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Virginia Regulatory Town Hall
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Department of Health Professions
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Board of Dentistry
chapter
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
Action Amendment to restriction on advertising dental specialties
Stage NOIRA
Comment Period Ends 9/5/2018
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8/6/18  11:41 am
Commenter: Douglas H. Mahn, DDS

Opposing Removal of Restrictions on Dental Specialty Advertising in Virginia
 

Date:    August 06, 2018

 

To:       Virginia Department of Health Professions

Re:       Opposing Removal of Restrictions on Dental Specialty Advertising in Virginia

Dear Board Members,  

            I was recently informed that the Virginia Board of Dentistry proposed removing restrictions on specialty advertising.  I was informed that this proposal was in response to lobbying from dental groups that are not affiliated with the American Dental Association (ADA).  Removing restrictions on dental specialty advertising places the public health at risk.  Let me briefly explain why.

            There are currently 9 ADA recognized specialties.  To achieve recognition as a ADA recognized specialist, dentists must complete years of training under strict guidelines of their parent specialty organization.  This  includes intensive specialty literature review, supervision of the treatment aspects of their specialty and examinations.  It has been my experience that the general public is not well informed about some of the dental specialties and the intensive training they receive.

            An example of this  problem  is seen with the dramatic rise in the number of dentists placing dental implants with limited training.  This limited training would allow them, however, to advertise as having specialty training if restrictions to advertising were removed.  Removing restrictions, therefore, would place patients at increased risk for an invasive surgical procedures that could have irreversible consequences.   A study published in the Journal of the American Dental Association in 2014, Outcomes of implants and restorations placed in general dental practices, concluded that "implant success rates in general practices may be lower than those reported in studies conducted in academic or specialist settings".  It would seem prudent to make sure that the public  is not confused by advertising that appears to place the limited training of some dentists on the same level as an ADA recognized specialty program.

            As a peridontist, I can tell you that the American Academy of Periodontology is very concerned about the considerable rise in cases of implant disease and other complications  in the past few years.  I have found many of the implant problems  that I see are due to poor management of the implant site by dentists with limited training and were avoidable.

            The problem of dentists advertising as having specialty training without having attended an ADA recognized specialty program affects all of the dental specialties and the public health.  In the best interests of the public, I strongly urge you to oppose removing restrictions on specialty advertising.  Failure to do so, will lead to unnecessary harm to our patients.

Respectfully,

Douglas H. Mahn, D.D.S.

Periodontist, Manassas, VA

 


8/6/18  5:28 pm
Commenter: Rod Rogge, DDS

Dental Specialty Designation
 

I would like to voice my strong opinion against allowing non-residency trained dentists to advertise and indicate to the public that they have specialty training and certification. 

The American board of dental specialties is a unofficial organization that claims to have certification in specialty credentials.  The “requirements” that this so-called board pretends to be valid are laughable in comparison to the requirements by the ADA Commission on Dental Accreditation.  Legitimate, state-authorized licensure and credentialing and accreditation developed in the 18th century to protect the public from frauds and charlatans.  Our system of state boards and licensing and accreditation of true training programs are a continuation of that process, which has resulted in a very high standard of dental and medical care in this country.  Allowing dentists to claim specialty designation when they have only a fraction of the clinical and didactic training demanded of fully trained specialists is a terrific abuse of  public trust.  It is your responsibility in the Department of Health to ensure that our citizens receive the best possible care by the best trained practitioners.  Bowing to the pressure of threatened lawsuits and other assaults on dental professionalism helps no one.  If anything, as technology continues to advance at a rapid rate, the requirements of training accreditation will need to increase, not decrease.  Please shut the door on this outrageous proposal to make specialty designation meaningless.  Better yet, shine a light on this non-transparent organization that aims to destroy the quality of the dental profession from within, and let the public know how reckless and irresponsible and financially unprincipled their movement has become.


8/8/18  9:04 am
Commenter: Elizabeth A. Alcorn, DDS

Advertising of Dental Specialities
 

I do not support changing the current regulation for advertising of dental specialties.  There is too much financial pressure on dentists that is leading too many to push the limits of their training to perform treatments that should be performed by a specialist.

Patients have no way of knowing the skills of the dentist they see and by keeping the current regulation as it is allow a small but important protection to the patient.


8/8/18  9:51 am
Commenter: Joshua Fein, DDS, MS

Strongly opposed
 

I would like to add my opposition to the excellent posts already listed. 

