PLEASE ONLY SIGN IF YOU ARE A REGISTERED LICENCED DENTIST OF ONTARIO

To:

Karima Velji

Assistant Deputy Minister

Ministry of Health

Irwin Glasberg

Fairness Commissioner

Office of the Fairness Commissioner

Subject: Addressing Ontario’s Dental Hygiene Labour Supply Shortage by Enabling Practice Opportunities for Internationally Trained Dentists

Dear Ms. Velji and Mr. Glasberg,

On behalf of dentists in Southwestern Ontario, we the undersigned licensed dentists  of Ontario write to express our collective concern regarding the province-wide shortage of Registered Dental Hygienists (RDHs)

This shortage is impacting timely access to oral health care and has the potential to exacerbate health inequalities. This shortage is also burdening dental professionals and arguably the broader health care system.

A System Under Strain

Ontario is currently facing a deepening workforce crisis in oral health care. As highlighted by Statistics Canada and data from the Canadian Dental Hygienists Association and the College of Dental Hygienists of Ontario:

• Ontario holds 43.5% of the nation’s RDHs, yet between 2019 and 2023, only 936 new hygienists entered the workforce.

• Nearly 1 in 4 RDHs are projected to leave the profession within the next five years due to retirement or burnout.

• Over 80% of dental offices report actively recruiting hygienists without the availability of qualified candidates.(As per StatCan)

We applaud the federal government’s initiative to remove financial barriers to care through the introduction of the Canadian Dental Care plan (CDCP). However, the influx of new patients has created and will create an increasing – and sometimes urgent – demand for dental services. If access to oral health care continues to be compromised, those with unmet needs often visit physician and hospital emergency rooms (ER) to try to alleviate their oral health issues. As has long been shown, such physician and ER visits are inefficient and ineffective, as they provide little oral health care and further strain Ontario’s already burdened healthcare system.

A Viable, Inclusive Solution

We propose a practical and immediate solution: Allow internationally trained dentists (ITDs)—of whom over 5,000 are currently in Ontario’s licensure pipeline—to provide preventive and other care (e.g., tooth cleaning and polishing) under a supervised, limited practice license.

These individuals possess an academic and clinical foundation that would make them suitable for such activities, and with structured training approved by the RCDSO, could make an immediate and meaningful contribution to addressing the shortage and existing access to care issues. This approach is already being successfully explored in several U.S. states, including Florida, Massachusetts, Utah, Kansas, Arizona, and Illinois. Here in Canada, the College of Dental Surgeons of Alberta (CDSA) is already launching a pilot program as well. According to the CDSA, “[t]heSupportive Pathway will allow ITDs to work as an Oral Health Care Professional (OHCP) in underserved areas as they progress to NDEB [National Dental Examining Board] certification. ITDs will be issued a restricted registration permit (main register with conditions) and be under the direct supervision of a Supervising Dentist”. 

This program would:

• Align with current government initiatives to integrate internationally educated professionals into their fields.

• Provide new immigrants with meaningful, gainful employment aligned with their qualifications, facilitating cultural and economic integration.

• Reduce the strain on government programs supporting underemployed skilled immigrants.

• Reinforce Ontario’s leadership in equity, diversity, and inclusion within professional regulation.

• Support public health by expanding access to preventive and other oral health care
• Reduce inefficient, ineffective, and costly health care visits for dental problems best treated in dental offices.
Recommendations for Long-Term Stability

In addition to this immediate solution, we recommend that the Ministry of Health and relevant regulatory bodies consider strengthening workforce planning via long-term forecasting and data-driven alignment of training programs with population needs.

Conclusion

We commend the Government of Ontario and the Office of the Fairness Commissioner for their efforts to create an inclusive pathway to licensure for internationally trained professionals. We now ask you to extend that same vision by approving a limited-scope registration model for internationally trained dentists to provide preventive and other oral health care.

This approach would be fiscally responsible, immediately impactful, and in the best interest of public health. We would welcome the opportunity to meet and discuss this initiative further.

Thank you for your time, leadership, and consideration.

Respectfully,

The undersigned dentists of Ontario