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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9/2/18  3:33 pm
Commenter: Aaron Stump DDS Charlottesville Pediatric Dentistry

Strongly oppose
 

I strongly oppose this amendment for a variety of reasons:

1) Misleads unknowing public into believing they are receiving specialist care when they are not

2) Degrades specialist training and dental/medical practice

I feel that dentistry, being a subset of medicine, should hold itself to a high standard. Gone are the days of the barber-surgeon where one could get a haircut and an amputation in the same place at the same time. There should be a higher standard of advertising when there are clearly higher standards in practice, specialty training, and board certification. Although medical doctor in title, my children's pediatrician does not advertise as a gynecologist or endocrinologist, even though they may be able to handle some basic gynecological or endocrine issues. 

Above all, this is a general public safety issue. The general public is not knowledgeable about technicalities of specialty dentistry as a practice. It needs to be clearly stated to allow them to objectively elect care from a general dentist or specialist, just as I have the choice to seek care from my PMD for my allergy issues or seek care at Board Certified Allergist.  

The ADA Ethical Advertising Code states: Section 5.H. ANNOUNCEMENT OF SPECIALIZATION AND LIMITATION OF PRACTICE, of the Code sets forth the General Standards for determining the education, experience and other appropriate requirements for announcing specialization and limitation of practice. These are: 1. THE SPECIAL AREA(S) OF DENTAL PRACTICE AND AN APPROPRIATE CERTIFYING BOARD MUST BE APPROVED BY THE AMERICAN DENTAL ASSOCIATION. 2. DENTISTS WHO ANNOUNCE AS SPECIALISTS MUST HAVE SUCCESSFULLY COMPLETED AN EDUCATIONAL PROGRAM ACCREDITED BY THE COMMISSION ON DENTAL ACCREDITATION, TWO OR MORE YEARS IN LENGTH, AS SPECIFIED BY THE COUNCIL ON DENTAL EDUCATION [AND LICENSURE], OR BE DIPLOMATES OF AN AMERICAN DENTAL ASSOCIATION RECOGNIZED CERTIFYING BOARD. THE SCOPE OF THE INDIVIDUAL SPECIALIST’S PRACTICE SHALL BE GOVERNED BY THE EDUCATIONAL STANDARDS FOR THE SPECIALTY IN WHICH THE SPECIALIST IS ANNOUNCING. 3. THE PRACTICE CARRIED ON BY DENTISTS WHO ANNOUNCE AS SPECIALISTS SHALL BE LIMITED EXCLUSIVELY TO THE SPECIAL AREA(S) OF DENTAL PRACTICE ANNOUNCED BY THE DENTIST

We should follow this guideline.