Dental specialty training is a rigorous multi-year undertaking that leads to clear improvements in outcomes and most importantly, improved safety for our patients.  The public cannot be expected to know the difference between a properly trained specialist and one advertising as such with no formal training.  This regulation change would lead to widespread confusion and misinformation that would end in harm to patients and would discourage graduating specialists from coming to Virginia for fear that their hard earned specialty certificate would be undervalued. 

This proposal is outrageous, irresponsible, and harmful to the people of Virginia. 

 


8/8/18  10:10 am
Commenter: Natalie Powell

Strongly Opposed
 

I also am strongly opposed to this proposed change. All specialists go through years of advanced training and there is a difference in the  quality of care and management of complications provided by the education learned over years of advanced training versus a few weekend courses. 


8/8/18  10:15 am
Commenter: Robert LeNoir, Brown Reynolds Snow LeNoir Dentistry

Strongly opposed
 

This opens up the ability for the public to misled and to create a distrust among the public for the profession.  


8/8/18  10:44 am
Commenter: Nicholas Ilchyshyn, DDS

Oppose Amendment
 

Having practiced nine years as a generalist and over 34 years as a periodontist, the proposed amendment would not serve the public well. The rigorous standards of the ADA Commision on Dental Education cannot be supplanted by other competing entities aimed at conflating the definition of a specialist. 


8/8/18  12:05 pm
Commenter: Mark R Zemanovich, DDS

Strongly Oppose!
 

The fact that this proposed change is even up for consideration is disheartening and down right scary.  The practice of dentistry is complicated (and has become much more complicated over the years) and current 4 year dental education does an overall fair job at best for preparing dentists to be competent at even the most basic skills and treatment planning.  Allowing undertrained practitioners to claim specialty status will, without a doubt, lead to patient harm and continue to degrade the profession into the future.   I strongly oppose this change!


8/8/18  12:17 pm
Commenter: Frank Grogan DDS

Strongly Oppose Amendment to Advertising Dental Specialties
 

As a general dentist for 38 years, I have been impressed with the consistent quality of care provided by those dentists practicing in the recognized dental spcialties.  The term 'Specialty' implies care that is more focused in a specific area, provided by a dentist that has received more education and clinical experience in order to meet a prescribed and tested level of patient care.  The dentist has been recognized by peer review for excellence in a specific area of dentistry.  If the proposed Amendment is put in place, most of the general public will continue to assume that the professional definition of a dental specialist has not changed; but it will have completely changed.  This will take the dental profession more into the area of becoming an occupation and less of a profession that exhibits self control.  Passing this Amendment is not consistent with the Boards duty to protect the public from inferior dental care.  Thanks for consideration of my position.

Frank Grogan DDS


8/8/18  1:49 pm
Commenter: Mayer G. Levy, DDS

Deleting from section 80 requirement to be appropriately recognized: definite opposition. It is not
 

Type over The Board was established to enhance the professionalism of Dentistry, not to demean it. I strongly oppose this change. text and enter your comments here. You are limited to approximately 3000 words.


8/8/18  3:53 pm
Commenter: Matthew Stephens, DDS, Dental Associates

Opposed
 

The specific prohibition should remain. 18VAC60-21-80 G is well written to keep both our paitents and practitioners safe. A true specialist has earned the right to advertise as such and as a profession we should hold that right in high regard. 


8/8/18  9:44 pm
Commenter: Chris R. Richardson, DMD, MS

Oppose this potential change
 

It is truly disheartening to see that this regulatory action is being considered.  The American Board of Dental Specialties has hired an exceptional attorney to make every effort to move this through each state.  The threat of legal action has made this even more distasteful.  To be honest, the legal threat is the only thing moving this forward.  If you review the CODA requirements for specialty training for the existing dental specialties, they far outweigh the tremendously minimal requirements of the ABDS recognized specialties.  In fact, their requirements are roughly equivalent to one month of a 3-5 year specialty program. Imagine going to see a dentist thinking that they are specialty trained and you find out it is a very watered down version, if that. 

