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1 hints: For organizations outside the Salud system, please note the following (hopefully) helpful *Some of these policies may be contained in the HR or Central Administration manuals of your organization. *JCAHO will be looking for some evidence that all appropriate employees have reviewed this manual. For example, a signoff sheet works, and can be kept either with the manual (if you have only one practice site) or with the employee s personnel file (if you have multiple sites). *Check the Toolbox Folder for examples of signoff sheets.

2 PLAN DE SALUD DEL VALLE, INC. DENTAL DEPARTMENT CQI PROGRAM Prepared for Plan de Salud del Valle, Inc. By Eva Poulson, DDS

3 DENTAL DEPARTMENT Dental Department CONTINUOUS QUALITY IMPROVEMENT PROGRAM CONTINUOUS QUALITY IMPROVEMENT POLICIES Dental CQI CQI Reporting Form Dental Quality Assurance Auditing Continuous Quality Improvement Plan Credentialing Policy Provider References/ Competency Provider Credentialing Provider Privileging Checklist Dental Assistant Competency Faculty Appointments Continuing Education Physical Plant STANDARDIZED MINUTES FORMAT Provider Team Minutes Dental Team Minutes

4 CONTINUOUS QUALITY IMPROVEMENT PROGRAM

5 DENTAL CQI PLAN Salud Dental Department participates in CQI Management Teams as part of SALUD s overall Continuous Quality Improvement Plan. The established clinic management team protocols have been defined as follows: 1. The Dental department will participate in clinic-wide team meetings on a regular basis. 2. The dental provider team will consist of all dentists and dental hygienists from all sites. This team shall meet at least once a month (except June-August while migrant school is in session), unless the number of persons unable to attend due to illness or vacation would render the meeting unproductive. This assessment shall be made by consensus of the team. Meeting times are scheduled by general consensus of the team. 3. The dental clinic team shall consist of all staff levels at each dental site. This team shall meet at least once a month, with the same exceptions as above. The clinic management teams shall schedule meetings by consensus at each site individually. 4. Minutes of all dental team meetings shall be distributed to the team members prior to the next meeting for a review whenever possible. In addition, all minutes for the current year are to be kept on file by the Dental Director at each dental clinic site. 5. Salud Dental Department maintains a goal of two dental-specific CQI projects per year in addition to participating in Salud s overall CQI program. Project results should be forwarded to the CQI Committee, via meeting minutes or by report. The CQI reporting form may be used for this purpose.

6 CQI REPORTING FORM Dental Department Site: Date: Parties Involved: Statement of Problem: Baseline Data: Root Cause Analysis: Proposed Intervention: Follow up Plan: Post Intervention Data: (Use additional pages as necessary)

7 DENTAL QUALITY ASSURANCE OVERVIEW The purpose of dental quality assurance is to establish standards and policies for evaluating the quality and appropriateness of oral health care by the Salud Dental Department. The progression of quality assurance is regarded as a kinetic process with staged development. In the initial stages, basic standards will be formulated and limited chart auditing implemented. As the process continues, standards will be reviewed and improved through revision, and the auditing process will be expanded. All Salud staff will be responsible for implementing the quality assurance process. This includes involvement in setting standards, establishing and implementing audits, and improving the process through revisions and additions. GENERAL It is not the intent of the process of quality assurance to set procedural techniques for the practice of dentistry. Standards and policies will be established to assist and improve the practice of general dentistry at Salud. Standards of care will be determined and agreed upon by the practitioners responsible for individual treatment of patients. These standards will be reviewed and revised as necessary on a yearly basis or at the request of the staff dentists. PROCEDURE Charts will be reviewed and audited on a regular basis. Findings of the chart audit will be documented, collated, reported, and retained in a quality assurance manual. It is the hope and intent of the Salud staff that quality assurance is viewed as a learning process, and that individual critiquing is informal.

8 QUALITY ASSURANCE COMMITTEE AUDITING PURPOSE To formulate, establish and maintain standards and policies, and evaluate the quality of dental treatment at Salud. MEMBERSHIP The committee, in its auditing function, will be comprised of all Salud dentists and hygienists. PROCEDURE The committee will review a random sampling consisting of 10 charts per provider, and 10 student charts per site, in which the patient was seen in the last three months. This review process will be done at least two times per year. EVALUATION The goal of the committee will be to identify any problems and deficiencies in the provision of dental care at Salud, then to inform the providers and staff of these problems and deficiencies so that the department can improve their practice of dentistry. The random charts will be reviewed by the entire committee and critiqued using a preestablished list of standards as the evaluating criteria.

