Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Health Professions
Board
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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8/17/18  7:50 pm
Commenter: Jonathan Wong, DMD; Coastal Pediatric Dental & Anesthesia

Interesting Perspectives
 

As one can see this is quite possibly the most participation we have seen from Virginia Dentists in a Town Hall. This is a very unpopular proposal, and organized dentistry has been very powerful in encouraging participation.

Here are two additional facts:

1)  There is only one CODA residency that must be completed in nearly all states in order to legally practice deep sedation and general anesthesia ( again aside from the OMFS exemption). You simply cannot legally deliver this type of care without completing this specialized training, which consists of 3 years of anesthesia training.  This training does not include any "dental surgery procedures" but instead focuses on anesthesia and sedation for both medical and dental procedures.  It met all standards for specialty recognition except for a vote by the House of Delegates.  This process has always been biased, and receives a response much like this Notice has.  Those that are trying to make comparisons to medicine need only Google the differing opinions of the American Medical Association and the American Board of Medical Specialties to see the flaws in their argument and the conflict of interest that would be present if the AMA was the sole determinant of medical specialty education and specialty recognition.  There is a reason the AMA and ABMS are co-members in an independent Accreditation Council of Graduate Medical Education, because it helps separate the conflict of interest and lays out the standards for education and specialty (and subspecialty) recognition.  https://www.boardcertifieddocs.com/pdf/Resources_BCDInformation.pdf & https://www.abms.org/media/120037/wed_2_brigham_addressingevolving.pdf

2) There have been many arguments discussing medical specialists voiced by others in the Town Hall.  Let me also present this fact:  Arguments regarding misleading advertising as cardiologists or other subspecialties does not carry weight.  For example the cardiologist.  Cardiologists are not specialists, they are subspecialists under the specialty of internal medicine.  Now no one would say that a cardiologist should not advertise his advanced training to the public as a cardiologist.  But the current regulation if applied to cardiology, would state that the cardiologist would have to disclose to everyone that they are a cardiologist by training, but that their actual specialty is internal medicine.  How many people would have much faith in that cardiologist then?  For more details about these designations in medicine please see: https://www.abms.org/media/176512/abms-guide-to-medical-specialties-2018.pdf

The political nature of these processes and decisions have caused us to be in this current dilema. I only ask that the Board recognize the flaws in the current system and the fact that most of the concerns being voiced are not based on facts.  My position is obviously not popular, but the need for change is, in my opinion, based on facts.

I completely agree that specialists deserve specialty recognition.  I agree that general dentists should not be allowed to advertise as specialists by merely taking a CE course.  However, the current regulations don't seem to be stopping this anyway, but it is preventing those that have completed said "residency training" from ethically advertising what they do because the ADA House of Delegates chose not to vote to approve other CODA accredited residency programs as specialists.