You should take the time to read the dissent opinion by Judge James Graves of the 5th Circuit Court of Appeals.  This legislation was approved from a fear of First Amendment Rights regarding Freedom of Speech.  This is ridiculous and Judge Graves states in his opposing opinion that "Misleading Speech" is not covered under the Rights of The First Amendment.  Those that would claim specialty status based on a weekend continuing education course are in fact misleading the public regarding their abilities.  Sadly, the public will not know the difference.  The Virginia Board of Dentistry is charged with protecting the Commonwealth's public from an oral health perspective.  This legislation does not live up to that charge.  Please don't misunderstand, the current regulations in place are very well done.  A dentist may claim that his/her practice is limited to a certain arena, however, they must also state that they are providing this limited scope of care as a  general dentist.  

The ADA recently established The ADA Commision on Specialty Recognition.  The first meeting of this commision was in May this year.  Interestingly, The commission is made up of ONE specialist representative from the nine ADA recognized specialties and NINE general dentist. A very fair representation.  These general dentist see the value in recognizing specialist for what they bring to patient care with regards to skills, predictability, long term prognosis, patient management, and ability to treat difficult problems.  My advice to the Virginia Board of Dentistry is to wait and see what this commission decides and how they will, without conflict of interest, position the recognition of specialties in dentistry.

Finally, this legislation will be a heavy burden for the young clinicians who seek to become the most well-educated specialists in the field of Dentistry.  These young people have invested 4 years of college, 4 years of dental school training, and 3-6 years in an ADA recognized and CODA accredited Specialty Training Program.  Imagine spending 11-14 years of your life to become the very best and at the end of the day, anyone else who took a weekend course can claim specialty status.  Not to mention the Time, Energy, and Stress related to that training, but also the financial commitment.  Student debt is astounding and for a specialty trained student,  the current graduate debt-load is anywhere from $350,000.00-1,000,00.00 dollars. YES, you read that correctly. Please make the correct ETHICAL and MORAL decision regarding this proposed legislation.  PLEASE DO NOT make this change to Specialty Advertising in Virginia.  If it helps you to know, tremendous strides in defeating this have occured in IOWA, NEW JERSEY, and NORTH CAROLINA. I appreciate your attention. 

 

 

 


8/8/18  10:52 pm
Commenter: Adam Ta, DDS

Strongly Opposed to removing restrictions on specialist advertising
 

It is pretty absurd to think that there is any justification for misleading the public and allowing a general practitioner (or even for a specialist advertising outside of their specialty) to falsely advertise expertise in a specialty field without graduating from an accredited residency training program.  Patients, their families (parents), and even their insurance carriers are paying specialist fees, investing their time, money, and trust into that dental practitioner, with a certain expectation for level of care and competence.  It's practically fraudulent to market and advertise for patients to come receive dental care at an orthodontic practice and not be seen by an orthodontist, or go to a pediatric dentist and not see a pediatric dentist.  If a general practitioner wants to offer those services outside the scope of their typical training, I think that's up to them and their comfort level, but they certainly should not be able to mislead the public and advertise as a specialist.  Would you be upset if your brought your child with heart disease to a cardiology practice to be evaluated by a non-cardiologist?  Or would you trust the care of your loved one undergoing chemotherapy at an oncology practice to treatment by a non-oncologist?  Seems obvious to me, but if we allow this type of deceit and misinformation to become commonplace, the already skeptical public will lose even more trust in their healthcare practitioners.


8/9/18  11:20 am
Commenter: Shravan Renapurkar

Strongly oppose removal of restrictions
 

Recognition of a specialty should be under the guidelines and authority of a state/federal agency and not a subjective matter. I strongly oppose removal of restrictions on advertising as a specialist of any sort. 


8/9/18  8:53 pm
Commenter: Jonathan L Wong, Coastal Pediatric Dental & Anesthesia

A Mislead Uproar - How to make specialties and specialists less biased and actually carry weight
 

While I support the ADA and the VDA, there have been some egregious behaviors that have occurred in specialty recognition that few seem to have a complete understanding of.  In 2012, dentist anesthesiologists applied for specialty recognition with the ADA.  This was not the first attempt at specialty recognition. However, during this attempt, the ADA, CODA, and the Board of Trustees agreed that all specialty requirements were indeed met. Nevertheless, the final phase in approval was a vote by the ADA House of Delegates.  At that time, emotion and politics outweighed logic. A campaign was launched stating that anesthesia and sedation would no longer be allowed by anyone other than dentist anesthesiologist, insurance would not pay for sedation and anesthesia unless it was provided by a separate anesthesiologist, and that dentist anesthesiologist were unsafe in their practice of itinerant anesthesia. Websites were launched saying anesthesia was a right for all dentists, such as www.anesthesiaforall.org. AAOMS and its oral surgeons were single handedly able to prevent specialty recognition. In addition, standard meeting protocols for the House were allowed to be breached so that the oral surgeons could “have the floor” to express why the specialty should be denied.