9 PROCEDURE NOTES Charts of Audited by (A) General consents obtained (B) Pt. name, # on all chart pages (C) Health history reviewed (D) Cancer check, for walk-in visits (E) Blood pressure taken, for walk-in visits (If > 18 years old) (F) Entry includes tooth number(s) treated (G) Treatment rendered & materials used were properly noted (H) Local anesthesia noted (Type and amount) ( I ) Prescriptions or medications given were properly noted

10 (J ) Appropriate consents were obtained (Oral surgery, endo, N2O) Dental Department (K) Treatment to be rendered at next visit was noted (L) Fees were noted (M) Charting was accurate (red/blue, corresponds to notes, etc.) (N) Entry dated and signed

11 EXAMINATION CHARTS Charts of Audited by (A) Consents obtained (B) Health history reviewed (C) Blood pressure taken ( pts. >18 y.o.) (D) Cancer check (E) PSR recording (F) Occlusion noted (G) Fluoride status (H) Preventive counseling ( I ) Charting was accurate (red/blue, corresponds to notes, etc.) (J ) Treatment plan

12 (K) Fees noted (L) Appropriate provider signature(s) (M) X-ray mounts labeled (N) X-ray quality (contacts, apices, contrast, cone cuts, etc.)

13 DENTAL HYGIENE Charts of Audited by (A) Name, DOB, chart number was noted (B) Treatment procedures, as well as charges, were noted (C) Health history was reviewed (D) Oral hygiene and plaque index status was noted (E) Perio status was noted (F) Oral hygiene instructions were given (G) Hygiene treatment status was noted (H) DDS NV was noted ( I ) Appropriate provider signature(s)

14 PROCEDURE NOTES STUDENT Charts of Audited by (A) General consents obtained (B) Pt. name, # on all chart pages (C) Health history reviewed (D) Cancer check, for walk-in visits (E) Blood pressure taken, for walk-in visits (If > 18 years old) (F) Entry includes tooth number(s) treated (G) Treatment rendered & materials used were properly noted (H) Local anesthesia noted (Type and amount) ( I ) Prescriptions or medications given Were properly noted

15 (J ) Appropriate consents were obtained (Oral surgery, endo, N2O) Dental Department (K) Treatment to be rendered at next visit Was noted (L) Fees were noted (M) Charting was accurate (red/blue, corresponds to notes, etc.) (N) Entry dated and signed

16 EXAMINATION CHARTS STUDENT Charts of Audited by (A) Consents obtained (B) Health history reviewed (C) Blood pressure taken ( pts. >18 y.o.) (D) Cancer check (E) PSR recording (F) Occlusion noted (G) Fluoride status (H) Preventive counseling ( I ) Charting was accurate (red/blue, corresponds to notes, etc.)

17 (J ) Treatment plan Dental Department (K) Fees noted (L) Appropriate provider signature(s) (M) X-ray mounts labeled (N) X-ray quality (contacts, apices, contrast, cone cuts, etc.)

18 DENTAL HYGIENE STUDENT Charts of Audited by (A) Name, DOB, chart number was noted (B) Treatment procedures, as well as charges, were noted (C) Health history was reviewed (D) Oral hygiene and plaque index status was noted (E) Perio status was noted (F) Oral hygiene instructions were given (G) Hygiene treatment status was noted (H) DDS NV was noted ( I ) Appropriate provider signature(s)

