I am in support of assuring dental professionals of the Commonwealth know and understand the statutes that regulate dental practice through an initial examination.  However, requiring a test every 3 years is a poor method for achieving this goal at this time.  First, there has been no promotion of the existing rules to practicing dental professionals by the BOD.  In  fact, I have been aware of no regular communication from the BOD to practicing dentists in recent years.  We used to receive regular newsletters by mail, which one would think would be even more efficient by email, but this has not been the case.  Second, the BOD has been reluctant to clearly define their positions re: important areas of the professional code relating to the ethical practice of dentistry and the ownership of dental practices.  Third, it is not clear how this unproctored examination is going to solve a problem, which has not been clearly identified.  I would suggest considering the following, prior to instituting this triennial examination:

1.  Identify the areas of the regulatory codes in which the BOD has determined poor understanding and/or adherence by dental professionals of the Commonwealth.

2.  Reinstitute regular communication with licensed dental professional in order to promote understanding of the regulatory codes.

3.  Communicate directly with the VDA and other dental organizations in order to facilitate the education of dental practitioners re: the regulatory codes.

4.  Reassess the necessity for an examination or other means for assuring understanding and adherence to the regulatory codes after the above steps have been followed.

Thank you for your consideration,

Guy Levy