As you are aware, there have been successful Federal lawsuits surrounding the protectionist and political nature of the above described proceeding.  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.

The ADA, in an attempt to rectify their self-acknowledged bias and systematic flaws, unanimously approve House Resolution # 65 and created a new Council for Specialty Recognition.  House Resolution # 65  states, “A dentist may ethically announce as a specialist to the public in any of the dental specialties recognized by the American Dental Association including dental public health, endodontics, oral and maxillofacial pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics and dentofacial orthopedics, pediatric dentistry, periodontics, and prosthodontics, and in any other areas of dentistry for which specialty recognition has been granted under the standards required or recognized in the practitioner’s jurisdiction, provided the dentist meets the educational requirements required for recognition as a specialist adopted by the American Dental Association or accepted in the jurisdiction in which they practice. Dentists who choose to announce specialization should use “specialist in” and shall devote a sufficient portion of their practice to the announced specialty or specialties to maintain expertise in that specialty or those specialties. Dentists whose practice is devoted exclusively to an announced specialty or specialties may announce that their practice “is limited to” that specialty or those specialties. Dentists who use their eligibility to announce as specialists to make the public believe that specialty services rendered in the dental office are being rendered by qualified specialists when such is not the case are engaged in unethical conduct. The burden of responsibility is on specialists to avoid any inference that general practitioners who are associated with specialists are qualified to announce themselves as specialists.”

Although the petition brought by Dr. Mayberry is being described by others as  an attempt to circumvent the ADA and force the Virginia Dental Board to accept the American Board of Dental Specialties (ABDS), this was not what was proposed in the regulatory change. Instead § 54.1-2718 would have remained unchanged and the regulations changed such that the "specialist" must not advertise an "unsubstantiated claim."  I had proposed that the regulation be changed to reflect the House Resolution # 65 and get rid of the reference to the antiquated Ethical Code that the regulation was based on.  The Dental Board did not haphazardly adopt Dr. Mayberry’s petition or ADA House Resolution # 65.  Instead, it was well considered and thoroughly evaluated by Virginia legal counsel and announced in this fashion.  Perhaps it is more prudent to recognize both the ADA and ABDS as authorities, as there are inherent flaws that have yet to be proven rectified in the ADA's Specialty Recognition.

Having said all of the above, I also understand the voiced concerns of patient safety and the risk of dentists misleading their patients. However, it appears that many dentists are advertising as cosmetic dentists, sleep dentists, sedation dentists without much concerns. However, when someone whom the State has recognized as having true advanced training required to obtain a general anesthesia permit attempts to promote their services, it is “unethical and illegal.” In addition, barring the public from knowing what advanced training someone has, can actually be detrimental to patient safety.  Why should patients not know that they have access to dentist anesthesiologists? Why should patients have to settle for a dentist that went to a weekend sedation or anesthesia course?  Why does the public not know about anesthesia providers in dentistry? Basically, it is because of these antiquated regulations. A great example of how this protectionist mindset can backfire is the recent media storm involving Dr. Goyal in AZ, whom was able to falsify anesthesia credentials. One of the reasons this is was able to occur was because there is not official recognition by the ADA and their state components of the CODA accredited anesthesia training programs as anything more than general dental training – much like a CE course a dentist may purchase and attend.

I hope that this letter may help elucidate the complexities that surround this issue. In full disclosure of the above, I am a dentist anesthesiologist by training.  I have 5 years of post-graduate training in hospitals at CODA accredited and GME accredited residencies.  However, I am a general dentist with the requisite training for a State recognized anesthesia permit.  My own society’s parameters of care restrict us from practicing dentistry while providing deep sedation or general anesthesia, therefore I must limit my practice to anesthesia, yet I am required to say I am a general dentist and not an anesthesiologist.

 

Thank you,

 

Jonathan Wong, DMD

Diplomate, American Dental Board of Anesthesiology *

Diplomate, National Dental Board of Anesthesiology *

Fellow, American Dental Society of Anesthesiology *

*Anesthesia services provided by a general dentist


8/9/18  9:49 pm
Commenter: Jonathan L Wong, Coastal Pediatric Dental & Anesthesia

A common theme among dissenters
 

After thoroughly reading the dissenters' opinions, there seems to be a theme. All of them seem to suggest that advanced CODA accredited training should give specialty recognition.

