Adams School of Dentistry: Policy on Extramural Clinical Activities

The purpose of this Policy is to set forth the requirements for extramural clinical activities occurring outside the Adams School of Dentistry. These activities include but are not limited to: rotations, volunteer clinics, private practice, externships, and international trips sponsored by student organizations.

Title

Adams School of Dentistry: Policy on Extramural Clinical Activities

Unit Policy

I. Introduction

A. Purpose

The purpose of this policy is to set forth the requirements for extramural clinical activities occurring outside the Adams School of Dentistry. These activities include but are not limited to:

• rotations,
• volunteer clinics,
• private practice,
• externships, and
• international trips sponsored by Student organizations.

B. Scope of Applicability

This policy applies to all Students and Residents at the Adams School of Dentistry.

II. Definitions

1. Direct Supervision: the attending faculty member:
   1. must be present in the same facility or location;
   2. must be available during the performance of the acts that are being performed pursuant to the attending's order, control, and approval; and
   3. must personally examine and evaluate the results of such acts.
2. Extramural Site: any location that is not owned and operated by the University of North Carolina at Chapel Hill ("University"). This term includes the term "extension facilities" as referred to in the North Carolina Administrative Code ("NCAC"). For purposes of this Policy, UNC Medical Center is considered an extramural site.

III. Policy

A. Policy Statement

All Students and Residents must be appropriately supervised at extramural sites in accordance with North Carolina law and Commission on Dental Accreditation ("CODA") requirements. Failure to abide by this Policy may subject the Student or Resident to criminal penalties under the North Carolina Dental Practice Act for the unauthorized practice of dentistry.

1. DDS Students

Except as provided in the "Exceptions" section below, Doctor of Dental Surgery ("DDS") Students are not permitted to practice dentistry outside of the Adams School of Dentistry unless:

1. they are practicing under the direct supervision of a duly licensed dentist acting as an instructor:
   1. at least one dentist must be appointed as adjunct faculty to the University to serve as preceptor for the Student
   2. any other dentists acting as instructors at the site must be approved by the Dean prior to the activity;
2. the North Carolina State Board of Dental Examiners (the "Board") has been notified of the extramural site in accordance with 21 NCAC 16K .0106; and
3. a written agreement has been executed between the Adams School of Dentistry and the extramural site.

The Executive Vice Dean for Education (or designee) is responsible for maintaining a list of all extramural sites where DDS Students are authorized to practice, including:

1. rotation sites, and
2. Student-led volunteer clinics.

Under no circumstances may a DDS Student receive fees, compensation, or other remuneration of any kind for dental services rendered.

2. Dental Hygiene Students

a. Undergraduate

Except as provided in the "Exceptions" section below, Dental Hygiene Students are not permitted to practice dental hygiene outside of the Adams School of Dentistry unless:

1. they are practicing under the direct supervision of a duly licensed dental hygienist (or dentist) acting as an instructor:
   1. at least one dental hygienist (or dentist) must be appointed as adjunct faculty to the University to serve as preceptor for the Student;
   2. any other dental hygienists (or dentists) acting as instructors at the site must be approved by the Dean prior to the activity;
2. the extramural site has been approved by the Board in accordance with 21 NCAC 16G .0106; and
3. a written agreement has been executed between the Adams School of Dentistry and the extramural site.

The Dental Hygiene Program Director (or designee) is responsible for maintaining a list of all extramural sites where Dental Hygiene Students are authorized to practice, including:

1. rotation sites; and
2. Student-led volunteer clinics, in coordination with the Vice Dean for Education (or designee) for any shared sites.

Under no circumstances may a Dental Hygiene Student receive fees, compensation, or other remuneration of any kind for dental hygiene services rendered.

b. Dental Hygiene Education (DHED)

Subject to any Program-imposed restrictions on moonlighting, DHED Students who are duly licensed to practice dental hygiene in the State of North Carolina may engage in unrestricted extramural practice. These DHED Students should be aware, however, that the Adams School of Dentistry's malpractice insurance policy only covers activities that are related to the DHED Student's enrollment and/or employment at the Adams School of Dentistry.

