FAQs – Revised Scope of practice registration standard

The revised standard applies to all registered dental practitioners (dentists, dental hygienists, dental prosthetists, dental therapists, oral health therapists), except those with student or non-practising registration. The key change is the removal of the regulatory requirement for dental hygienists, dental therapists and oral health therapists to practise within a structured professional relationship with a dentist. We have also removed the term ‘independent practitioner’ from the standard. This recognises that dental practitioners, across all divisions of dentistry, are responsible for their decisions, treatment and the advice they provide.

All dental practitioners are members of the healthcare team and are expected to work with other members of that team to provide the best possible care and outcomes for their patients. That may mean referral, delegation or handover to the member of the team who is best placed to manage a patient’s care.

Dental practitioners must only perform treatment for which they have been educated and trained and in which they are competent. The Board expects all dental practitioners to practise within their own individual scope of practice of their dental practitioner division and the definition of dentistry. The definition of dentistry can be found in the new Guidelines for scope of practice.

The division a dental practitioner is registered in and the definition of dentistry broadly describes the range of practice that a practitioner can carry out. Dentists may practice any activities within the definition of dentistry. However, the other divisions (dental hygienists, dental prosthetists, dental therapists, oral health therapists) have a narrower range of practice. 

An individual’s scope of practice depends not only on their division but also on education, training and competence. A practitioner’s own scope of practice may vary from other practitioner’s in the same division. It may be more limited than the division’s overall scope. To make sure that a practitioner is working within their scope of practice, they must only perform dental treatments that they have been educated and trained in, and that they are competent in.

The Board’s new Guidelines for scope of practice provide further advice and guidance on the scope of practice for each of the divisions of the Register of Dental Practitioners.

The Board’s Code of conduct sets the standards for the professional conduct of all dental practitioners. The Board held the view that there was a need for the Scope of practice registration standard to reflect the contemporary status and regulatory requirements of the profession. This in no way diminishes the responsibility for all members of the dental team to provide the best possible care and outcomes for their patients. The revised standard highlights that each member of the team has a role to play and they are each responsible for the care provided and decisions they make.

Changing the standard also continues the Board’s incremental approach to moving away from prescriptive requirements for scope. The revised standard and Guidelines for scope of practice, together with the Code of conduct, are part of the Board’s regulatory framework. Because these documents apply to all dental practitioners across a range of clinical settings to meet the needs of patients, they don’t refer to specific areas of practice.

Yes. A dental practitioner may prefer to have formal arrangements in place with other members of the dental team to be clear on how they will manage and care for patients. Workplace arrangements may also describe the expected scope of dental practitioners in these settings, which may vary from workplace to workplace. 

While the Board is removing the regulatory requirement for a structured professional relationship, all practitioners are expected to continue to have professional relationships within the healthcare team. By referral, delegation and handover of care of a patient to another practitioner for assessment and management, in accordance with the principles of the Code of conduct, a professional relationship is established. Professional relationships underpin good patient care.

Members of the dental team are unlikely to see much change at all. The Board will not be requiring more of dental practitioners than it does currently. The Board is simply removing the regulatory obligation to have a structured professional relationship. The professional working relationship between a dentist, other members of the dental and healthcare team and dental specialists will not need to change.

The individual scope of dental hygienists, dental therapists and oral health therapists did not change on 1 July 2020. They must continue to only perform treatment for which they have been educated and trained and in which they are competent. The only change is the removal of the regulatory requirement to have a structured professional relationship in place.

It’s important to remember that while some practitioners may be performing procedures as directed by, for example, the treating dentist or an orthodontist, they are not qualified or sufficiently experienced or competent to provide those treatments independently.

Under the revised standard, dental practitioners must not direct any person, whether a registered dental practitioner or not, to carry out dental treatment or give advice outside that person’s education and competence.

Continuing professional development is the means by which all dental practitioners maintain, improve and broaden their knowledge, expertise and competence, and develop the personal and professional qualities required throughout their professional lives.

A dental practitioner cannot move from one division to another through continuing professional development (CPD). However, divisions set the broadest limits of scope of practice and within that division of registration, an individual’s scope of practice may differ from others in the same division of registration. So, an individual’s scope of practice could change through CPD, but not beyond their division. It will depend on their education, training and competence and this applies to all divisions of the Register of Dental Practitioners.

CPD is important to maintain and improve a practitioner’s skills and experience and to broaden their scope of practice within the division they are registered. 

A practitioner can broaden their practice within their division on the register. 

CPD cannot change their scope into that of another division. Dental hygienists, dental prosthetists, dental therapists and oral health therapists cannot become dentists by completing CPD courses.

Practitioners need to:

• keep their knowledge and skills up to date
• work within their scope of practice, and 
• evolve their practice within their division on the register.

CPD, such as a course about a new technique or procedure, will help maintain, improve and broaden a practitioner’s expertise, experience and competence and develop the personal and professional qualities needed throughout an individual’s career. 

The Board expects practitioners to choose CPD based on their division’s scope of practice and understand its limits. 

Previously in some jurisdictions, dental hygienists, dental therapists, oral health therapists and dental prosthetists could do programs that were approved by the Board to extend scope of practice. These practitioners may have needed to complete such a program when foundation knowledge was required beyond the scope of the qualification that lead to registration.

Board approval of such ‘add-on’ programs expired in December 2018. The Board only approves programs of study accredited by the Australian Dental Council that lead to registration or endorsement. 