19 CREDENTIALING POLICY The following credentials are expected as a condition of employment in the Plan de Salud del Valle, Inc. Department of Dentistry: DENTISTS: -Graduation from an accredited dental school -Licensure in the state of Colorado -Current CPR certification -Current DEA registration -National Practitioner Data Bank shall be checked for reported incidents -Must be eligible to be a member in good standing of the ADA, CDA, and local component dental societies -All staff dentists are required to obtain faculty appointments at the University of Colorado School of Dentistry for the purpose of precepting students -All dentists will maintain Continuing Education credits in accordance with the requirements of the Colorado Dental Association HYGIENISTS: -Graduation from an accredited dental hygiene program -Licensure in the state of Colorado -Current CPR certification -National Practitioner Data Bank shall be checked for reported incidents -Must be eligible to be a member in good standing of the ADHA, CDHA, and the local component dental hygiene society -All dental hygienists will maintain Continuing Education credits in accordance with the requirements of the Colorado Dental Hygiene Association DENTAL ASSISTANTS: -Current CPR certification -Obtain radiology certification within 30 days of employment All dentists shall practice general dentistry within the scope of their licensure, training, and competencies. All dental hygienists shall practice within the scope of their licensure, training and competencies. All dental staff shall practice within the limitations of the State Dental Practice Act of Colorado. The verification of certification for all employees is the responsibility of the Personnel Director. All documentation of verification shall be kept on file by the Personnel Director's office.

20 POLICY PLAN DE SALUD DEL VALLE, INC. DENTAL POLICIES AND PROCEDURES CREDENTIALING POLICY FOR DENTAL PROVIDERS In order to assure that Salud maintains a high quality of dental services by hiring only qualified providers, the credentials of prospective provider employees are evaluated as part of the hiring process. PROCEDURE The following credentials are to be obtained by the personnel department prior to finalization of the hiring process: 1. Licensure by the Colorado State Board of Dental Examiners. 2. Existence of any action against the applicant by the Colorado Sate Board of Dental Examiners. 3. Existence of any claims filed with the National Practitioners Data Base. 4. Current CPR certification. In addition, after one year of employment, and on an annual basis thereafter, the following items are also checked: 1. Continuing Education credits as recommended by the Colorado Dental Association 2. Current faculty appointment at University of Colorado School of Dentistry 3. Other faculty appointments as required to precept students at the assigned service site

21 TO: RE: Employment Reference Employee Name: Social Security #: Date: Dear Sir/Madam: The above referenced practitioner is applying for clinical privileges at Plan de Salud del Valle, Inc. The Credential Committee is in the process of evaluating this practitioner s qualifications. We would appreciate your assistance in completing the following questionnaire. A copy of authorization/release for liability is attached. If you have any questions, you may call me at (303) , ext Thank you for your assistance in evaluating this applicant. Sincerely, Ann Hogan Human Resources Manager 1. How long have you known the candidate? In what capacity? Professional Personal 2. Dates of Affiliation / 3. Have you had direct clinical experience/observation with this practitioner? 4. What is your present position? 5. Should questions arise, may we telephone you? 6. During the time period noted in Question 2, was this practitioner ever subject to disciplinary

22 action, such as admonition, reprimand, suspension or termination? (If yes, please explain on the next page) Dental Department Evaluation: Please rate the following: Professional Judgment: Excellent Good Fair Poor N/A Clinical Competence: Excellent Good Fair Poor N/A Emotional Stability Excellent Good Fair Poor N/A Procedural Skills Excellent Good Fair Poor N/A Relationship with Provider staff Excellent Good Fair Poor N/A Relationship with Support staff Excellent Good Fair Poor N/A Relationship with Patients Excellent Good Fair Poor N/A Professional Attitude Excellent Good Fair Poor N/A Sense of Responsibility Excellent Good Fair Poor N/A Ethical Conduct Excellent Good Fair Poor N/A Record Keeping Excellent Good Fair Poor N/A Patient Management Excellent Good Fair Poor N/A Recommendation: Highly recommend without reservation Recommend as qualified and competent Recommend with some reservation (please comment) Do not recommend (please comment)

23 Comments: Thank you for completing this questionnaire. Please feel free to offer any additional comments, which you believe, will assist the Credential Committee in their evaluation or further explain answers on questionnaire. Signature Title Date

24 PLAN DE SALUD DEL VALLE, INC. DENTAL POLICIES AND PROCEDURES CREDENTIALING CHECKLIST FOR DENTAL PROVIDERS DATE PROVIDER Licensure- State of Colorado Colorado State Board Actions National Practitioners Data Bank Current CPR certification Continuing Education Faculty appointment