For purposes of this Policy, DHED Students who are not licensed to practice dental hygiene in the State of North Carolina are subject to the same restrictions on extramural practice as undergraduate Dental Hygiene students [refer to subsection-A(2)(a) above].

3. Resident Dentists

a. Fully-Licensed Dentists or Physicians

Subject to any Program-imposed restrictions on moonlighting, Residents who are duly licensed in the State of North Carolina to practice dentistry and/or medicine may engage in unrestricted extramural practice within the scope of their respective licensure. These Residents should be aware, however, that the Adams School of Dentistry's malpractice insurance policy only covers activities that are related to the Resident's enrollment and/or employment at the Adams School of Dentistry.

b. Intern Permit Holders

Except as provided in the "Exceptions" section below, dental Intern Permit Holders are not permitted to practice dentistry outside the Adams School of Dentistry unless:

1. the Intern Permit holder is appropriately supervised by a duly licensed dentist in accordance with 21 NCAC 16Y .0104;
2. the activity occurs at a Board-approved site listed at the Board's Intern Permits and Information webpage;
3. the Board is notified prior to the change in practice location; and
4. a written agreement has been executed between the Adams School of Dentistry and the extramural site.

The Associate Dean for Advanced Dental Education (or designee) is responsible for maintaining a list of all extramural sites where Intern Permit holders are authorized to practice.

Under no circumstances may an Intern Permit holder receive fees, compensation, or other remuneration of any kind for dental services rendered.

B. Exceptions

1. Student Health Action Coalition (SHAC) Dental Clinic

For purposes of this Policy, clinical activities though SHAC are not considered "extramural" unless they take occur at a location other than the Adams School of Dentistry or other University-owned facility. However, the supervision requirements outlined in this Policy still apply at any intramural SHAC location.

2. After-Hours Facilities Use Only

For arrangements where an extramural site is providing after-hours Facilities Use only (e.g., certain Student-led volunteer clinics) and has assumed no other obligations toward the extramural activity, no written agreement is required unless:

1. requested by the extramural site, or
2. a written addendum is necessary to avoid confusion with an extramural site that also hosts Student or Resident rotations.

However, the supervision and Board notification requirements outlined in this Policy still apply.

No Student or Student group may establish a volunteer clinic without a Faculty Sponsor. Faculty Sponsors are responsible for ensuring Students are advised of all administrative issues associated with operating a dental clinic, including:

• faculty supervision,
• workplace safety,
• infection control,
• HIPAA privacy/security,
• clinical documentation and informed consent, and
• resource procurement.

3. Telehealth and "On Call" Activities by Residents

For purposes of this Policy, telehealth and other "on call" activities by Residents are not considered "extramural" unless they are unrelated to the Residents' enrollment and/or employment at the Adams School of Dentistry. However, these activities are still subject to the supervision requirements codified at 21 NCAC 16Y .0104(c).

4. Out-of-State Activities

Any clinical activities occurring outside the State of North Carolina must comply with the applicable laws of the jurisdiction in which the activity takes place (e.g., externship at an out-of-state dental school or hospital, international service trip, etc.). Students should be aware that the Adams School of Dentistry's malpractice insurance will not cover activities that have not been approved by the Adams School of Dentistry.

IV. Clinical Affiliation Agreements

The Adams School of Dentistry maintains a standard agreement template for clinical affiliation arrangements referenced in Section III-A (see Attachment A). Modifications to the template - or agreements that have been drafted by the extramural site - must be reviewed by the Office of University Counsel. The Agreement must be signed by an authorized University official in accordance with the School's Procedure for Signing Contracts.

V. Related Requirements

A. External Regulations

• North Carolina General Statute § 90-29(c)(4): Necessity for license; dentistry defined; exemptions
• North Carolina General Statute § 90-233(c)(2): Practice of dental hygiene
• North Carolina General Statute § 90-29.4: Intern permit
• 21 NCAC 16K .0106: Reports to Board
• 21 NCAC 16G .0106: Dental hygiene school extension facilities and off campus classes
• 21 NCAC 16Y .0103: Employment
• 21 NCAC 16Y .0104: Direction and supervision

VI. Contact Information