid complaints and encourage colleagues to contact one another and resolve issue to serve the public better. I miss the old day when we used to pick up a tool called the "PHONE", and resolved the issues amongst ourselves to help our patients all because we cared about our profession and our integrity.

    Finally, without clearly defined and written expectations, we could erode our relationships all round, and have a 'them" vs "us" situation with our Institutions - which we should be holding in high esteem!

    Communication among us dentists, transparency and written expectations from the College will help us all serve the Public better. Let's start with QA simplifying things and Standard of Practice in all disciplines of dentistry - Transparency and well defined Expectations are the key to success.

  10. Dentist

    I appreciate the challenges faced by CDSBC in balancing expectations of the public and the Health Professions Act with those of registrants. I would appreciate clarification of some aspects of the new QA and have the following questions for CDSBC:

    1. Improved Patient Outcomes are a stated objective of the new QA.
    a. How does CDSBC currently assess patient outcomes?
    i. number of written complaints received?
    ii. number of written complaints approved for investigation
    iii. ratio of written complaints approved
    number of complaints received

    iv. number of complaints to Health Professions Council
    v. number of insurance fraud investigations/charges?
    vi. Other such as nature of the complaint?

    b. How will CDSBC determine if the new QA achieved improved patient outcomes?
    i. By reduction in raw number of complaints or by a specified percentage of complaints as in (a) above? Other measures?

    2. a. What were the criteria through which the current QA program was evaluated and determined to be inadequate?

    b. Will the new QA be evaluated by the same criteria that deemed the current QA inadequate?

    4. Given the large number of CDSBC registrants, what percentage of registrants
    a. had complaints registered against them?
    b. had complaints against them approved?
    c. had complaints against them proceed to Health Professions Council?
    d. had insurance concerns/investigations against them?
    e. How do 2017/18 complaints statistics compare to 5 years ago? 10 years ago?

    Extrapolating from the “user pay” concept, why does CDSBC not focus upon those registrants receiving complaints against them instead of mandating that all registrants require remedial QA measures?

    A very small number of registrants receiving multiple complaints will skew the complaints statistics.

    5. a. Does CDSBC have data that correlates ≥ 900 continuous practice hours/cycle with favorable patient outcomes? As compared to < 900 hours and unfavorable patient outcomes?

    b. Does CDSBC have data that correlates 90 CE credits/cycle with favorable patient outcomes? As compared to < 90 CE credits and unfavorable patient outcomes?

    6. Peer Review
    a. Through which criteria will “peers” be vetted as competent evaluators?
    b. Will peer-evaluators receive training and be standardized? Which statistics will be used to ensure standardized peer-evaluation?
    c. How will bias be controlled?
    d. What are the criteria for the evaluation performed by peers?
    i. Dentistry encompasses a broad scope of practice – record keeping, infection control, and treatments: radiology, restorative/prosthetics, oral medicine/pathology, pedo, perio, endo, ortho, oral surgery, sedation…
    Will each scope of practice be investigated? Or random, specific aspects? What are the specific criteria/standards for evaluation of each scope of practice?

    ii. How are patient cases for review selected? Are cases selected randomly by the peer evaluator or are cases selected by the dentist being reviewed which will bias the case selection.

    e. How will peer evaluators and dentists for review be matched?
    f. How will patient confidentiality be protected?
    g. What are the consequences for the reviewed dentist if an unsatisfactory assessment is received? (pass/fail?).

    7. Core courses: perhaps CDSBC would consider including Privacy and Digital Information Security for dental offices considering the concerns with internet scams, identity theft and hacking concerns.

    Thank you!

  11. Dentist

    I applaud the CDSBC for putting so much time and thought into this proposed QA program. I know that the best intentions are fueling this endeavor, but there are several concerns I have with the proposed program.

    I think having particapatory learning worth more credits is a great initiative. There is no question that we learn better when we can engage multiple senses - seeing, doing, hearing. And by practicing within a course, we are able to take more risk in a controlled and supervised setting which can help us better manage cases in the future, properly diagnosis cases within our scope of ability, and gain confidence to perform procedures more successfully.

    One thought to consider with the 2/3 core credits, is that one of the largest issues facing new graduates is the lack of business management education that they are receiving in school. While dental schools (rightly) focus on training competent dentists, we also have to acknowledge that most of us will wind up running our own small businesses. What other profession expects their graduates to be health care providers, business owners, accountants, marketing agents, HR managers, etc. I fear that new grads (who normally are very up to date on the newest technologies and techniques) will be forced to take courses that will be slightly repetitive in topics, when in practicality they will need as much business management education as they can possibly receive. I am not saying that the 2/3 rule should change, but I think it is something that we should be cognizant about and find out if there is a way to address this issue.

    Self-Study - this rule seems a bit backward to me. In an age when technology is becoming more and more a part of everyday life, I wonder why we are restricting online platforms as a method of study. I wonder how is a live webinar different from an in person course? In both situations I am able to ask questions during the course. In neither situation is something ensuring that I am actually "paying attention" as some may say is the reason for requiring in person events. I often see doctors at "live" ce events scrolling facebook during the lecture, talking with friends, responding to emails, or even sleeping. I think we have to be also be realistic that there is a huge cost investment with live ce events, that will disproportionately affect younger members who are graduating with high debt loads. Not only are most of these ce events held during the week, but many new grads get stuck working the less desirable work days (including weekends) so live events require time off from the office (not only cutting into their personal days they can take off, but loss of income). There is also the added cost (most live courses are more expensive than online ones) of the course, the travel to and from and accomodations for those events out of town. There is also a huge time commitement to these events. With 50% graduating dentists who are women, we will also see this unfairly affect them especially during the time when they have young children and unable to travel away from them, or find childcare. This also affects those dentists practicing in more remote areas where access to care is harder and now they have to travel farther distances to make these events. I think there may be a better way to create requirements around online courses to make them acceptable to the college (tests after the course, with a certain % to pass them, etc). Online courses allow flexibility of people's schedule so that time off from work is no longer a hindrance.

    3 year rule: We need to remember that our fastest growing group are female dentists and younger members, both of which are going to be having young families and dealing with the challenges of meeting this requirement and the continuous practice hours (discussed below). Again, heavy requirements of in person ce when a dentist may have complications from pregnancy and childbirth can just be another stress during what should be a recovery time period. Having children can be an unpredictable event and often you are not able to travel (especially depending on how far you are from a hospital to begin with) for a few months before and after giving birth. This will be a major problem for those women practicing in remote areas where in person CE is not readily available to them. There at least needs to be an option for individual evaluation on a case by case basis.

    I agree with the required competencies, for ensuring a baseline of behavior and education for all dental professionals.

    Objective Feedback - I agree with this in theory but I don't think that this should be a requirement of the college, but rather a recommendation for all of us as dental colleagues. I believe that visiting other offices are amazing opportunities to learn and grow, however many will not want to open their doors to their competitors. This means that many will have to travel to an office outside their area to observe. Again this puts added stressors on new grads and those who live in more remote locations. Now I know that they could also just have a small peer group do a video conference, but some new dentists to BC may not have the connections to create a peer group during their first few years in the province. I believe that the latest stats show that there is a huge group of foreign trained and US trained dentists entering BC every year and we have to acknowledge that they may not know anyone to make connections for either of these options : groups or visits. Also I believe that this relies on the honor system and it will quickly just be an abused excuse for old buddies to hang out for the day when very little objective analysis will be obtained.

    Continuous Practice Hours - We really need to have an option for women having children. Many women have kids close in age, and pregnancy and child birth are events that can not be planned out and often carry inherent medical risks. There is no way to know if you will have to be out on bed rest far in front of your due date, if you will have a premature baby, or if there will be complications post delivery. We allow our staff to take an 18 month maternity leave and hold their jobs for them, yet women dentists are given no concessions in terms of helping them get back to work and maintaining their licenses. It will be an all too common occurrence to see a pregnant dentist have pregnancies close together and the possibility of complications may prevent her from even being able to get those hours in 3 years, especially if we are requiring in person ce for most of those required comments.