Why is it then that graduates of CODA accredited residencies in Orofacial Pain, Oral Medicine, and Anesthesia are forced off the ADA list of 9 exclusive specialties?  These graduates face the exact burden that was discussed by Dr Richardson as being unfair.

The problem with the proposed text is the legal arguement of what would constitute an unsubstantiated claim? Does this need to be defined further?  This is part of what the American Board of Dental Specialties (ABDS) has done, mostly because CODA accredited graduates were being excluded from what is being argued as the definition of a specialist.

The one exception to this might be Implant Dentistry, which from my understanding has fellowship programs, however they are not CODA accredited.  However, the ABDS states, "Certifying boards seeking Dental Specialty must require a minimum of two (2) full-time, formal, advanced educational programs that are a minimum of two (2) years in duration and are presented by recognized educational institutions:  Any alternate pathway must demonstrate it is equivalent with didactic, clinical and completed cases to their two-year post-graduate training program."


8/10/18  9:19 am
Commenter: Lillie Pitman, DMD

Strongly Opposed
 

It is truly disheartening to see that this regulatory action is being considered.  The American Board of Dental Specialties has hired an exceptional attorney to make every effort to move this through each state.  The threat of legal action has made this even more distasteful.  To be honest, the legal threat is the only thing moving this forward.  If you review the CODA requirements for specialty training for the existing dental specialties, they far outweigh the tremendously minimal requirements of the ABDS recognized specialties.  In fact, their requirements are roughly equivalent to one month of a 3-5 year specialty program. Imagine going to see a dentist thinking that they are specialty trained and you find out it is a very watered down version, if that.  This does not protect the public, which is the goal, isn't it? 

You should take the time to read the dissent opinion by Judge James Graves of the 5th Circuit Court of Appeals.  This legislation was approved from a fear of First Amendment Rights regarding Freedom of Speech.  This is ridiculous and Judge Graves states in his opposing opinion that "Misleading Speech" is not covered under the Rights of The First Amendment.  Those that would claim specialty status based on a weekend continuing education course are in fact misleading the public regarding their abilities.  Sadly, the public will not know the difference.  The Virginia Board of Dentistry is charged with protecting the Commonwealth's public from an oral health perspective.  This legislation does not live up to that charge.  Please don't misunderstand, the current regulations in place are very well done.  A dentist may claim that his/her practice is limited to a certain arena, however, they must also state that they are providing this limited scope of care as a  general dentist.  

The ADA recently established The ADA Commision on Specialty Recognition.  The first meeting of this commision was in May this year.  Interestingly, The commission is made up of ONE specialist representative from the nine ADA recognized specialties and NINE general dentist. A very fair representation.  These general dentist see the value in recognizing specialist for what they bring to patient care with regards to skills, predictability, long term prognosis, patient management, and ability to treat difficult problems.  My advice to the Virginia Board of Dentistry is to wait and see what this commission decides and how they will, without conflict of interest, position the recognition of specialties in dentistry.

Finally, this legislation will be a heavy burden for the young clinicians who seek to become the most well-educated specialists in the field of Dentistry.  These young people have invested 4 years of college, 4 years of dental school training, and 3-6 years in an ADA recognized and CODA accredited Specialty Training Program.  Imagine spending 11-14 years of your life to become the very best and at the end of the day, anyone else who took a weekend course can claim specialty status.  Not to mention the Time, Energy, and Stress related to that training, but also the financial commitment.  Student debt is astounding and for a specialty trained student,  the current graduate debt-load is anywhere from $350,000.00-1,000,00.00 dollars. YES, you read that correctly. Please make the correct ETHICAL and MORAL decision regarding this proposed legislation.  PLEASE DO NOT make this change to Specialty Advertising in Virginia.  If it helps you to know, tremendous strides in defeating this have occured in IOWA, NEW JERSEY, and NORTH CAROLINA. I appreciate your attention. 


8/11/18  1:58 pm
Commenter: Thanos Ntounis DDS,MS

Strongly opposed to the proposed Specialty Advertising proposal.
 

