CDSA Update for Alberta Associate Dentists offering Botox

regulation & industry updates Nov 13, 2016
a dentist talks to a patient about Botox

The following update was recently posted in the October 2016 issue of the College of Dental Surgeons of Alberta (CDSA's) Updater.

Associate or Contractual Dentists Providing Facial Esthetic Therapies and Adjunctive Procedures

Dentists can provide facial esthetic therapies and adjunctive procedures (FETAP) (ie: botox, dermal fillers, etc) services in a dental clinic that they do not own and be in compliance with the Standard of Practice: Facial Esthetic Therapies and Adjunctive Procedures (FETAP Standard).

In this scenario, the owner dentist and other dentists not providing FETAP services (ie: botulinum toxin, dermal fillers, etc) are not required to hold FETAP certification (ie: Level 1 - Advanced Anatomy & Into to Botulinum Toxin, Level 2 - Basic Botulinum Toxin, Level 3 - Advanced Botulinum Toxin courses). FETAP certification is granted by the CDSA to each individual dentist and certification is not based on whether the dentist associates at a dental clinic or owns the dental clinic. It is possible to associate at a dental clinic and only perform FETAP services.

In spite of this, there continue to be ethical, regulatory and medicolegal requirements that are germane. In general, the best way to describe the necessary arrangement would be analogous to that of any associate relationship or a space rental agreement.

The requirements of the FETAP Standard apply to the individual dentist performing the FETAP services (the Treating Dentist) and are not changed by virtue of their relationship with the dental clinic. The Treating Dentist is required to complete an examination on the patient and ensure that the FETAP services are part of an overall maxillofacial treatment plan as set out in the FETAP Standard. The Treating Dentist must also have complete clinical records, including photographs, and must provide after-hours or emergency coverage specific to the treatment they have provided. There must be appropriate coverage of these patients by a dentist with an equivalent or higher level FETAP certificate in case the Treating Dentist is not available. With any dental treatment, advising patients to present to an emergency clinic or the University of Alberta Dental Clinic is relinquishing the dentist's ethical responsibility. The continuity of care arrangements for the patient if the Treating Dentist is unavailable requires that a dentist with an equivalent or higher level FETAP certification be available to address the patient's concerns.

From a practical perspective, consider a written agreement between the dentists detailing the associateship agreement, or rental of space. It is advisable for the Treating Dentist to have a separate chart, financial record, and billing system. Any agreement must also detail the protocol for ongoing patient care should the relationship end and the agreement be terminated. It will always remain the responsibility of the Treating Dentist to arrange for this continuity of care.

View a PDF of the memo here.


For more information on botox and dermal filler training requirements for Alberta dentists, click here.

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