    Thank you for listening to this feedback. I think we have to remember EVERY dentist who practices in BC and not merely cater to the majority here. We need to make sure that those who are serving in the most remote regions where care is so needed, also take on added burdens.

  12. Certified Dental Assistant

    Wow, 50 dentist to 8 CDA in this response forum! What could this mean?? I heard that the number of CDA seats at CDSBC has gone from 2 to 1(!) that's half the representation for CDA's gone. Is this any indication of how these changes will truly reflect the realities of assisting. it is already difficult to find engaging and relevant while affordable CE opportunities as a CDA. In an era of staffing shortages, if CDA's are not properly represented in these changes could tihis exacerbate these challenges?..... I've attended CDABC AGM's the last 3 years, it's odd that at this crucial junction the CDSBC's CDA representatives (now singular) have not been dispatched to communicate the importance of CDA involvement with these proposals....

  13. Dentist

    The content is good to apply, except for the “Objective Feedback”, I think is not necessary as we always share thoughts and open discussions with our peers at any CPD event!

  14. Dentist

    Although much time and effort has been put into this Proposed QA Program, and I agree with much of in theory, I truly doubt it can really change the safety and quality of care to the public. It will likely significantly increase the cost and headaches to all involved. The logistics required for the College to assess whether the requirements are properly attained may prove to be an issue.

    As some have already commented, is there really a problem for the majority of the registrants? There will always be the bad apples in the barrel. Is there a trend that this number is growing? If so where (BC, other desirable places to live, North America, affluent countries, globally?) If so, why? Are we attracting the wrong individuals into our profession eg those whose primary interest is in the business of dentistry vs the profession of dentistry. Is our selection process flawed? Is it really an issue?

    Many of the previous posted comments have been excellent eg #6 Nov 3rd has addressed many of the points in a thoughtful manner

    The comments about female professionals are very worthwhile taking to heart. This is also true for Volunteers and part-time practitioners regarding hours of continual practice and minimum CE (or CPD if you feel it is so important to change). For female CDAs, dentists and dental therapists, child-rearing and maternity leave is a real and overlooked issue. I feel they can be brought up to speed and as professionals, they would want to be without having to achieve the general requirements set out in the proposal. It would be more humanistic if cases were looked on an individual basis. For example, consider if one had triplets!!! It'd be a nightmare to comply with the QA Program. Being unable to fulfill the requirements of the QA Program for a few years doesn't negate them from being a competent and caring health professional. As for is difficult enough to deal with the access to care issue. Retired or semi-retired dentists/CDAs may wish to volunteer in a free clinic. They may be very experienced and able professionals who just want to help the less fortunate. It may be an idea to have different licensing requirements and fees for these individuals. If anything, such activities should be encouraged and roadblocks taken away. The public would benefit. These individuals would have no selfish or ulterior motives. They'd just simply want to be of service.

    I agree participation CE is worth more than lecture only CE as long as the individuals partake so the 1.5 credits/hr make sense for these cases. This includes hands-on courses as well as study clubs (best in small groups as more chance all partake). As has been pointed out in other comments there are the "knives and forks" members as well as those that sleep through lectures. We all are aware of those professionals that exceed the CE requirements by a long shot and those that acquire the minimum requirements so they can keep their license. This will always be the way. To be a true professional one would want to continually learn and provide the best for their patients/clients. There are materials, techniques, etc. existing and constantly developing that one may learn that could result in improved outcomes for those under our care, especially in more complex treatment. The professional should be aware of what options are available and either choose to refer or take participation courses if choosing to treat. Participation definitely is worth more credits than lecture only and should be encouraged. How to determine if one is truthful in their entering their credits to the College could be a problem logistically.

    With regard to the Objective Feedback. Theoretically idealistic but realistically likely would be a failure. Many of us already do this via study clubs, comprehensive programs, having other dentists, students, etc. in our practices. There are those of us that thrive on this kind of relationship. However, there are those that are naturally introverted but are truly happy, very competent and ethical in their practice. Peer to peer reviews and outside office visits would upset these individuals incredibly. Would it lead to better protection to the public? I know of such individuals and have seen their work when they've referred patients who have moved into our area. Their work is of a high standard and has been successful in the longterm. Their patients have glowing reports of them and a very positive attitude toward dentistry. I consider them fortunate to have been in such colleagues' care. These quiet individuals are those who don't join study clubs but choose journals, online courses, Vumedi emails, etc. to get their CE. On the other hand I've also had patients of dentists who are hi profile, extensively advertise, have been involved in a lot of marketing and whose quality of work has resulted in complex problems. The nature of dentistry means biases, timidness, the "holier than thou" attitude, competitiveness, etc. which could lead to animosity and breaking down of relationships rather than the intended positive experience. Again the logistics of it working? There are those of us that have always conferred with others we respect who may have more experience and knowledge in a particular discipline. A true professional will seek those relationships. If just to attain a requirement, it can be a farce and may just result in undue stress for some individuals.

    The Required Competencies: Infection Control, Recordkeeping, Ethics courses and the SJE are good ideas. However any recommended courses would have to be well-scrutinized. What would be considered "right" could be debatable. One only has to read the recent article appearing in October/2018 "Oral Heath" of Dr John Hardie's "Critique of the RCDSO Draft Document on: Standard of Practice: Infection Prevention and Control in the Dental Office" to illustrate the potential problems in selected courses on these matters as well as with the SJE. Although the Required Competencies are a good idea having to take 2/4 of them each cycle is overkill. Perhaps each could be taken once every 5 years. If implemented they could be staggered over the first 3-4 years. After being in practice over 40 years, I think even once every 5 years isn't necessary. In our experience staff members can take some of these courses and report back at a staff meeting any important changes. These can lead to discussion and any changes deemed necessary can be undertaken.

    CPR Certification is a good idea for the entire staff although the CDSBC can only have requirements for those under licensure.

    In over 41 years of practice I have seen the standard of care of the majority of dental professionals has been positive and in the best interest of the patients. Of course there are the exceptions but they seem to be in the minority. There will always be those in any profession (or any walk of life) whose self-interests come before their patients, clients, students, etc. and result in a complaint. I feel it is the College's place to deal with these individual problems as they arise. To proceed in the way the Proposal has been there really an issue to go to that extent? Certainly if the number of complaints has been found to be increasing, something more than what we have must be done to protect the public.

    Thanks for the opportunity to input. The comments are insightful. As the proposal stands, it may prove to be a nightmare. Simplify and there likely will be more compliance and less cost.

  15. Dentist

    Good Day
    I have reviewed the proposed changes to the Quality Assurance Program...
    Your changes are well thought out and absolutely required...
    I realize some of these changes will be difficult...
    Of course the office visits will meet the most resistance.
    As talking is easy,
    for some the walk may not be so easy...
    My experience in life has taught me that money and egos often lie in the path of change...
    Objective learning becomes the criteria by which we ALL can become better clinicians and professionals
    Peer review and objective learning is the hallmark of every trusted professional organization...
    As a group we have to be concerned with the overall drop in public trust and the results of that loss in confidence will not only affect us now but all the future generations of dentists...
    It is TIME TO UP OUR GAME....

