Culture of Compliance

By Laura Thill

Consistent infection control protocols throughout a large group practice protect dental owners, their team and their patients from the spread of disease.

For large group dental practices, implementing and maintaining an effective infection control program can be challenging due to their size and the fact that they include multiple licensed providers. But failing to do so places them at a heightened risk of infection, making the effort well worth their while.

Samantha Sharon

“All dental providers should have protocols in place for infection control, but because the group practice typically has multiple licensed providers, we face a much greater risk if infection control protocols are not in place and followed,” says Samantha Sharon, CHC, CHPC, vice president of compliance, Benevis. “Infection control processes and procedures should be implemented and audited regularly to ensure compliance with dental board rules and regulations, Centers for Disease Control and Prevention (CDC) guidelines (https://www.cdc.gov/oralhealth/infectioncontrol/guidelines/), Healthcare Infection Control Practices Advisory Committee (HICPAC) regulations and OSHA (https://www.osha.gov/). The protocols help to ensure patient and team member safety as part of day-to-day operations.”

Ensuring that all facilities within a large group practice adhere to an infection control program may seem overwhelming, Sharon acknowledges. “But the end result – knowing that your offices provide the best care to your patients and having comfort in the fact that you are doing the right thing – is rewarding,” she says. “Start by building a basic checklist of the most important items that the dental board and OSHA requires, and the CDC recommends. Implement a monthly auditing and reporting mechanism to ensure visibility and accountability. Don’t let the little things slide, and always make this a priority. Creating a culture of compliance takes time, but is well worth the effort to build a solid group practice foundation.”

Elaine Olejnik

The first step toward a successful infection control program is “constant training,” according to Elaine Olejnik, compliance officer, Great Expressions Dental Centers and Dr. Robert Brody, chief clinical officer, Great Expressions Dental Centers. Training should focus on “the what, the why and the how of infection control, as outlined by the CDC, the Organization for Safety, Asepsis and Prevention (OSAP), the Occupational, Safety and Health Administration (OSHA), the American Dental Association (ADA) and state and local dental associations,” they point out.

“The second step is the implementation of sound infection control practices based on this training,” Olejnik and Brody continue. The third and perhaps most important step is to implement a culture of safety, which is embraced by all levels of an organization, they add, noting that their organization addresses all of these with regards to its infection control program. “We are particularly proud of the culture of safety within the Great Expressions team, which we have developed to protect both our patients and our employees.”

Consistent protocols

Brian Bay

Dental groups have a lot to risk by failing to adhere to an effective infection control program. “There are a variety of illnesses and diseases – a primary one being Hepatitis B – that can be spread if proper infection control procedures are not followed,” says Brian Bay, senior manager, risk management and loss prevention, Aspen Dental Management, Inc. (ADMI). Whether a large group or an independent practice, “any clinician or clinical team can face violations, such as unprofessional conduct, breach of the standard of care, dental board actions, lawsuits, etc.,” he points out. “It’s critical for any dental provider to understand and always follow infection control guidelines, procedures and protocols to protect themselves and ensure their patients are receiving the best quality care possible.”

For this reason, every practice should designate an individual to oversee infection control, Bay notes. “At Aspen Dental branded practices, the lead dental assistant is tasked with coordinating infection control for all instruments,” he says. Office managers are responsible for broader infection control programs in the practice. Ultimately, the licensed dentist is held accountable for infection control in the dental practice and [he or she] needs to be involved in the process as well.

Additionally, it’s important that all facilities in a group practice follow consistent infection control protocols, Bay says. “At Aspen Dental branded practices, the owner dentists have adopted a standard procedure for infection control. ADMI has identified vendor partners who can help aggregate data, identify trends and report on metrics so we can best evaluate how well the practices’ infection control procedures and protocols are working in every office.”

Indeed, it can be challenging when infection control experts such as Bay can’t be on site at every office the DSO supports, ensuring first hand that the staff properly follow infection control procedures and protocols. “It never hurts to offer more training to the dental owners we support and their staff to ensure they have a better understanding of how to prevent cross contamination from occurring.”

Consistent message

Dr. Robert Brody

Group practices that emphasize a culture of safety often are more likely to implement a successful infection control program, according to Olejnik and Brody. “These practices have a consistent message stressing the importance of infection control,” they point out. “As a result, they will develop a successful infection control program. Some may argue as to which comes first – the culture or the infection control program. Either way, both are needed to protect group practices from infection liability. You cannot have one without the other.

Olejnik and Brody agree that having a designated infection control coordinator at each location helps reinforce the group culture of safety. “Though all successful infection control programs are a team effort, a leader or go-to person is needed to move it forward in a seamless manner,” they say. “In fact, the CDC recommends there be a designated infection control coordinator. The Great Expressions infection control coordinators are our eyes and ears within each office. We work in tandem to ensure success of the program, and we could not do it without them.” That said, it’s important to have the right tools in place to support such a program. “Great Expressions Dental Centers utilizes a comprehensive tool – a monthly checklist – which ensures the infection control standards within the office stay compliant. GEDC is fortunate to have a forward-thinking IT department, which developed [our] Compliance Dashboard, providing transparency into each office’s progress.”