It is trully disheartening to see such proposed action being discussed. In the interest of the patient population of Virginia, I oppose the proposed change. It is misleading and dangerous to the public for a practitioner to advertise as specialist in any area without the necessary formal training. Residency programs that are CODA- accredited provide the necesary Knoweldge, Skills AND attitudes that constitute a specialist! 

In case that this proposed change goes through, I am concerned that the Virginia Dental Board will face significant increase in patient complaints and possible malpractice lawsuits that will undermine the public's trust to Doctors of our state. 

As a young father, I am considering a scenario where my child would need specialty care. It is my right to trully know if the Doctor has gone through rigorous accredite training prior to claiming he is a specialist! I am sure you feel the same. I urge you to oppose the proposed change on Specialty advertising. 

 


8/13/18  4:50 pm
Commenter: Dr. Robert A. Strauss

Opposed
 

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.


8/13/18  8:18 pm
Commenter: Sorin Uram-Tuculescu, DDS, MS, PhD, VCU School of Dentistry

Opposed
 

Thank you for the opportunity to voice my opinion.

It appears to me that the Amendment to Restriction on Advertising Dental Specialties would introduce the risk to de-quantify the effort spent in order to become a specialist. It is likely that the amount of sacrifice - including time, effort, expenses, declined opportunities - currently paid by a resident in one of the recognized specialties is in danger to dissipate as soon as one can call themselves a specialist after attending a less regulated program. The gain in knowledge and skills over a number of years, that currently characterizes a formal specialty training program cannot be matched by expedited training, regardless of the granting agency. For the best interest of the public, please reject the Amendment to Restriction on Advertising Dental Specialties.


8/14/18  7:29 am
Commenter: Lloyd Vakay

Dental Specialists
 

I believe it is wrong to mislead the public on the professional credentials of non certified dentists by allowing them to hold themselves out as specialists.


8/14/18  9:23 am
Commenter: Christabel Sweeney DDS

Oppose this change
 


8/14/18  6:14 pm
Commenter: Pandora Wojnarwsky

Strongly oppose
 

I strongly oppose this change.


8/14/18  10:12 pm
Commenter: Jason Margolis

Strongly opposed
 

Strongly opposed to this amendment. To pass this amendment will allow non-specialists to pose as an individual which would be misconstrued for someone with advanced formal training. WE as healthcare providers took an oath to "do no harm". This amendment allows those individuals seeking to advertise themselves as something they are not, which in turn would undoubtedly lead to doing harm to the public. 

 

This amendment will only allow less regulation, devalue our credibility as a healthcare profession and increase the risk to the general public. As a whole, our profession is upstanding and work together to maintain the highest standard of care toward our patients as a team approach, working side-by-side with the general dentists and their respective specialists. 

 

The few individuals whom want to mislead the general public by advertising a specific skill by which they are not formally trained is deceitful, immoral and unethical. I challenge those individuals to consider re-entering the formal educational process of an ADA CODA-accredited specialty to obtain the rigorous formal training and better their knowledge and skill to provide the highest standard of care as opposed to modifying this amendment to a play on words. 

 

Thank you for your consideration in maintaining the integrity of our dental healthcare standards for the general publics safety.


8/14/18  10:14 pm
Commenter: Mariano Polack

Strongly opposed
 

It is a disservice to the public and the profession to allow dentists that have not attended an ADA accredited specialty program to advertise as specialists.  Would anyone choose to have their kidney removed by a physican who is not a surgeon, but advertises as a specalist in surgery? How is this protecting the public?

All dentists should be allowed to perform all procedures they are legally allowed and trained to do, but not to advertise as something they are not. Depending on the specialty program, 400 hours of training at an accredited insitituion are covered in just the first couple of months. Equating 400 hours of training to 3, 4 or more years of full time residency training diminishes the profession and confuses the public.


8/15/18  8:48 am
Commenter: Gavin Aaron DDS, MS

Strongly opposed
 

As a lifelong Virgnian who lives and practices in Roanoke, I am surprised and taken aback by this outlandish amendment.  I can't believe the proposed amendment has made it this far.  What ever happened to common sense?  If a law/rule change makes things less safe for the public, common sense would tell you that's bad, right?

So now Virginia is willing to change the law to make dental care potentially more dangerous to the public because a lobbying group paid enough money? Is that what this is really about?  Because I don't see how any argument to allow non-ADA trained dental specialists to promote themselves as such would stand on its merits alone. Is that what this is really about?  By allowing this amendment to pass, the  Virginia legislature is basically saying to the dentists that relatively new fringe organizations have as much clout as the ADA, as long as the price is right.  The ADA, the American Dental Association, has guided the educational standards for dentists and dental specialists since the beginning.  