    • Dentist

      With all due respect, as much as "objective feedback" is an appealing catchphrase, I haven't seen any concrete evidence that it is going to improve public safety and public trust in our profession in a cost-effective manner. I do mourn the erosion of public trust in our profession through the quarter century of my career as you do. However, I suspect it has more to do with our behaviours that demonstrate self-interest (lack of professionalism and collegiality) over the public's in these competitive business climates. Consumers are smart, and they know how to "go public". Let's hope the College spends its energy wisely on the small proportion of registrants who are harming this trust, rather than tinkering on a CE program that works. I do support opening up more on-line, on-demand venues for registrants away from major urban centres to carry out CPD.

  16. Dentist

    Some of the proposed changes I believe are unnecessary, while some i think are a good idea. For required competencies i agree CPR should be mandatory.
    The objective feedback section is unnecessary and wasteful of our members time without providing any value to public or practitioners.
    Collaborative peer groups already occur at any CE course and office visits will not achieve the outcome you are looking for.

  17. Certified Dental Assistant

    I fully support the mandatory completion of the core competencies courses every 2 CPD cycles as this provides an opportunity to provide standardized, evidence-based information that supports and reinforces prior learning, and provides an opportunity for clarification and correction of misinformation. The frequency allows for information, technology, recommendation updates to be reviewed by all registrants. There should be an evaluation component to each.

    There is a huge amount of misinformation and misunderstanding (or lack of) within this area and much has changed in many registrant’ careers. I feel that it should be included in mandatory core competencies of the QA Program.

    Objective Assessments
    - I like this idea in theory but in reality I think it most likely that these groups will be formed by friend-peers which would make objectivity difficult.
    - If these types of assessments are to truly be supported within the QA Principles, I believe that “office to office” groups and visits would be more effective. The exclusion of other registrants (DT’s and CDA’s) from the “dentists only” groups is not only is non-collaborative but effectively eliminates the ability of ALL registrants to benefit from the information, feedback and perspectives that may be offered. This is true of the all the base competencies and especially true of infection control, record-keeping and SJE.
    - For example, CDA’s can discuss infection control recommendations all day long, but if the dentist does not take part in the discussion and appreciate and support the groups identified issues, ideas, or solutions, there is little actual value in the exercise.

  18. Certified Dental Assistant

    These proposals all look good in theory, but in practice they are anything but good. The average dentist in BC already has so much on their plate as far as requirements for licensure: continuous practice hours, CE credits, managing staff at a time where retention is challenging, running a business, creating treatment plans, consulting with health care professionals, plus the added pressure of student loan repayment for many. Dentists and CDAs alike have access to study groups where collaboration hits the key objectives of these other initiatives you are proposing to pursue. I would like to say that as a CDA as well, in a profession which is mostly female, the continuous practice hour requirements should have some leniency for child raising. CDAs (and female dentists) should not be penalized or pressured in this way to have the choice to stay at home for even the time that the government now gives to mothers: up to 18 months. This should be waived for that time and the dentist they work with should affirm their qualifications (within a reasonable amount of time being away from work- even 5 years of CE is kept up to date). I do not believe that this is unsafe for the public when a skilled professional is keeping current with CE, and while there are (uncertified, unregulated) dental assistants that have none of this governance or requirements at all! This is discriminatory and should meet the basic standard to which our government supports parents.
    In addition, the college should do its due diligence to randomly select offices to audit, rather than having peer on peer reporting. What dentist wants to give a poor review to their peer without first giving them the chance to listen to reproach and then improve? I believe this will do nothing but burden an already-burdened profession and the well-intentioned introspection you are looking for will result in misrepresentation and false reporting. It will be an increase of yearly fees for more staffing at the college to service objectives that are not grounded in reality.
    Also, volunteer hours outside of the country or province counting as continuous practice hours would do well for those dentists and CDAs who put their skill to use in this manner, and should be encouraged more.

  19. Dentist

    I have been a member of a hands on and didactic study club for 23 years. I have attended multiple didactic courses, hands on Endo courses and perio surgery with patients. I feel that the Collaborative portion of the requirements are unnecessary for myself. I agree with the rationale, but a study club of multiple engaged practitioners with mentors allows for wide reviews, comments and critique from general dentists and mentor/specialists with cases. I feel this type of study club outweighs two general dentists coming together to discuss a case. This one on one or phone call etc conversations about cases occur continually within my practice but it is the study clubs which can bring the challenging cases to be brought forward and shared between practitioners. Many elements of treatment planning are achieved and experienced this way which I feel is far more effective forum.

  20. Dentist

    This product shows a lot of thought and effort has gone into proposing the aforementioned changes.
    There should, however, be some attempt to state clearly the motivation for this change, other than "emerging trends".
    With respect to renaming CE :

    Perhaps the trend that is followed is to emulate our Federal politicians with introducing another acronym, CBD ,into our vernacular. Perhaps if we say CPD fast enough it will have the same appeal.

    Required Competencies:

    I am encouraged with the introduction of SJE. However, the use of SJE should be strategic as pertinent points and ideas can be better made when tied to situations as that is what our daily practices are , essentially experiential learning. With each topic , infection control, record keeping, etc there are key points and messages that are important to be conveyed. Place these in SJE and have registrants answer these on registration. There doesn't need to be many questions , simply be intentional and make the point.
    It needs to be noted that having the required competencies in a " complete this " format doesn't lead to a desired effect. In other jurisdictions , Ohio to be exact, it was required to have registrants complete a substance abuse course. After a few years, it was noted that this required competency didn't achieve the desired effect and was summarily removed.

    Objective feedback:

    The notion of Objective feedback may stem from some research from social scientists that suggest our abilities to self assess is flawed. Practicing Dentistry requires of us the ability to measure and assess our successes by tenths of microns on a daily basis. We can't ignore the requirement to self assess. What is being asked is whether we possess integrity.
    It has been my understanding that a very small percentage of practitioners stray over the lines of professional conduct. It then stands to reason that these individuals will be subjected to discipline as their transgression becomes apparent. After all, the CDSBC is a complaint driven entity that protects the public. One needs to ask , then, "is there an issue" ? There then shouldn't be a potentially intrusive attempt to obfuscate the very core of what it is to be a professional. You can not have a profession deemed to be professional and then treat the same as lacking the very qualities that embodies it.
    The act of objective feedback is what I have witnessed over twenty five years in various jurisdictions in North America and that is the collaborating of dentists in dental society meetings. You can't legislate integrity. If you want to create a way to insure skill then try an exam after graduation. Collaborate with all provincial boards to create a message to new graduates while in dental school. If you can not promise this to be effective, how will uncalibrated office visits be any more successful?

    If there is the suggestion that one thinks they are good at something but really aren't, that is what dental school is for , not a regulatory board. I have seen a steady reduction in societal memberships and this is curiously timed with the apparent need to collaborate. Encourage societal memberships in coordination with the BCDA to establish this.
    With regards to dentist office visits, is there a metric to measure outcomes as being successful?
    It seems the process of visiting each other is the process.
    If the CDSBC wishes to approach CE from a pedagogical perspective then this is well beyond their directive.
    So what do we do? If we are trying to appease the government then this is not the way to do it.
    The SJE format can be used in a poignant way to compile several scenarios that registrants will have to sign off on at registration. These scenarios can be changed year to year but the subject matter ( record keeping, infection control, etc) will have direct intentional situations that speak to points that CDSBC feels are important for that year.

    A lot of good thought and work has gone into producing the QA program and I thank you for the opportunity to shares some ideas.
    Its time to revisit the strengths that allow us to be self regulated and not move away from them.

  21. Dentist

    I'm open to the required competancies of record keeping, infection control and ethics, as well as the CPR requirement. However, I'm skeptical of using situational judgement exercises as a means of assessing registrants. Who determines what a correct answer is? There are often multiple ways to approach a problem. How will a registrant's answer be evaluated? How does this assess a registrant's communication skills? Will this online assessment reflect their approach in real life?

    As for the objective feedback proposal, most dentists I know already seek objective feedback in study groups, dental societies, from specialists or informally with colleagues. Adding dentist-to-dentist visits or collaborative peer groups is unnecessary and time-consuming.

