Agencies | Governor
Virginia Regulatory Town Hall
Department of Health Professions
Board of Dentistry
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
Action Amendment to restriction on advertising dental specialties
Comment Period Ends 9/5/2018
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8/13/18  4:50 pm
Commenter: Dr. Robert A. Strauss


I stand opposed to this ammendment. Specialty recognition requires that the specialty be UNIQUE and taught at a higher level. This ammendment would allow self-appointed "specialties" which are neither unique (dental implants, currently performed well by multiple different groups and therefore, by definition, not unique) nor regulated (based on the ABDS rules one could be a speciailist just based on CE only with no formal training).  This loose set of definitions would lead to every practitioner self-describing themselves as specialists. It would seem to me that this would not be in the interest of protecting the public, the primary purpose of the Board.

As to CODA recognition for non-specialites (such as anesthesia and oral medicine) it should be recognized that ANY group can request CODA recognition, they do not have to be a specialty. Just because a group has requested and paid CODA for recognition, that does not indicated that that group is a specialty (ie it has not met the criteria of uniqueness and advanced level of training). ADA specialties are so designated because they have proven that their area of practice is NOT performed by other practitioners (eg maxillofacial surgery, advanced perio, public health, etc) and is taught in a structured advanced training program.

Thanks for your attention and all you do for our profession.