What's next?  A mall security organization getting the laws changed so security guards can patrol our neighborhoods in cop cars?  

The higher-ups may think these changes in dentistry may not make an impact, but dental specialists - as well as general dentists - see the aftermath of inadequately trained dentists performing advanced dental procedures all the time.  And while not life-threatening, the poor outcomes can literally change an individual's appearance, oral function, and self-esteem for the rest of his/her life.  Not to mention the physical pain and financial impact.

What gives me pride as a resident of this state is the conservative governing principles and resistance to potentially dangerous changes in state law. I realize that my comments may come across as unprofessional, but I don't know how else to convey my passion against this completely unacceptable amendment.

 


8/15/18  1:09 pm
Commenter: John Unger, VCU School of Dentistry

Strongly Opposed
 

I am strongly opposed to the proposed amendment as I believe it would mislead and confuse patients.  The current guidelines provide patients with the assurance that the specialist they would see is educated and trained in the speciality and has completed a rigorous course of study that is subject to periodic reviewed by the Council on Dental Accreditation.  We owe our patients nothing less.   


8/16/18  6:55 am
Commenter: Herb Hughes DDS

Protect the public and oppose the amendment
 

 

I strongly oppose the amendment to restriction on advertising dental specialties for the simple reason is that it puts the general public at risk. It is our duty to create and maintain rules and regulations that have the philosophy of “Do No Harm”. Throughout my 32 year career, I’ve seen numerous cases where non-specialists have attempted to treat patients with clear aligners only to find out after the fact that it was improperly diagnosed and treated. I recently had an orthodontic transfer case from Houston where a general dentist spent over 3 years and 13 refinements in an attempt to correct an anterior crossbite only to find out that she had failed to make the proper diagnosis and as a result, the patient is in the process of having orthognathic surgery in order to establish a normal bite relationship. Protect the public and oppose the amendment.


8/16/18  7:31 am
Commenter: Scott Berman

R u kidding me?? Why would u want to mislead the citizens more than current advertising does? WTHeck
 

8/16/18  7:32 am
Commenter: Nitika Mittal DDS MSD

Opposed
 

This eliminates the need for specialists across the state. It would destroy the careers of thousands of individuals, causing them to become bankrupt, leave the state of Virginia, and thus would reduce access to care. Specialists are there for a reason. They have gone through extra training. Have paid for it. Have taken board exams to qualify to call themselves specialists. It’s not  a title which is self appointed. youre reducing the specialty practice to a dog and pony show. 


8/16/18  7:41 am
Commenter: Elizabeth Jones

Strongly opposed
 

Strongly opposed. This will lead to patient/consumer misunderstanding and confusion in making informed decisions and consent. 


8/16/18  8:18 am
Commenter: Jeffrey Rothman DDS

Strongly Oppose, Please protect our patients!
 

False and misleading advertsing leads to mistreatment and mistrust of our patient population.  Lets keep honesty and professionalism in our field of dentistry.  Dentist are trusted members of our community, please don't change this standing by passing such a flawed amendment!

 


8/16/18  8:22 am
Commenter: Dr. Justin Hughes DDS, Hughes Orthodontics

Strongly Opposed. Protect the Public
 

This ammendment allows for the deception of the public into thinking they are in the hands of a specialist when in reality they may be seeing someone who took a weekend class at a Holiday Inn. The standard and quality of care delivered to the public will be lowered by this ammendment as anyone and everyone can claim a "specialty" designation without proper credentialing and training. Please vote NO to this ammendment. 


8/16/18  9:15 am
Commenter: Swathi Reddy

Strongly Oppose
 


8/16/18  9:42 am
Commenter: Robert A Miller DMD

Strongly oppose to reduce confusion
 
In this era of DIY, big budget TV advertising, we must protect our public, not just as dental specialists but also general dentists. We should be clear in advertising our practice types (if specialists, state what we do.) If a general dentist does a specialty without attending a formal residency, it confuses the public when they read an ad and conclude "my dentist does both" (pick any specialty!)