25 DENTAL DEPARTMENT PRIVILEGE REQUEST Dental Privilege Code Dental Procedure Requested Approved Diagnostic Initial Oral Examination Periodic Oral Examination Emergency Oral Examination Periodontal Examination Pulp Vitality Tests Diagnostic Casts Palliative (emergency) Treatment of Dental Pain-minor procedures Office Visit for Observation (During Regularly Scheduled Hours) Other Services Performed Radiology Intramural Complete Series Intraoral Periapical First Film Intraoral Periapical Each Additional Film Intraoral Occlusal Film Bitewings Single Film Bitewings Two Films Bitewings Four Films Panoramic Film Preventive Prophylaxis Adult Prophylaxis Child Topical Application of Fluoride Child Topical Application of Fluoride Adult Nutritional Counseling for the Control of Dental Disease Oral Hygiene Instruction Sealant Per Tooth Space Maintainer Fixed Unilateral Space Maintainer Fixed - Bilateral Recementation of Space Maintainer Restorative Amalgam Restorations Amalgam Primary

26 02131 Amalgam Permanent Dental Department Resin Restorations Resin - Anterior Composite Resin Crown Anterior Primary Resin Posterior Primary Resin Posterior Permanent Crown-Single Restorations Crown Resin (Laboratory) Crown Resin with Metal Crown Porcelain/Ceramic Substrate Crown- Porcelain Fused to Metal Crown ¾ Cast Metallic Dental Privilege Code Dental Procedure Requested Approved Other Restorative Services Recement Inlay/Crown Prefabricated Stainless Steel Crown Primary Prefabricated Stainless Steel Crown Permanent Prefabricated Resin Crown Prefabricated Stainless Steel Crown w/ Resin Window Sedative Filling Core Buildup, Including Any Pins Pin Retention Per tooth, in addition to restoration Cast Post and Core in addition to crown Prefabricated post and core in addition to crown Labial Veneer (Laminate) Chairside Temporary Crown (Fractured Tooth) Crown Repair, By Report

27 Endodontics Pulp Capping Pulp Cap Direct Pulp Cap Indirect Pulpotomy Therapeutic Pulpotomy Root Canal Therapy Anterior Bicuspid Molar Dental Department Apexification/Recalcification Initial, Interim and Final Visits Periapical Services Apicoectomy/Periradicular Surgery Retrograde Filling Per Root Root Amputation Per Root 03470* Intentional Replantation (Including Splinting) Other Endodontic Procedures Surgical Procedure for Isolation of Tooth With Rubber Dam Bleaching of discolored Tooth Unspecified Endodontic Procedure, By report (Pulpectomy) Rotary Endodontic Technique Periodontics Surgical Services Gingivectomy or Gingivoplasty Gingival Curettage, Surgical Gingival Flap Procedure, Including Root Planing Crown Lengthening, Hard and Soft Tissue Adjunctive Periodontal Services Periodontal Scaling and Root Planing Periodontal Scaling Performed in the Presence of Gingival Inflammation Periodontal Maintenance Procedures (Following Active Therapy)

28 Prosthodontics (Removable) Complete /Partial Dentures Complete Upper/Lower Immediate Upper/Lower Upper/Lower Resin Base Upper/Lower Partial Cast Metal Base with Resin Saddles Adjust Complete or Partial Denture Repairs to Dentures Repair Broken Complete or Partial Denture Base Replacing Missing or Broken Teeth Complete or Partial Denture Repair Cast Framework/Clasp Add Tooth to Existing Partial Denture Add Clasp to Existing Partial Denture Rebase Complete/Partial Denture Reline Complete/Partial Denture (Chairside) Reline Complete/Partial Denture (Laboratory) Other Removable Prosthetic Services Interim Partial Denture Tissue Conditioning Prosthodontics, Fixed Bridge Pontics Pontic Cast Metal Pontic Porcelain Fused to Metal Pontic Resin with Metal Bridge Retainers Crowns Crown Resin with High ble Metal Crown Porcelain Fused to Metal Crown ¾ Cast Metal Crown Full Cast Metal 06792

29 Other Fixed Prosthetic Services Recement Bridge Core Build Up For Retainer Bridge Repair Oral Surgery Extractions Simple Extractions Root Removal Exposed Roots Surgical Extractions Surgical Removal of Erupted Tooth Requiring Elevation of Mucoperiosteal Flap and Removal of Bone and/or Section of Tooth Removal of Impacted Tooth Soft Tissue Removal of Impacted Tooth Partially Bony Removal of Impacted Tooth Completely Bony 07241* Removal of Impacted Tooth Completely Bony with Unusual Surgical Complications Surgical Removal of Residual Tooth Roots (Cutting Procedure) Other Surgical Procedures Tooth Reimplantation and/or Stabilization of Accidentally Avulsed or Displaced Tooth and/or Alveolus 07271* Tooth Implantations Surgical Exposure of Impacted or Unerupted to Aid Eruption 07285* Biopsy of Oral Tissue Hard Biopsy of Oral Tissue Soft Alveoplasty Surgical Preparation of Ridge for Dentures Alveoplasty in Conjunction With Extractions

