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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8/30/18  10:57 am
Commenter: Elizabeth C. Miller DDS, MS, Atkins, Maestrello, Miller Pediatric Dent

Strongly Opposed




Dear Ms. Reen and Members of the Virginia Board of Dentistry,

I appreciate the opportunity to comment on the proposed changes to the "specialty laws."  I fully support Virginia's regulations that require those who are advertising as "specialists" to have successfully completed a post-doctoral advanced dental education program of at least two full-time years and which program is accredited by the Commission on Dental Accreditation (CODA).  Allowing providors who have not completed these extra years of training to advertise to the public as "specialists" would threaten the safety of our patients and most-likely create more work for the Virginia Board of Dentistry.  If there are no distinctions between a dentist who has completed their post-doctoral training and a dentist who has not, but advertises as such, the unfortunate scenerio will be the patients who suffer and who then make their voice known publicly about their mis-understanding.   For example, as a Board Certified Pediatric Dentist who is in a large group practice with four other Board Certified Pediatric Dentists and two Board Certified Dental Anesthesiologists, we see many children whose parents have been mis-led by the advertisements of large group practices of general dentists who claim to specialize in pediatric dentistry.  These children are referred to us frequently after an attempt is made by the general dentist to complete a difficult procedure on a young child, but is unsuccessful.  The child is then sent to our office with a very serious dental issue which potentially could have been avoided. The most difficult aspect is that the child is usually emotionally scarred from the previous dental experience, to the point that our practice has to place many of them under general anesthesia to complete the procedure that the general dentist attempted.  These instances could be avoided if the public understood the extra training of a pediatric dentist prior to having a difficult procedure completed on their child.

I respectfully request that the Virginia Board of Dentistry consider these concerns during its review.  If you have any questions or concerns, please feel free to contact me or our practice.  Thank you for your time and attention to this matter.


Elizabeth C. Miller DDS, MS

Board Certified Pediatric Dentist

Atkins, Maestrello, Miller and Associates Pediatric Dentistry, P.C.