8/16/18  9:50 am
Commenter: Elvi Barcoma DDS

Strongly opposed
 


8/16/18  9:53 am
Commenter: Kevin Brewer, Alexandria Oral Surgery

Strongly opposed
 

I am strongly opposed to the proposed ammendment. There is already a great deal of confusion among the public regarding the organization of dentistry in the US. This ammendment would only further muddy the waters. General practicioners who seek to limit their practice to a given area of dentistry should be required to prominently disclose that they are a general dentist with a limited practice. 


8/16/18  10:12 am
Commenter: Syed Kalim Hussaini, DDS

Strongly Opposed
 

I strongly oppose this ammendment. I believe this will create a lot of confusion for the general public when it comes time for them to decide what their healthcare options are. They are confused already with everything that is out on the internet and this will only make it worse.


8/16/18  10:38 am
Commenter: Dr. Gerardo Guajardo

Strongly opposed
 


8/16/18  10:40 am
Commenter: Luis Gutierrez

Oppose this change
 

This change will mislead patients and hurt the dental profession. Allowing general dentists to call themselves “specialists” will not provide any benefit to the public.


8/16/18  10:44 am
Commenter: Hyue K. Kwon, DDS, PC

Strongly oppose. The public need to know who are real specialists for their dental care
 


8/16/18  10:47 am
Commenter: Elijah Wang DDS MS

Opposed
 

Strongly opposed.


8/16/18  10:51 am
Commenter: Brandon Johnson DMS MS

Strongly Oppose
 

It’s in the public’s best interest to create honest, transparent demarcation between dental health professionals regarding  training/certification. The public has no other easily accessible resource to differentiate between providers and it could cause confusion and mistrust between patient and provider.


8/16/18  11:03 am
Commenter: Thomas Waldrop, Professor, Director Graduate Periodontcs, VCU

Amendment to restriction on advertising dental specialties
 

I strongly oppose this action as it is miss leading to the public and and insult to those that have trained in those specialties recognized by the ADA and specialty boards and to patients that seek out the expertise of specialist for a specified treatment. In medicine and dentistry physicians and dentist seek out specialty training to become experts in a specific field and patients seek out those specialties knowing they are getting highly trained experts in a specific modality. I would ask those who are in favor of this amendment "would you go to a physician who took a weekend course on heart surgery do your by pass procedure?" I would think not. If we as dentist go down this road to dilute the word specialist as it was meant to mean in dentistry and medicine we are doing a great diservice to the public. As health care provides our primary mission is to serve the public and provide the highest level of care. Having been in education for over 35 years and trained over a hundred residents and given multiple surgical CE to general dentist I can ensure you that the level of training differs. Hence, the care provided to the public differs. I would not be opposed to someone  doing a specific procedure if they have had good CE but I do oppose someone calling themselves a specialist unless they have had advanced training in an ADA accredited program. The ADA has established the The ADA Commision on Specialty Recognition and I would suggest Virginia consider the results from this governing body to see what it decides.  I would hope VIriginia has the ethical and moral fortitude to make the right decision on this proposed legistration and not make the change to Specialty Advertising in VIrginia. Thank you for the opportunity to comment on this proposal.


8/16/18  11:04 am
Commenter: David Lee DDS MS

Strongly opposed
 

Strongly opposed


8/16/18  11:10 am
Commenter: Jordan Katyal, DMD

Strongly Opposed
 

I am strongly opposed to this proposition, which would grossly misinform the public about the difference between a true specialist and one who has not undergone formal additional training in order to obtain specialist credentials. 

 


8/16/18  11:14 am
Commenter: Sarah Summers, OMFS

Strongly Opposed!
 


8/16/18  11:39 am
Commenter: Dr. Scott Frey

Avoid inviting fraud
 

While there is a need to reform the current law to recognize focused training in areas outside the 9 already established dental specialities, the board must enact the reforms in a way that avoids inviting fraudulent behavior and undermining informed patient consent. Where recognized specialties already exist, it is important to the public interest whether or not their doctor is a recognized or board certified specialist in those areas. Removing that requirement would be very unwise. In areas of dentistry that do not overlap or conflict with the currently recognized specialties where dentists might seem focused training the board must outline standards for required training in these new areas in order to continue to promote a high level of patient care. It is important that “specialization” mean something to the public both for the existing specialities and for new areas that VA may decide to allow in the future. 


8/16/18  11:41 am
Commenter: John Jewett, Tri-Cities Orthodontics

Strongly Oppose, Protect the Public