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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8/27/18  11:00 am
Commenter: Dr. Adam Hogan DDS

Strongly in favor

Dear Sir or Ma'am, 

Those opposed to this amendment are either unaware of the education and certification process of the AAID/ABOI and/or they reap financial benefit from the current "standards" of specialty care.  Those standards are adopted by the trade organization known as the ADA.  While I support the ADA and some good regulations and recommendations to standardize dentistry and protect the public.   We also recognize the ADA as a top-heavy organization run by current "specialties" with financial incentive to continue the old system.   A supreme court has recently ruled that the ADA does not have the authority to regulate and define specialties in dentistry, that the ADA is hindering the first amendment and that the leadership of the ADA is overwhelmingly specialists with financial incentive to continue their old system.    

When I was a general dentist coming out of the Navy, I researched specialty programs.   With strong affinity and skill for surgery and desire to learn more, I called several programs and spoke with many residents in periodontics and oral surgery.   I heard a unanimous, cohesive and synonomous cry from residents whose programs touted the placement of 25, 50 or even 75 implants over 2-3 years.   But in reality, they barely placed half that number and got credit for other implant placement simply by watching their fellow residents place them while they took credit.   In contrast, I found a mentor who placed 50 implants per month.  I studied under him.  I took the AAID Maxi course.  I studied, submitted cases for review and passed my Associate Fellow exam.  I studied, took written exams, submitted more cases and sat for oral boards to pass my Fellow exam and Diplomate of the ABOI.   Now I teach dental implants to colleagues and am a board examiner for the AAID.   My training and experience justifies my ability to be called a "dental implant specialist" far more than a resident who just placed (and did not restore) 20 or 40 implants over 3 years.   

One has to consider that there are non-traditional and sometimes better ways that dentists seek specialty status.  Our legislative branch should recognize the hard work and achievements of our general membership.   

If the Virginia Board of Dentistry is not already aware, the AAID, ABOI and ABDS have already won supreme court cases in several states.   This is a first amendment right issue.   Unless the VA Board wishes to spend a substantial amount of money and time fighting a hopeless Constitutional fight that California, Florida and Texas have already lost, then I would recommend that they adopt an amendment and allow specialty advertising by those with the proper education and credentials.