  22. Dentist

    I think that some of the quality assurance changes will be good in that it will encourage hands on courses for dentists as well as ensure that infection control and employment standards are acknowledged and up to date.
    However, I am very concerned about the ‘objective assessment’ aspect as I don’t believe, in the small community that dentistry is, that this can truly be objective. Whether assessing a case presentation of a fellow colleague or inspecting their office for infection control protocols or charting, I believe that bad blood will be produced in both scenarios. Unlike medicine where much of the discussion surrounding patient care is based on diagnosis about physiologic and metabolic systems, in dentistry patient care is conducted by the hand of the dentist, showing his/her technique and talent. It produces a tangible product and assessing this could be taken very personally by many, as an attack. With the competition building in BC with increased dentist to patient ratios, I really feel we need to prevent animosity between dentists.

    One thing I would add and ask the board to consider under the mandatory courses are courses on mental illness. Many dentists and other members of the dental team suffer from mental illness and dentists need to be informed on the latest research findings on how to identify and help themselves or others in this realm. With well being being such a strong pillar for good conduct in general but especially influential in a profession where you affect many others, this would be a vast oversight not to include in the mandatory CE courses.

  23. Dentist

    I hope that the comments here will truly be used in the consultation and reconstruction of the proposed changes to the Quality Assurance program. Since there is no proposed goal/problem/concerns it is hard to come to any conclusion that this is anything other than a "make work project". As a dentist in private practice for 11years, I see areas where the profession could be improved upon to better serve the public, but fail to see how what is proposed hear will serve that end. As far as a Quality Assurance measure, since the number of internationally trained licensees is on the rise and does not show any sign of slowing down. Should not the focus be on making sure new dentists, trained in BC or elsewhere, continue to meet the standard of care beyond licensing? Institutes exist to "teach the test", there is no assurance that what is taught is adhered to.
    Beyond this the categorization of CE credits is onerous to the registrant and short sighted by the college. To limit credits for • Practitioner health/wellness • Practice management • Volunteering does not serve the registrant or the public. In effect you are discouraging practitioners from having good self-care, sound business knowledge and serving a greater cause...this is a recipe for the collapse of the profession. It is exactly what should be taught to improve quality, especially in an era where being a dentist is exceptionally challenging. Lastly my concern with the "Required Competencies" is that the course work for these doesn't even exist yet. Some of the ideas are good however. I like the idea of encouraging collegiality with peer groups and office visits. In practice I don't think they will work. However a Situational Judgment Exercise that combined these would be an amazing thing to encourage. It is what I do the most and learn the most from. Sharing a case with 5 or more colleagues is what is already happening with younger professionals thru online platforms and would keep the college relevant and dentists engaged in effective learning.

  24. Dentist

    While I am open to any program to increase the competency and ethics of the profession I'm unsure that more obligations to attend ethics courses, have peer to peer evaluations, and create more paperwork to justify attendance at CE courses can attain this. I think it would is incumbent on the CDSBC to randomly choose 3-5 cases of previous investigations where a member failed the profession and then show that if these new guidelines were in place they would have prevented failings of that member. Please show us how these new responsibilities as proposed will guarantee the return of improved professionalism. There are only so many hours per week that I can provide to my business, patients, and peers and this proposal does not recognize the pressures we are under at the present time to meet the needs of the public. I think the peer to peer review is entirely useless to lift the profession and as such should be dropped.

  25. Dentist

    I think this will unnecessarily add to the many challenges that a dentist has; ie staff problems, competition, paying student loans and struggling to manage a business financially. In my opinion instead of making a dentist’s life more difficult than it already is, there should be more control over the number of newly licensed dentists each year. This will ease the existing competition and give dentists more time to persue more continuing education courses.

  26. Dentist

    I'm sorry but I just don't see that the current system of quality assurance is so flawed that we need this drastic of a change. This seems needlessly bureaucratic and impractical. How are we to assure "objectivity"? Who would be deemed to be a worthy judge?
    Dentists in BC and Canada in general hold themselves to a very high standard. By any international comparison our dentistry is amongst the highest quality.
    Problems in quality should continue to be addressed in a similar manner as they are now.
    I don't see the need to burden the conscientious majority of practitioners with needless time consuming inquisitions.

    Continue to support excellence in continuing education in dentistry.

    The College is fully capable of protecting the public from the distinct minority of problematic practitioners.

  27. Dentist

    Sounds like a way for dentists who don't practice to make more bureaucracy for the rest of us struggling to meet all current restrictions, qualifications etc on top of trying to run a business. CE is fine already!!!

  28. Dentist

    I think that in the Lower Mainland we have the opportunity to participate in hands-on Study Clubs that give the opportunity for dentists to observe the clinical practices of other dentists. This is incredibly valuable. I have been in Study Club where rural dentists came into town for the Study Clubs. I would like to see more Study Clubs available to rural dentists because the experience is truly life changing. Should this be mandated? I am not sure about that. Rural dentists face a lot of challenges in that they don't have specialists and colleagues to consult with or turn to in many cases. I think that ensuring CE in a broad number of topics is good so dentists don't just focus on one area although requiring education in pedo if you don't treat kids does not make sense. I think that anyone sedating patients at any level should have to take Airway Management and ACLS courses.

  29. Dentist

    The entire idea sounds onerous and bureaucratic. I am not sure why the college seems to re invent the wheel rather than focus on what presently works. Peer review and life long learning happens all the time in clinical practice and through study clubs or courses and that seems to work quite well. This entire program sounds like a create work project. I think the college has bigger issues and this is not one of them

  30. Dentist

    My concern is with continuous practice hours. As a dentist with over 30 years experience with full time dentistry, retirement or partial retirement is in the near future. Part of my retirement plan is to provide volunteer dentistry to "have not" countries as a Dental Missionary for periods of up to one year. In order to obtain a temporary dental license for many of these underservised countries, a current license is required in my home country. It may be difficult to keep my license in BC if I do not obtain these 900hrs in a three year cycle since I may be away for a full year of this cycle. Will any credit be given towards my 900hrs of practice if these hours are obtained while working in another country? I realize, also, that we are being asked to give volunteer time to our home countries and communities as well. I have been doing this throughout my career by offering discounted or free treatment to those who cannot/will not pay for it. After more than three decades in providing treatment, a volunteer license to practice within our own communities should not be so difficult to obtain. Thanks

  31. Dentist

    Changing continuing education to 'Continuing Professional Development' is unnecessary as the new term does not encourage a greater ownership of one's professional development and it actually weakens the link to life-long learning. Continuing Education is succinct and sufficient whereas Continuing Professional Development is a vague bureaucratic term that is meaningless.

    Core and non-core activities:

    Practitioner health/wellness belongs in the core activities. What is more clinically relevant than a practitioner that is happy, healthy, well rested, and properly focussed? If taking care of oneself not a core activity then you are using a definition of core activity that I am unaware of.

    Situation Judgement Exercise (SJE):

    CDSBC should consider other sources for these exercises rather than enjoying a monopoly. I cannot imagine the amount of time, money, and effort that setting up SJE will require. I am not confident such an investment by the CDSBC will have the desired results in the behaviour of BC dentists. If the CDSBC has evidenced-based research that proves this not to be the case then I respectfully request the opportunity to review such research.

    Objective Feedback:

    Existing study clubs and dental societies achieve most, if not all, of the goals of this section. Current study clubs and dental societies are having trouble attracting young members and retaining older members. Both groups are attracted to the lure of free on-line CE. Rather than create an onerous new system of collaborative peer groups, that is alien to all of us, why not promote objective feedback in the Study Club/Dental Society framework? After all, is a ‘collaborative peer group’ only an awkward and inefficient way of saying study club or local dental society?

