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
Previous Comment     Next Comment     Back to List of Comments
8/26/18  8:22 pm
Commenter: Josh Hanson

Must be approved to protect the public from harm

As you are aware, there have been multiple successful Federal lawsuits surrounding the protective and political nature of dental specialty recognition. Even the ADA has openly recognized the flaws of this process, even before the first lawsuit in Texas was decided. More and more State Dental Boards are changing their position or are being met with legal action. Furthermore, the American Board of Dental Specialties has emerged as an alternative to the ADA, a trade organization, being the official and sole determinant of dental specialties. The American Board of Dental Specialties mirrors the events that created American Board of Medical Specialties.  It was born out of a determination that a trade group, in their case the American Medical Association, could not and would not determine medical specialties without bias.  Therefore a 3rd party was created as the certifying organization.


Implant dentistry is a prosthetic discipline with a surgical component, and as such you can only be a specialist if you perform both procedures. The AAID (American academy of implant dentistry) has oral surgeons, prosthodontics, periodontist and general dentist as members and ensures the appropriate skills and knowledge is present through the ABOI (American Board of Oral Implantology)

It is false advertising when an oral surgeon or periodontist advertises they are specialist in implants. They only do the surgical part. Without doing and knowing the prosthetic part you cant be a specialist in implants. Is it simply not possible.

Of course all the specialist here are opposing it. They have their own reasons for their opposition, and the public interest and welfare it not one of them. Having a recognized implant specialty through the ABOI would mean they finally would not be able to advertise as implant specialist without taking the credentialing exam and presenting cases form start to finish. Again implants is a prosthetic discipline with a surgical component.

In my daily practice I see implants placed poorly by both general dentist and specialist alike. Many residency programs have oral surgeons or periodontist place less than 50 implants. Does that make you a specialist just because you did a residency, never restored anything prosthetically and managed to put 50 implant or less in bone. That is the easy part. And what about dentist that graduated specialty programs before implants even came around. Do you automatically become an implant specialist just because you did a residency but never was taught implants.

The same applies to the American Board of General Dentistry (ABGD) so I strongly suggest they should be included as well. They have not been mentioned yet. They already have federal approval since they are recognized by all the armed forces. If you become a diplomate of the American Board of General Dentistry in the armed forces you automatically get a pay increase because you are considering a specialist in your field – general dentistry just like internal medicine. They get a pay increase just like the other already ADA approved specialties. This has been a standard for over 30 years despite what the ADA says. A legal no mans land as they already are federally recognized for 30+ years as a specialty certification, yet the ADA does not endorse the ABGD. By not including them would create a legal problem with federal vs state law.

The changes does not suggest getting rid of a certifying body. It just allow us to mirror medicine. You would have a general dentistry specialist like in internal medicine. You would have a specialist in implants, anesthesiology etc. The resolution does not allow dentist to advertise being a prosthodontist, endodontist, oral surgeon, orthodontist etc. without proper training.

The Virginia Board of Dentistry has the obligation to protect the public from harm and by permitting Certified doctors to advertise themselves accordingly will do exactly that. Allowing specialists to shut this rule change down will do just the opposite.