Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Dentistry
 
chapter
Regulations Governing Dental Practice [18 VAC 60 ‑ 20]
Action Requirement for jurisprudence examination
Stage NOIRA
Comment Period Ended on 12/16/2015
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12/16/15  11:19 pm
Commenter: Mark A. Crabtree, DDS, Past President Virginia Board of Dentistry and VDA

Oppose Law Exam for Renewing License
 

I oppose the concept of requiring law abiding practitioners being required to take the law exam.

I support requiring applicants applying for initial Licensure to practice in Virginia to successfully take an exam covering the Laws and Regulations prior to being issued their license.  This was the practice in the past and was adequate to assure that licensees understand the laws as they are being licensed. 

Retaking the exam should be solely reserved for those who violate the states laws and regulations.  The general practicing public should not be punished by requiring an additional exam which is an unnecessary regulatory burden and imposes additional cost to the practicing dentists.  The grand majority licensees have no problem practicing within the law.

There is a problem that lies with the operation of the Board of Dentistry.  That problem is POOR COMMUNICATION with the Licensees.  The Board should be REQUIRED by Code to send by mail a copy of the Code and Rules and Regulations of the Board to the licensees.  EMAIL is not sufficient communication.  This should include a periodic Communication such as a Newsletter that includes all regulatory proposals and their status in the rule making process.  This should include publishing the Board of Dentistry’s Disciplinary Actions against the licensees.  Including the licensee’s name and offense in the Newsletter will be a deterrent to breaking the rules and will make clear to the rest of the licensees the rules that are being violated.

The data that is being used to support this burdensome regulation is inaccurate.  If there has been an increase of this magnitude the burden lies WITH THE BOARD OF DENTISTRY for FAILING to adequately keep the practicing public adequately informed of their actions.  This increase has occurred as the Board has refused to communicate effectively with the Licensees.

CommentID: 45206