    How much time and attention will the CDSBC be directing to reading the ‘collaborative peer group forms’? Dentists are professionals, not technicians, and such Orwellian requirements appear to be downgrading our status from independent professionals to technicians required to fill out forms that our supervisors will scrutinise.

    Dentist-to-dentist office visit:

    This reminds me of a Soviet era joke: So long as the bosses pretend to pay us, we will pretend to work.

    I have grave concerns that actual office visits will not happen. The physicians of British Columbia have experience with this system and they overwhelming rate it as a farce. Although well intended, this activity will be fraught with fraud: dentists will only show their colleagues what they deem palatable, colleagues will not visit each other’s offices despite reporting differently, and only glowing reports will be submitted. Which professional wants to be responsible for giving negative feedback to the CDSBC about a colleague without giving that| colleague first a chance to improve any shortcomings? However, under this system the inspecting colleague would be obliged to report to the CDSBC first or fear reprisals. I cannot imagine an evidence-based study that shows such a system works well. As other dentists have stated in previous feedback statements attending conventions, study clubs, and local dental society meetings achieves the goals this draconian debacle is clumsily attempting.

    Audit & Record Retention:

    In order to receive CE credit we must submit to the CDSBC for approval. Is the CDSBC not checking submissions? I do not understand the need for a double check. In the first place the CDSBC should not award CE credit where credit is not due.

    In summary, I applaud the CDSBC in its efforts but the current guidelines require revision. These QA proposals will require the CDSBC to hire many more staff, spend an awful lot of time and money developing SJE’s, feedback templates, and the like for a poor return on investment. Also there is no proof that what the CDSBC develops will not be counter-productive despite the best intentions. If the invasive and bureaucratic elements of the proposals are pared-back the positive impact will not be lessened. I suggest the best way to best protect the public is to strengthen professional comradery with high quality CE courses, study clubs, and local dental societies. Forcing us to report on ourselves will force us to tell you want you want to hear.

  32. Dentist

    For dentists outside of Canada, who maintain the requirements to re-enter, the program should provide all courses online to fulfill the requirements. For an office visit- how can this be fulfilled if the office is not in BC or not in Canada?

  33. Dentist

    Overall my personal experience with the qa program we have now is great. I gain most of my ce through conventions and local lecture presentations by various speakers, where i also have to opportunity to chat dentistry with my peers during coffee break, after presentations etc . I find just talking to other dentists and cdas you can gain alot of knowledge and it is during the ce events that i get that chance. One thing i find though speaking to some of my dentist colleagues is that female dentists with young children ( and female cda's with young kids) find it hard to make time on weekends to find childcare to go to ce events; especially in small town BC where there is a lack of daycares etc. I also find it tough sometimes to get staff to join ce lectures etc due to their lack of time for good reason (kids , sporting events , etc). So overall i think there are many thing to consider for the qa program, but i thought i just drop a line to make note of the challenges of time commitments of dentist and staff who have young children; maybe the more ce options the better. Cheers

  34. Dentist

    I agree with the CPD cycle hours and the inclusion of credit to be given for volunteering.
    However I have concerns over the Situational Judgement Exercise; who is going to police this and decide if the registrant's response was correct or incorrect and what will be the consequences of giving the wrong answer?

    As to the Objective Feedback; I too think this is a 'daft' idea and not well thought out. like Dentist Oct 17th I too agree with the comments of Dentist Oct 15th who states the peer to peer review will just create animosity and wont help the public.
    Deal with problems as they arise as CDSBC does now,after all we already have a duty to report under the HPA.
    I agree that being a member of a study club is of value but if you are the only dentist in a remote town, joining one is often not a possibility. Also always attending say a study club devoted to crown and bridge the registrant can still have problems and be of concern to the public in other areas of dentistry ie. pediatrics.

    There was mention of corporate dentistry policing themselves with their own study clubs and peer reviews. I think this is a genuine concern.

    In conclusion, the current system to protect the public has served us well, there is no perfect answer to ensure a 'perfect dentist', there will always be 'bad apples'.

  35. Dentist

    I have a concern with continuous practice hours. I used to be an Ontario dentist; the RCDSO does not have a continuous practice requirement. If a dentist or certified dental assistant does not have enough education credits at the end of a three-year cycle, they can make up for the shortfall by enrolling in courses until the requirement is met. However, it seems like if a registrant falls below the minimum number of practice hours, there is no way for them to begin working (under any registration class) to acquire enough hours to regain full registration status.

  36. Dentist

    Ethics, Record keeping, Infection control, and SJE's all lend themselves very easily to an online learning format, which could be available to take by any practitioner at any time. The practitioner could choose to watch / listen to the course OR could attempt to challenge an exam. There are several advantages to this approach: 1. Ease of updating material as policies and best practices change...the CDSBC could update slides or segments of video very easily 2. Very cost effective for CDSBC to create and distribute . 3. Very cost effective and time effective for registrants. Many of us practice far from the lower mainland and travel to "in person" courses in each CE cycle will be expensive and time consuming. 4. Promotes easy access to re-take courses as a "refresher" at anytime . 5. Ensures consistency of what is presented to attendees . Please strongly consider creation of online modules to meet these requirements. Thank you.

  37. Certified Dental Assistant

    I agree with the proposed list of required competencies however, I have a question and/or comment regarding the courses particularly, for now, the CDSBC Recordkeeping course. First of all, the course is well designed and well formatted and a very good teaching/training tool. My concern is that do you think that it might be viewed as a conflict of interest that CDSBC will require the registrants to take this core competency, as per the Proposed QA, given that the registrants pay a fee to take the course to claim CE? And I think this will also be a concern for the other core competencies that the College will be developing as per the Proposed QA draft document. As per the CDSBC website," it is not a training institution and its core mandate is to protect the public by overseeing the conduct and competencies of its registrants"; providing the registrants CE opportunities is very good, however, will this be considered "training", especially that they are for fee?
    One other comment, more of an fyi, by January 2019, the CPR-HCP will be replaced by Basic Life Support (BLS) which includes CPR C, all skills of the HCP training plus few added knowledge and skills e.g opiods overdose. It is best to get more information regarding this from Canadian Red Cross.

  38. Dentist

    Completely agree with this comment:

    "I do have concerns/issues with the "Objective Feedback" portion. I see so many potential issues with the "Dentist to Dentist" office visits. At its best, I feel dentists will feel too timid to truly report/suggest what their thoughts are. At its worst, I feel overly empowered dentists might feel they are an agent "inspecting" on behalf of the College. It would be very difficult to find someone who is not too friendly or not too authoritarian. Most of us are conscientious and put a lot of effort in our practice. To me it's like asking parents to rate each others' kid behavior (in the open).....just a difficult subject to give true and open feedback

    I also wonder what happens if a "previously visited" dentist runs into problems with the college. Will the dentist that has visited the office be liable? If yes, I don't want that responsibility. If no, then to what end does this serve?

    I understand very well the role of the College is to protect the public. I am in favor of making clear to us dentists, what is expected of us. But I am also in favor of dealing with the individual problems as they appear rather than increasing bureaucracy to deal with the lowest common denominator."

  39. Certified Dental Assistant

    I think the Peer to Peer program would be of benefit but not in the way proposed currently. If new graduates with less than 5 years experience were paired with dentists with over 10 years to discuss the running of a practice, treatment of difficult cases and other matters this would better support younger dentists coming into the profession and provide the opportunity for mentorship without competition.

  40. Certified Dental Assistant

    As a stay at home mom to 2 children born 20 months apart (one with special needs that makes it difficult to obtain child care) I feel like the continuous practice hours are almost impossible for me to obtain as the only day my husband isn’t working is on Saturday and I live in a city that has absolutely no dentists who are open on Saturdays. So in order to get my CPHs I would need to travel 45min -1 hr away. Every Saturday. I feel like it is discriminatory to require them due to the limited number of hours that dentists are open. Nurses have 24 hrs a day 7 days a week that they can work which makes it easier for them to obtain.

