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  1:16 pm
Commenter: George Sabol DDS

opposed to changes to specialty advertising regulations

I am writing to express my strong disapproval of the proposed changes to Virginia’s specialty advertising regulations. The proposed changes would only serve to confuse the public about the differences between a  dentist who has at best taken some CE  and a dentist who has spent 2-5 years studying in a rigorous CODA accredited advanced specialty program.  Can you imagine thinking that you scheduled an appointment with a cardiologist only to find out that the treating doctor is a family physician that took some CE and now is advertising that they specialize in Cardiology?   I know that you, members of the BOD, would demand the services of a cardiologist that attended an accredited specialty residency. 

The current Virginia regulations clearly state who can advertise as a dental specialist and insure that a dental specialist has indeed had 2 plus years of continuous advanced education at a CODA accredited program.  The primary purpose of the BOD is protect the health and safety of the public and the acceptance of the proposed changes would be a direct abandoment of your duty to the citizens of the Commonwealth of Virginia. 

The BOD should not be involved in determining what level of education and training qualifies one to practice as a specialist.  The National Commission on Recognition of Dental Specialties and Certifying Boards was recently created by the ADA House of Delegate in October 2017 to do so and  it would be prudent for the BOD to postpone decisions on this matter until the Commission has had adequate time to study this issue and report their recommendations.

Lastly, I fully support the comments and suggestions that the American Association of Orthodontist recently submitted to the Virginia Board of Dentistry.  I trust you will make these comments available for the public and hope that the BOD will postpone any decisions until the National Commission on Recognition of Dental Specialties and Certifying Boards has a chance to report their recommendations.