Dental practitioners are encouraged to reflect on their own practice and identify areas where they can gain benefit from continuing professional development (CPD) activities to broaden their knowledge, skill and competence. This means that practitioners should choose their CPD wisely and must self-assess whether the selected CPD activities or courses provide sufficient training, particularly for more invasive procedures, to incorporate a new procedure, technique or treatment as part of their clinical practice.

The Guidelines on continuing professional development provide direction on the characteristics practitioners should consider when choosing their CPD activities.

The Board is doing work around strengthening continuing professional development (CPD) which includes developing tools for practitioners to reflect on their knowledge and skills and how they may plan their CPD to ensure they are contemporary, and evidence based in their practice. 

The Board has developed the reflective practice tool to support and help dental practitioners to reflect on their own knowledge, skills and abilities. The tool also supports dental practitioners to engage in team-based discussions about competent practice for good patient care and can be used by practitioners to help plan their CPD .

The Board is neither the authority for the issuing of Medicare provider numbers nor for the recognition of health professionals or their related services by private health insurers.

Following the changes to the Scope of practice registration standard on 1 July 2020, from 1 July 2022, dental hygienists, dental therapists, and oral health therapists can access Medicare provider numbers to directly claim for services under the Child Dental Benefits Schedule (CDBS).

This is an opt-in arrangement, which means that previous claiming arrangements can remain in place i.e., a dentist can continue to claim for CDBS services rendered by dental hygienists, dental therapists and oral health therapists.

More information about the change to Medicare provider numbers is available at the Department of Health website.

From 1 July 2022, all dental practitioners are eligible to apply for a Medicare provider number.

Where a dental practitioner does not hold a provider number, the usual arrangement, by both Medicare and private health insurers, is to accept the use of a dentist's provider number for work done by that dental practitioner. 

That arrangement remains subject to the business rules of:

• Medicare
• private health insurers, and
• the workplace. 

Private health insurers may enter into billing arrangements with health practitioners who do not hold Medicare provider numbers. Private health insurers will have their own rules and requirements to address the changes to provider numbers that come into effect on 1 July 2022.

Before 1 July 2020 when the Board’s revised standard came into effect, the regulatory requirement for a structured professional relationship might have been used by a dentist to allow the use of their provider number by other members of the dental team. This was not its purpose.

The regulatory requirement for a structured professional relationship, which no longer applies, recognised the framework for referral and management to dentists by other members of the dental team when the care required fell outside of the scope of practice of other dental practitioners. It also recognised that a dentist may need to refer patients to other members of the dental team.

There is nothing in the revised standard to stop a practitioner from continuing the business practice of controlling the use of their provider number. It is ultimately up to Medicare and health insurers to determine if a dental practitioner who has a Medicare provider number can allow it to be used by another dental practitioner. 

However, if the structured professional relationship was used as a de-facto protocol to enable this practice, then, if a dental practice chooses not to continue with a structured professional relationship as a formal workplace arrangement, alternative protocols or business rules may still be needed to allow these practices to continue. 

This will also apply to any dental practitioner new to the workplace who does not hold a provider number. But again, that arrangement remains subject to the business rules of:

• Medicare
• private health insurers, and
• the workplace.

This is a matter to be worked through by each dental practice and is not one for which the Board has any regulatory oversight.

A practitioner must not carry out any dental treatment or give advice that is outside their education, training or competence. If patient examination, treatment planning and diagnosis is within a practitioner’s scope of practice, there is no regulatory requirement in the scope of practice standard for a dentist to be present. However, a workplace may have protocols and formal workplace arrangements requiring that a dentist is present. This is for a workplace to decide and is not regulated by the Board. 

If a practitioner’s treatment planning and diagnosis identifies care is needed that is outside of their scope of practice, then they must refer the patient to another practitioner with the necessary skills and knowledge to care for the patient.

All dental practitioners must refer a patient when the requirements of care are outside their own scope of practice. This means, from a regulatory perspective, an oral health therapist can refer patients to an orthodontist. However, a practice may have protocols and formal workplace arrangements that require a dentist examines a patient and refers them to an orthodontist. Such arrangements are not a regulatory matter for the Board.

The qualifications of health practitioners have changed over time and as a result they have different names. What is relevant is that at the time the individual registered as a dental practitioner, their qualification was accepted as a pathway to registration – what is now called an approved qualification for registration. A dental hygienist and an oral health therapist have different scopes of practice and neither scope refers to the capacity to work alone. 

What is important is that all dental practitioners are members of the healthcare team and must work together to provide the best possible care and outcomes for their patients. Whether a practitioner works alone and ensures this best possible care is managed by referral to other practitioners outside of the practice, or whether they work in a larger practice with practitioners in other divisions within the practice and refer internally, is workplace function and not a matter for the Board. Practitioners must only perform dental treatment for which they have been trained and educated and in which they are competent.

This will depend on the practitioner’s foundation training, that is the training that lead to their qualification, or pathway, to registration. If that training included the treatment of adult patients for a particular procedure, then the practitioner may be able to do continuing professional development (CPD) to broaden the scope of their management of adult patients. If the therapist has only been trained, on any procedure, to treat patients up to the age of 18, it is unlikely they could achieve the knowledge, skills and competence to treat patients of any age through CPD. The Board expects practitioners to practise within the limits of their knowledge, skills and competence and to refer a patient’s care to a more appropriate practitioner when needed.  Doing CPD may only expand your scope within the division of your registration and does not enable you to practise in another division.

No. The Board’s Professional indemnity insurance registration standard details the Board’s requirements which remain the same.