  41. Certified Dental Assistant

    I do not see a great value in the dentist peer program.
    It would take up time that could be better used by these professionals and waste production time. After 27 years as a CDA I believe that
    Dr.s can get advice from peers easily enough without supervision from the cdsbc. Respectfully drafted.

  42. Dentist

    What about dentists that fly in and out from out of province or small towns?? how will they find the time and resources to participate in objective feed back??
    This is not practical...

  43. Dentist

    I agree that active learning in a study club environment provides more opportunity for meaningful improvement in one’s knowledge and skills. As for the comment about ‘knife and forkers’ who attend study club without full involvement, there will be those that sleep through lectures as well. The 1.5 units for participatory learning is a great idea.
    As for the Objective Feedback requirement, I urge the committee to include active study club participation to fulfill this requirement. In my experience study clubs mentors have provided much objective feedback. Ad do other study club members. Much more than the two scenarios suggested.

  44. Dentist

    My question is how does one choose or organize a Collaborative peer groups or Dentist-to-Dentist office visit? If it is volunteer members that choose to take on this task, then, would we be forced to cooperate with these members and allow them into our practice? My concern is that if these 'collaborative dentists' may be a local competitor and allowing them in your office would open up some 'trade secrets' for their benefit.

    Would any of these peers be a specialist? If so, they have a vested interest to judge your qualifications as a general practitioner to perform their area of expertise. For example, some specialists may feel a GP have no business providing Orthodontics in their practice.

    As Corporate Dentistry continue to grow, will they form their own peer group? Not to say that their evaluations may not be genuine, but Corps policing themselves presents a conflict of interest.

  45. Dentist

    It is difficult to attract New CDA s to this profession. This won't help!!

  46. Dentist

    I'll start by saying I appreciate the effort and thought that those involved in the college have done to produce such a proposal.

    I encourage the higher CE points awarded to study club education. I have had good experiences in the study club format and I am one to see the value.

    I do have concerns/issues with the "Objective Feedback" portion. I see so many potential issues with the "Dentist to Dentist" office visits. At its best, I feel dentists will feel too timid to truly report/suggest what their thoughts are. At its worst, I feel overly empowered dentists might feel they are an agent "inspecting" on behalf of the College. It would be very difficult to find someone who is not too friendly or not too authoritarian. Most of us are conscientious and put a lot of effort in our practice. To me it's like asking parents to rate each others' kid behavior (in the open).....just a difficult subject to give true and open feedback

    I also wonder what happens if a "previously visited" dentist runs into problems with the college. Will the dentist that has visited the office be liable? If yes, I don't want that responsibility. If no, then to what end does this serve?

    I understand very well the role of the College is to protect the public. I am in favor of making clear to us dentists, what is expected of us. But I am also in favor of dealing with the individual problems as they appear rather than increasing bureaucracy to deal with the lowest common denominator.

    • Dentist

      As others have mentioned, these are pretty sweeping changes. I would like to see the scope of the problem that these changes seek to address. Are BC dentists generally so bad that we need broad changes like this, or is it a problem of having to find a few bad apples in the barrel. The solution should be aimed at the problem. I feel these changes will cause a lot of cost and disruption to the average dentist with very little in terms of benefit to the public. In fact I would suggest that the increase in costs to patients will far outstrip any benefit they will see in terms of improved outcomes. This looks a lot like regulation for the sake of regulation.

      I have specific concerns with regards to the peer to peer evaluation process. I think this will be unworkable from the outset. What liability will the evaluating dentist have? How does this work at all in rural BC? Shouldn't the evaluating dentist have some training in how to evaluate, and what they are looking for? Who pays for the bureaucracy necessary to make it function? Ultimately, there will be a cost to patients and dentists alike, but for what gain?

      Thank you for listening

    • Dentist

      Nail on the head! I agree 100%

  47. Dentist

    Please Lets not get sucked into believing this will help the Public. This will create animosity amongst the colleagues and ends up serving no one. We do not need to be policed like jail birds. We are professionals and have carried ourselves well for the past 50 years

  48. Dentist

    I do not agree with required competency . why is the dentist required to repeat the same exam every two cycle??? I think that is way too many repetitions..
    Also, I do not agree with office checks... it is going to waste so many people's time and it will be very uncomfortable including our patients

  49. Dentist

    I would like to see an outline of the template being considered for in person office visits by dentists. This proposal makes me uncomfortable and I would like to know that dentists are not being expected to conform to a cookie cutter pattern that will discourage individual style. Dentists who have developed ways of improving patient experience may not be happy having other dentists learn what sets them apart from the competition. This means that dentists must find other dentists outside of their small communities to check their practice.

    How will office checks work as corporately owned practices begin to dominate within communities. Will they be policing themselves? Will they be ethical in evaluating non-corporate members? They currently offer their own CE to their employed/contracted dentists. Will these corporations, such as dental Corp start to direct the standard for these practice evaluations once they begin to gain a monopoly. They are already gaining a presence in schools. What safeguards are in place to prevent them from influencing the college and the university education and qualification process?

    As far as study clubs, I hope that these will not start to be a requirement instead of a suggestion. Some of us don’t have the time to attend study clubs regularly and when we can, may not be able to find a club with space available. In our community you have to be invited to join. If you are a quiet person, or have a family to see after work you may not socialize with enough dentists to garner an invite.

  50. Dentist

    I see no problems with the proposed changes to the Quality Assurance program. My only objection is to the proposed "Objective feedback" requirement. I see much value in being a member of a study club and discussing clinical cases with peers. However the proposed format for "Objective feedback" in my opinion is not valuable to members and frankly will be a waste of time. If members are required to take clinical records for a case each cycle to a meeting of peers and present it, the most likely scenario will be that members will show off their most successful case and fellow members will learn very little from the process. In my experience valuable learning comes from sharing clinical failures and if we are required to present cases to a room of strangers, most of us will not feel safe to share our failures in such an environment. The alternative proposal of hosting a fellow dentist at our office or doing a video chat is just as useless as it will just be a social gathering of fellow dentists. Going out for a coffee or a drink with a fellow dentist across the street from our office would probably fulfill the requirement of "objective feedback" and apart from fellowship I really do not see any value in such actions. If the College really wants "objective feedback" as part of the Quality Assurance Program, a website could be set up with the requirement that each member share a difficult/complicated clinical case each cycle with all other members with an outline of chief complaint/objective findings/diagnosis/treatment plan and allow fellow members to provide feedback and assistance with such cases. This would be valuable to both the presenting members and all members in general as everyone will have an opportunity to review the case, review the advice and provide feedback if they want to. This process is already happening on social media sites dedicated to dentists/dental professionals. The CDSBC can show leadership in implementing such a site in a more structured and at a more formal organizational level.