30 07320 Alveoplasty n In Conjunction With Extractions Surgical Excision of Reactive Inflammatory Lesions Radical Excision Lesions Diameter up to 1.25cm Removal of Tumors, Cysts and Neoplasms Excision of Benign Tumor Lesion < 1.25cm 07450* Removal of Odontogenic Cyst or Tumor Lesion Diameter up to 1.25cm 07460* Removal of nodontogenic Cyst or Tumor Lesion Diameter up to 1.25cm Excision of Bone Tissue Removal of Exostosis Maxilla or Mandible Surgical Incision Incision and Drainage of Abscess Intraoral Soft Tissue 07520* Incision and Drainage of ABCs Extraoral Soft Tissue Removal of Foreign Body, Skin, or Subcutaneous Tissue 07540* Removal of Reaction Producing Foreign Bodies Musculoskeletal Systems 07550* Sequestrectomy for Osteomyelitis Repair of Traumatic Wounds Suture of Recent Small Wounds up to 5cm Complicated Suturing Complicated Suture Up to 5 cm 07912* Complicated Suture Greater than 5 cm Other Repair Procedures Frenulectomy (Frenectomy or Frenotomy) Separate Procedures Excision of Hyperplastic Tissue Excision of Pericoronal Gingiva Orthodontics Minor Treatment for Tooth Guidance

31 08110 Removal Appliance Therapy Dental Department Minor Treatment to Control Harmful Habits Removal Appliance Therapy Interactive Orthodontic Treatment Removal Appliance Therapy Adjunctive General Services Anesthesia Regional Block Anesthesia 09230* Analgesia (N2O2) Miscellaneous Services Application of Desensitizing Medicaments Occlusal Guards Fabrication of Athletic Mouthguards Occlusal Adjustment - Limited Signature of Requester Date Signature of Reviewer Date

32 Dental Assistant Competency Test Dental Assistant Name: Reviewer s Name: Date: Demonstrated Review Requested Initials and Date Routine Procedures: Set up: Dental Assistant is able to prepare operatory and instruments for routine general dentistry procedures. Practice: Dental Assistant is able to anticipate dentist s needs during the procedure. Training Needed and Date of Training Reviewer s comments Radiology: Safety: Dental Assistant uses safe radiation exposure practices. (Lead apron, personal safety, correct exposure parameters) Accuracy: Dental assistant is able to expose radiographs of good diagnostic quality at least 90% of the time. Sterilization: Laboratory: Dental Assistant is able to demonstrate correct procedures for cleaning and sterilizing dental instruments. (Cleaning, preparation, and use of autoclave and dry heat methods). Testing: Dental Assistant is able to demonstrate correct procedure for testing sterilization equipment for adequate sterilization. Able to demonstrate correct documentation procedures.

33 Operatory, Disinfection, and Maintenance: Opening Procedure: Dental Assistant is able to prepare dental operatory at start of day. Closing Procedure: Dental Assistant is able to describe correct dental clinic area closing procedure. Disinfection: Dental Assistant is able to correctly disinfect the operatory between patients. Scheduling: Dental assistant is able to demonstrate correct routine scheduling procedures. Demonstrates appropriate phone techniques. Record Maintenance: Charting: Dental Assistant is able to accurately chart patient s dental condition from doctor s dictation. Forms: Dental Assistant prepares appropriate form as indicated by patient treatment. Charting is accurate. Encounters: Dental Assistant is able to accurately complete encounter form based on procedures completed. Insurance: (Reception Assistant Optional for others) Dental Assistant is able to accurately complete insurance forms based on information from the encounter

34 or procedure notes. Supplies (Supply or front desk assistant) Dental Assistant is able to correctly order inventory and distribute supplies and do so in a timely fashion.

