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Board task force begins work on penalty rubric to standardize sanctions for dental hygiene programs
Summary
The Dental Hygiene Educational Program Penalty Rubric Task Force convened and started categorizing violations and remediation timeframes under factors spelled out in 16 CCR Section 1104.3 to make penalties for program noncompliance more consistent and transparent.
The Education Committee received an update on the newly formed Dental Hygiene Educational Program Penalty Rubric Task Force and its first meeting on June 4, 2025. Committee co-chair Joanne Pacheco summarized the task force's mandate and early work to categorize violations and remediation timeframes using the statutory factors found in California Code of Regulations, Title 16.
Pacheco said the board had previously relied on removing board approval as a penalty, which prevented graduates from qualifying for licensure, and that intermediary sanctions were needed to provide programs an opportunity to remediate. The board obtained legislative authority in 2019 to implement citations, fines and probation as intermediate penalties, and the board promulgated regulations in 2023 to govern reviews, site visits, citations and fines.
Task force composition and scope At the March 22, 2025 full board meeting, the board appointed Pacheco and Julie Ellinger as co-chairs of the task force. The co-chairs appointed three subject-matter experts to the task force: Joanne Galliano, Michelle Hurlbut and Lisa Cambayashi. The task force began its work by discussing the factors specified in 16 CCR section 1104.3 subdivision (b)(3), including the nature and severity of the violation, the length of time since violation, potential or actual patient harm, history of similar violations, willfulness, gravity and the extent of remediation.
Planned process and timeline The task force discussed frequency of observed violations, appropriate remediation timeframes and how to structure a rubric so penalties will be applied consistently across programs. Task force members anticipate several future meetings before presenting a draft rubric to the board; the next task force meeting is scheduled for July 22, 2025.
Why it matters Task force leaders framed the rubric as a tool to increase transparency for programs and the public: by clarifying consequences for specific behaviors, programs will better understand regulatory expectations and the board will apply sanctions more uniformly.