  51. Dentist

    Problem with quality service has not much to do with luck of training.
    With corporation of dental offices, speed, production,billings is the main concern in many offices.The college missed the chance to assure the public with properly trained professionals when did nothing to stop this tendency.Dentistry is not a profession in many offices, but simply busyness, aimed for production and profit,

  52. Former Registrant

    I am impressed with the WG that provided the QAP. This document is comprehensive & detailed.
    I agree with several of the submissions/postings of the Consultation Forum, that questions the issue of whether this was well researched & evidence based. Could the CDSBC provide their Registrants with the published evidence/research that shows why a Registrant is not competent without 300 clinical hours/year or 90 hours of continuing education in a 3 year cycle?
    I was encouraged by the addition of ‘peer-to-peer’ interaction but agree with some posts/comments that question the CDSBC’s ability to direct & scrutinize this activity.
    I’m very pleased that the recommendations include local or international volunteer opportunities. I have participated in a host of local volunteer ‘clinics’, as well as 2 trips internationally. Firstly, it legitimizes the Registrant’s cost with Revenue Canada but also gives Registrants the opportunity to experience situations not normally seen in they own practice. Encouraging Registrants to ‘give back’ is a positive move forward. A ‘Win/Win’ for donors & recipients.
    I’m very concerned with the CDSBC’s liberal but inappropriate use of the term ‘Standards of Practice’.
    CDSBC's Standards of Practice broadly describe the responsibilities of practitioners in providing dental care to the public in B.C. These standards are an important foundation of continuing competence. Practitioners are encouraged to use these guiding principles when planning their continuing education activities.
    Although, the majority of the present CDSBC Complaints officers have attended a presentation by the past-Chair of the Canadian Endodontic Academy, enlightening them on the true definition & difference between Standards of Practice & Standards of Care, the CDSBC’s staff continue to utilize their own individual Standards of Care. The most important reason is because the CAE is the only discipline in our profession that has documented Standards of Practice. Sadly, those personal/individual Standards of Care can be infelicitous, with resulting poor outcomes.
    The perfect example is the posting made by a dentist on Sept. 22, 2018 @ 03:55pm. I am extremely disappointed by author’s comments. I felt their statements were fear-based & selectively factual. “The leader of this course has had his license removed in UK”. Actually, the dentist he is referring to had their license suspended for 6 months in 2016. It should also be noted that the same dentist received a special award from the same body in 1999.
    The author’s comment was not entirely true. I wonder why he didn’t provide all the facts?
    The author’s comment about have only specialist teach/mentor CPD to GP dentists/CDSBC Registrants is highly reminiscent of being ‘self-serving’ & a ‘turf-war’. I’m not sure this is about Protection of the Public, as he possibly is leading the reader to believe, but about ‘protection of their income’.
    The author’s statement…the DDS/DMD often lacks that ability, is especially offensive. To infer that only certified specialists have the ability to better able to dissect out the evidence, is a ridiculous statement that is not evidence based or true. It appears to be ‘narrow-minded’ & condescending.
    I have participated in the dental profession for over 50 years, 36 of those years as a licensed CDSBC Registrant. I’m intimately familiar with ‘turf-wars’. I grew up with a certified specialist. I can assure you that various forms of ‘turf-wars’ started shortly after the credentialing of certified specialists in the mid-1900s.
    I strongly suspect that the author is, in fact, an orthodontist.
    I’m not sure if he realizes that it’s 2018 & the world is moving on. Change is inevitable & I’m getting the impression that the author is staunchly ‘Status Quo’ & possibly believes, as a certified specialist, is the only qualified ‘gate-keeper’ of information dissemination.
    I feel sad he infers to the reader that only certified specialist can help protect the Public.
    Is it, in fact, in the Public’s best interest to dismiss ‘differing’ opinions? The author’s statement There is no scientific evidence in refereed journals to support this concept., again is not entirely true. Likely, the author was not able to find published articles because they are, in fact, out there. I wonder why? Is he aware that this modality of orthodontics is being taught in a credentialed dental faculty in Spain?
    Sadly, the author’s opinions are not only theirs. After perusing numerous CDSBC Orthodontist’s websites, other specialists infer that there are “benefit from seeing an orthodontic specialist instead of a general dentist.” This includes a certified specialist that derives an income for providing reports for CDSBC.
    Thankfully, Medical/Dental treatment is in constant flux.
    I can only pray that this author is not participating, in any fashion, with CDSBC. This type of attitude is an example of why, I suspect, the Ministry of Health has had to step in @ CDSBC. This is truly unprecedented & the disturbing ‘Elephant in the Room’.

  53. Dentist

    Overall I like this outline for continuing education points. I support the general direction

  54. Dentist

    The volunteer category should also include providing
    treatment in non profit clinics, educational institutes,
    long term care, this should be a broad group to help access to care

  55. Dentist

    In theory, I believe the Objective Assessments/Feedback is a good idea. However, in reality, the infrastructure required to support this will be expensive and time consuming. Who will be performing these "objective assessments"? If it is practicing dentists, how will they be compensated for production time? If it is designated dentists from the College, who will be paying their salaries? Who gets appointed to this position? Yes, similar assessments have be put in place in the medical system, but it is the government that pays for this time.

  56. Dentist

    This is my second comment. It pertains to one of the competencies: the communication activity. Who is going to be reviewing the process? You will present a case scenario and analyze the dentist's response. This is highly subjective. After 37 years of successful practice and no patient complaints I think I know how to communicate effectively wit my patients. i.e. listen carefully and thoroughly explain all options. The other issue with this is the bureaucracy of managing this.. I am guessing that there are about 3000 registered dentists. This means that on a three year cycle the College is going to have to review 1000 of these annually, many more if CDA's are included. How are you going to efficiently quarterback this and is the outcome going to be worth the time investment. I think that this has not been well thought out.

  57. Dentist

    Last week I asked every patient how they would feel about having another dentist from another practice observing the office and the reason why...not one of them responded positively...a few were neutral to the idea and most were strongly opposed to it. I

    • Member of the Public

      My daughter is a Associate Dentist in a BC practice and being a associate there is limited access to productive cases. She is given schedule to baby sit the unproductive late hours in the hope to grow the practice and buy her own handpieces and endo instruments even though there is no partnership clause in her contract, how will such new associates cope up with added case requirements. Mind you this is not a corporate practice but a solo practice. The owners of the practice warns the front desk not to book her with crowns and bridges cases and if she requests to shadow a procedure that principal dentist is doing, she is told that the Principal feels uncomfortable being watched on a procedure. If dentists in the same practice are not allowed to even observe a procedure, I doubt office to office visits will be welcomed with enthusiasm. With GP practices becoming more and more narrowed and insecure about referring out, within the same GP practice inviting other GP's with advanced training in specialized procedures ex. wisdom teeth extractions or endo procedures, leaves little scope of overall general practice for new graduates except simple fillings and attending minor emergencies. This in return, is not a healthy psychosocial environment for the new dentists who are under constant threat of loosing their work to another new dentist if their skills don't improve. With more denturists in town, even to get a decent experience in removable dentures is not possible. Such a competitive, egoistic, insecure environment is a disappointing experience for new graduates who are excited about professional growth and also have significant loans to pay off. At the same time, if Associate has not had a full scope of practice it will be difficult for them to fulfill new CE requirements even if they graduated with Gold medals. The Open CE requirement of 90hrs every 3 years, is also a bit of a concern, considering if someone fulfilled the 90hrs in first year and they decide not to take anymore CE in the subsequent 2 years, it doesn't balance the continuity of education in 3 years, so it should be divided in 30hrs for each year and not being cumulative unless someone is out of country on a mission for a year or so. Another major disappointing situation is of not hiring CDA's and having more chair side assistants in order to save overhead cost. I hope any new change truly helps both the public and providers mutually.

    • Organization

      CLARIFICATION FROM CDSBC: Please note that the objective feedback component of the proposed quality assurance program does not include observations of direct patient care. The dentist-to-dentist office visits would involve discussions of each other’s practice and procedures. We may not have communicated this as clearly as we could have and we’ll update our material to reflect this.

  58. Certified Dental Assistant

    I have been practicing for well over 30 years.
    I went through my continuing education and I have taken all the courses more than once.
    However in the last 10 years I have not had a raise in pay.
    CDA's are leaving Dentistry faster than they are coming in. Other jobs are available at higher pay, benefits and no requirement to pay for continuing education.
    Hopefully the College will offer these courses free of charge or we will have more people leaving Dentistry.

