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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8/22/18  10:49 am
Commenter: Jeremy Davidson

Strongly Opposed

Dear Virginia Citizens and Lawmakers,

First, as a currently recognized dental specialist, I realize that am speaking with some bias in my opinions.  Initially, I read this proposed change to be a threat to the public's ability to distinguish my dental practice from others in that I have attended a recognized Commision on Dental Accreditation approved dental residency program in orthodontics, and would like the public to be able to distinguish this clearly and easily.  However, after reading the intent behind this proposed change, in the "Alternatives" section of the NOIRA, I now understand this to be a desire for dentists with significant training in currently "un-recognized" areas of specialization, such as Implantology, to be able to have the same recognition and ability to advertise, as those of us in the recognized specialties.  The American Dental Association has recently responded to this concern with the formation of a commission to oversee the decision making process for recognizing dental specialties.  This will no-doubt become a political debate involving turf wars over which procedures belong to which specialties, fueled no-doubt by economic as well as academic motivations.  As, I am sure several currently recognized dental specialties will lay claim to the implant placement procedures as part of their residency training.  Therefore, in the interest of making the best decision for the general public in the long-run, I strongly oppose this "fast-tracked" legislation in order to allow the process to be properly vetted through the ADA's newly formed commission, as this is NOT a legislation change that will substantively improve the Virginia public's ability to access dental health.