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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9/3/18  7:19 am
Commenter: Wm. Graham Gardner D.D.S.


Dear Ms. Reen and the Virginia Board of Dentistry,

Comments in opposition to changes being proposed to 18VAC60-21

I urge you to vote against “the amendment to restriction on advertising dental specialties.” This is an extremely dangerous proposal that WILL be damaging to the public and to dentists.  Your decision will affect people in the Commonwealth of Virginia and will also set a precedent throughout the country.  I have listed my main concerns as follows:

Important Concern:  If the specialty distinction is eliminated, there is no reason for dentists to go through 3-5 years of extra education to call themselves a specialist.  The quality of care for patients will obviously drop significantly.  There will be no orthodontists straightening teeth, dentists will do that.  There will no oral surgeons doing jaw surgery, dentists will do that.  General dentists are not trained to do these things in dental school.  Patients will receive poor treatment.

Important Concern:  Patients will be deceived.  The patients will have no idea which dentist has had adequate training and which do not.  Patients will have no way to differentiate between which dentists practice specialty training consistently every day and those dentists that have done it once before.  Would you want your family members to have an implant (a surgical procedure) placed by someone that has only seen it once during an afternoon course? 

Important Concern:   The ADA just created a National commission on dental specialty recognition which proves that they are in favor of specialists in the dental profession.  Restricting the advertising of dental specialties is a slap in the face to the American Dental Association, which represents all dentists and not just the specialists.  It is even more of a detrimental insult to the American Association of Oral and Maxillofacial Surgeons, the American Academy of Periodontology, the American Association of Endodontists, the American College of Prosthodontists, the American Academy of Pediatric Dentistry, the American Association of Oral and Maxillofacial Pathology, the American Association of Public Health Dentistry, the American Academy of Oral and Maxillofacial Radiology and the American Association of Orthodontics.

Important Concern:  Who does this possibly benefit?  A group called the American Board of Dental Specialties which represents a very small sample of the dental community.  This proposal certainly does not benefit the majority of dentists and it MOST CERTAINLY DOES NOT BENEFIT THE PATIENT.  This is a national group trying to move their agenda throughout the country.  This is not a Virginia issue.

Important Concern:  This puts Virginia at risk.  When the Commonwealth allows dentists to advertise that they are at the level of a specialist when they are not, and a person gets hurt by poor treatment by this dentist, then the commonwealth is to blame for allowing this unqualified dentist to treat patients at this lower level. 


Why is this even being considered?

Why would health care ever be allowed to move to a sub-standard level where we are downgrading our treatment standards and deceiving patients?

I URGE you to do the right thing for the public.  Do not let patients be deceived.  Do not let the practice of dentistry sink to a sub-professional level.  Do not let underqualified providers treat patients poorly.


Thank you for your consideration and your excellent service to our great Commonwealth.



Wm. Graham Gardner D.D.S.