  59. Dentist

    - I support the addition of mandatory courses/modules and also agree that CPR should be added as mandatory in each cycle (annually, even).
    - It is challenging for individuals in many situations to add on a collaborative component due to time or location constraints and I urge CDSBC to rethink the notion of "objective assessments" as truly 'objective' or of value to the public, unless there is a reason suggesting otherwise (e.g. as part of a complaint resolution). The vast majority of practitioners in BC are competent professionals who should have the say in whether they wish to review their work in a collaborative format, not the CDSBC.
    -Likewise, I have concerns about validating the "Objective Assessment" requirements, especially if the CDSBC is concerned already about validating our existing 90-hour CE requirements, which has been described as 'onerous' ..are more staff to be hired for this? Will this impact our licensing fees? Many things to think about in this regard.
    Appreciate the call for feedback in any case.

  60. Dentist

    I think the logistics of this will be a nightmare. Given the sheer number of dentists in the province, coordinating peer review office visits is totally unrealistic. And as dentists, we are to take away production time in our own office to go visit another office?! Who will cover the cost of doing this- the college? The dentists? Think this may need much more feedback from the members

  61. Dentist

    After reviewing this program proposal as a dentist and business owner I believe that it is to onerous on an already taxing schedule. We do not need more regulation in this area and I cannot emphasize how detrimental further regulation and reporting requirements will negatively impact clinicians like myself. This is a recipe for increased burnout, worsen patient care and frustrated clinicians. This proposal is regulation for the sake or regulation and pays lip-service to the ever increasing drive towards more bureaucracy and control of the many by the few.

  62. Dentist

    This is a move in the right direction. One major concern is the need for greater overview of accredited courses. If CDSBC gives credit, then the course that is given should be based on evidence that is scientifically valid. An example of lack of evidence is Orthotropics.
    There is no scientific evidence in refereed journals to support this concept. Therefore the unsuspecting DDS or DMD takes the course, at expense and under the College's approval (because it gives CE hours) and the technique presented is not scientifically valid. The result is often that the patient's needs are ill served.The leader of this course has had his license removed in UK. Why are we validating this approach by allowing CE credits? Often the Dental specialist is better able to dissect out the evidence, because of their advanced training with a Masters Degree, whereas the DDS/DMD often lacks that ability. Furthermore when the DDS/DMD takes a course on specialty material by a DMD/DDS rather than by a specialist, and that course leader recommends treatment that is not evidence based, then the patient's needs are similarly ill served. A critical look at the course objectives, the course content and the post course evaluation are required to stop what some might call Charlatans who give certain courses, all given approval for CE credit by our College-the public's interest are not well served by some of these courses.
    Critical assessment of course material is in need of closer attention.

  63. Certified Dental Assistant

    As a Licensed and Certified Dental assistant I am in full support of the proposed changes to the Quality Assurance Program. All health professionals in BC should be involved in mandatory continuing professional development and life-long learning. Ensuring that required competencies are completed is a cornerstone of public safety. The current QA program is aligned with the College’s strategic plan goals in that: it aims to be fair and transparent; it improves professionalism and practice standards; it promotes professional collaboration; and is committed to organizational excellence demonstrated by its pursuit of continuous improvement for both the registrants and the program. If the College’s goal is to improve professionalism and practice standards, I am baffled as to why unlicensed Dental Assistant practice is allowed to continue in this Province. An unlicensed assistant is held to none of the above mandates.

    • Dentist

      re: 1.5 for hands on. In many of the study clubs I have been involved in several members are what service clubs call knife and forkers. They attend but they do not bring patients. therefore they do not have an enhanced learning experience. As well re: research on minimum practise requirements. When i checked 2 years ago no other college in canada had this requirement. What is this research? As to minimum practice requirements for CDA's I think it is unnecessary. Our paternalistic approach to delegation of duties allows a minimal numbe of procedures to be done by CDA's. After an absence for childrearing I think the skills can be brought up to date under the supervision of the dentist they are employed by. The physicians in BC are far less paternalistic. They are able to delegate duties and train staff under their licenses. e.g having an RN do filler injections. Our college has always catered to the lowest common denominator assuming that dentist are incapable of ethically training staff to perform duties. The current situation has resulted in the loss of CDA's avaialbe to the profession. As to the peer to peer process I think that is unnecessary and bureacratically cumbersome: great for growing the staff population at the college. As to the comment by CDA about not understanding why an office can employ a non CDA as an assitant. If they are not doing CDA duties dentists are quite capable of teaching the assistants how to capably assist without harming the patient. With a few briliant exceptions the CDA's I have received out of school have required considerable tutelage before their skills were up to par.

  64. Dentist

    It is worth noting that the majority of the references seem to come from a small group of researchers. Having said that, I like the look of the program and believe it is worthwhile. I would ask that some thought be given to the rural / urban divide (I expect that it has already!). As a practitioner whose experience includes working as the only dentist in a small community, some aspects of the program might be more difficult and certainly more costly for practitioners in similar small community situations to attain and complete. Thanks for allowing feedback prior to implementation.

  65. Dentist

    Would be nice to have a little more info on what ideas are being thought of when talking about Quality Assurance. Are we talking about increasing the amount of CE, is testing of skills an option being talked about? If testing is going to be done whom will over see it and whom will pay for it. What would be the passing grade? If failure happens what happens to licence? I do not believe the medical profession does this to their members. Just thoughts.

  66. Dentist

    I am transitioning to retirement and do not know in what category I will need to register once I stop treating patients. I will be doing dental forensic identification. I do not know if I will need a license in order to do this, and whether any of the proposed changes will affect me.

  67. Dentist

    My goodness, where to start with this proposed program? I think there are serious fundamental problems throughout and BC dentists need challenge a very sweeping (and potentially expensive both with regards to time and money) change to how they practice; where is the evidence that this will really make the world a better place?
    Speaking to some specifics:
    1. Use of the phrase, “Evidence shows...” and the like. What evidence? Yes, you have some kind of bibliography attached at the end, but there are no numbered references and citations. If you’re going to cite “evidence”, then make the direct connection to the specific citation so that your colleagues and assess this “evidence” for themselves. Otherwise it’s poor form to make these statements without backing them up. A refereed journal would toss out this submission, and I think that’s the standard you need to adhere to if you’re going to expect your membership to accept something as huge as this proposal.
    2. “The current hour requirement is not onerous and can be met by practising one hour a week.” There are fundamental problems here. Yes, if you worked a day a week for 42 weeks you could get the 300 hours/yr required. But one problem is - can you get the opportunity to practice only 1 day/week? You can’t do that in a solo practice - there is a reality called overhead. The vast majority of staff don’t want to work 1 day/week - the NEED the income. You can’t pay rent for 1 day/week. The list goes on. These kind of opportunities are by their nature very limited. In addition, I mentioned “evidence” before; where is the evidence that 300 hrs/year = competency? The requirement of “Evidence” cuts both ways, CDSBC. I suspect many of our colleagues could provide competent care with a third or fewer of those clocked hours. The essence of a great dentist is not just manual dexterity and constant repetition - it’s the knowledge and experience accumulated over decades of practice. This requirement would presume that you lose that knowledge and experience very quickly. Do you really think this is true?

    I hope the dentists of BC have the gumption to challenge their regulators regarding first the need for these sweeping changes in the first place, and look long at hard at each of these line items for their validity.

  68. Dentist

    I have practiced in this province for 25 years. The CE requirements in my opinion has always served the profession well. These new guidelines are added regulation for the sake of regulation. I'm sure that the liberal minded out there agree with them but I do not. If someone can point to an increase in danger to the public over the last 10 years as a result of lack of regulation of this type I would gladly reconsider my viewpoint, but I don't think it exists. Forcing this down the throats of our membership is unwarranted and unnecessary.