Having written protocols and a monitoring process, together with constant training and monitoring, is essential to ensuring so many employees across multiple sites follow a consistent set of infection control protocols, note Olejnik and Brody. That said, “while checklists and tools are wonderful adjuncts, the basis for Great Expressions’ success is truly a team effort,” they add.

Team effort
Because infection control affects the entire practice, all team members should be accountable for following appropriate protocols, notes Sharon. It’s an important step toward creating buy-in to the culture of the practice, she says. That said, “it is also important to ensure there are team members who are responsible for auditing and holding teams accountable,” she points out. “These roles should be assigned to at least two team members in a supervisory or management role. The responsibility of ensuring that infection control protocols are in place and being adhered to is not only practical, it is a requirement. Not implementing protocols can result in adverse patient outcomes, provider’s licensure being at risk, fines, bad publicity and even closure.

“Educating everyone in the practice to help them understand the why behind each process creates more informed team members,” says Sharon. “It also makes them more aware of their responsibility as healthcare providers to patients.” Dental owners should provide their team with informative training materials explaining why the infection control program is in place, she notes. “Education should be a full circle. Simply telling team members to do something does not create buy in. Helping them understand why the program is in place and enlisting their help makes them a part of something bigger.” Providers are likely to be more motivated when they understand these protocols are in place to protect their reputation and their dental license, she adds.

“The best part of group practices is their efficiency,” Sharon continues. “It would seem like a natural part of the business to apply the same philosophy to infection control protocols. Having a common system, checklist and audit requirements for all practices ensure everyone is on the same page and working towards the same goal.”

Sterilization protocols
All healthcare workers are at risk of contamination, says Sharon. “The key is to train the staff and ensure their understanding of the infection control protocols and the use of Standard Precautions to help provide protection against diseases. Without proper training for infection control protocols and utilizing Standard Precautions for all patients, employers are subjecting their employees to diseases that can spread through body fluids, such as hepatitis B virus (HBV), hepatitis C virus (HCV), human immunodeficiency virus (HIV), Mycobacterium tuberculosis, staphylococci, streptococci and other bacteria, which can colonize or infect the mouth and respiratory tract.”

Sloppy or lax infection control practices not only place the dental staff and patients at risk for such diseases as herpes, hepatitis, HIV, AIDS and tuberculosis, they can be life altering, note Olejnik and Brody. “Many of these infections are chronic, life-long and even life-threatening diseases, and they are often carried by individuals who either do not know they are infected or do not want to disclose their full health history,” they point out.

When it comes to infection control programs, “sterilization is by far the most important protocol, since instruments are being held by clinicians and placed in patients’ mouths,” says Bay. “Handwashing and disinfection are also critical to ensuring infection control best practices are always followed, but for a dental office, sterilization is definitely most critical.”

In addition to hand hygiene and sterilization of instruments, several key protocols covered in an infection control program include the administrative role, training, personal protective equipment (PPE), sharps safety, disinfection of the treatment room, sterilization of the armamentarium, biological monitoring/spore testing of sterilization units and more, according to Olejnik and Brody. “Great Expressions patients should never concern themselves with infection control in our offices,” they add. “Obviously, the PRIMARY concern is for the patient’s and employee’s well-being and health. However, a lack of adherence to a sound infection control program can also result in bad media coverage for the practice, legal ramifications and even a potential office closing.”

When dental facilities do not adhere to standard infection control protocols, and staff or patients become ill, the practice is exposed to a number of liabilities, including the following, according to Sharon:

  • Audits from the dental board and/or OSHA, potentially resulting in fines.
  • A dental board complaint, which can result in legal costs, disciplinary actions, restriction or loss of license and fines.
  • Malpractice litigation costs and settlements.
  • A tarnished reputation.
  • Loss of patients.
  • Negative social media posts.

“The time, expense and repercussions of these negative consequences can be avoided if everyone adheres to an established infection control process,” she says. “Although it seems like a big undertaking, implementing a basic infection control process in your office will promote patient and team member safety, protect you, minimize your risk and help ease your mind.”


Infection control checklist

Samantha Sharon, CHC, CHPC, vice president of compliance, Benevis, summarizes the key points of an infection control program:

  • Spore testing.
  • Instrument sterilization for both heat sterilization and cold sterilization.
  • Hard surface sterilization and use of barriers.
  • Sharps safety.
  • Safe injection practices.
  • Personal protective equipment (PPE) use and disposal.
  • Hand washing.
  • Waterline testing.
  • Blood or other body fluid spills and clean-up process and procedures.
  • Respiratory hygiene/cough etiquette.

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