35 FACULTY APPOINTMENTS In order to promote an awareness of the needs of underserved populations among future healthcare providers, Salud participates actively in precepting students. The Dental Department participates in the precepting of students from Dental Schools, Dental Hygiene Schools, and Dental Assisting Programs. Dentist and Dental Hygiene providers are expected to apply for and obtain faculty appointments at the schools from which they precept students. Letters of faculty appointment should be forwarded to the Personnel Director.

36 CDE POLICY 1. All FTE dental providers (dentists) must be eligible to be current members of the American Dental Association and all dental providers (hygienists) must be eligible to be current members of the American Dental Hygienists Association. This organization will pay the dues for these organizations. 2. All FTE dental providers must obtain continuing education requirements in compliance with the Colorado Dental Association Statement of Policy on Continuing Education. For dentists, this means each provider must complete 30 points of credit every year. Dental hygienists are required to obtain 30 hours of continuing education every year. This organization, minimally, will provide leave with pay for this activity, as well as pay for the tuition cost of most courses. 3. In keeping with the commitment to continuing education by this organization, providers may join additional associations such as the American Association of Public Health Dentists, the Academy of General Dentistry, National Network of Oral Health Access (NNOHA), etc. Payment of dues by Salud for these organizations will be decided on a case-by-case basis and that decision will be based on the appropriateness and usefulness of that organization to benefit Salud and its providers. Also, dental providers (dentists) may take additional continuing education beyond the minimum requirement on a leave with pay basis to a maximum of 50 additional hours. Depending on budget availability, Salud will attempt to pay the tuition cost of most courses. 4. Dental providers are expected to share information gained from continuing education courses with other dental providers. 5. Dental providers will share appropriate CE information with medical personnel. 6. Dental auxiliaries will be provided continuing educational opportunities with in-house training. Continuing education for dental auxiliaries offered outside Salud would be approved depending upon the appropriateness and usefulness of that training to this organization. Additionally, the approval will be decided on a case-by-case basis. 7. CPR training is to be made available to all FTE dental personnel, and dental personnel are expected to avail themselves of this training. Dental Staff is required to maintain current CPR certification.

37 PHYSICAL PLANT Dental Department Facilities, Equipment, Instruments, and Materials 1. Facilities must comply with local safety codes. Salud employs a designated Safety Officer and maintains a standing Safety Committee which continually monitors facility safety and safety procedures. 2. Salud will purchase equipment and instruments of the highest standard and quality affordable. 3. Dental staff is expected to maintain equipment and instruments in the best possible state by following routine maintenance procedures recommended by the manufacturer. 4. The dental department will order and use ADA approved materials, supplies and medicaments in the treatment of patients. 5. The dental department will utilize the most up to date materials possible. 6. Prosthetic procedures will utilize high quality materials from commercial laboratories. 7. Materials and medicaments are not to be utilized after their expiration date. Expired supplies are to be disposed of as indicated by the manufacturer. Options include: -Salud's central supply officer -Salud's pharmacy -Salud's central laboratory -General disposal in compliance with Salud's Waste Management Policy

38 STANDARDIZED MINUTES FORMAT Dental Department

39 MEMBERS PRESENT MEMBERS ABSENT OLD BUSINESS: PLAN DE SALUD DEL VALLE, INC. Dental Department (Your clinic name*) CLINIC STAFF MEETING (OR AGENDA) DATE This is where your would list all business carried over from a previous meeting, when you may have run out of time, things that require follow-up, or when someone was assigned to gather more information and report back their findings. NEW BUSINESS: This area would include any new issues to be discussed. The list of items is usually generated by suggestions from the members. Whenever possible, circulate the proposed agenda prior to the meeting so that everyone can gather necessary materials or background information. This way they can come prepared to participate in the discussion. STANDING COMMITTEE REPORTS: Include reports on all committees that meet regularly. This is really the only way everyone in your clinic can be informed of all the things happening throughout the Salud system. The representative gives the report from your clinic to that committee: EXEC/EXTENDED EXEC TEAM OFFICE MANAGERS SAFETY CQI JCAHO

40 Team Meeting Minutes Dental Department Please note that team-meeting minutes from previous years are filed in the office of the center dental director in the interest of space efficiency.

41 Team Meeting Minutes Dental Department Please note that team-meeting minutes from previous years are filed in the office of the center dental director in the interest of space efficiency.

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