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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9/4/18  12:13 pm
Commenter: John White

Strongly Oppose
 

I strongly oppose this amendment. As a recent graduate of VCU's Graduate Periodontics Program I'd like to provide some comparative data on the qualifications and time commitment of a CODA certified periodontist and implant specialist as compared to an implant specialist certified by the American Board of Dental Specialists (ABDS).

Over the last three years I spent roughly 8,000 hours (including nights and weekends) learning, studying, and teaching periodontology and implant dentistry as well as treating patients. I would argue that roughly 50% of this time was dedicated specifically to implant dentistry in all its facets. The easiest route of admissions into the ABDS implantology specialty requires 670 continuing education hours to apply for specialty. That's a 7,330 hour total difference and a 3,330 hour implant difference.

I completed 174 implant cases during my residency. The ABDS requires 75. That's a 99 case difference. Please keep in mind many of my cases require knowlege and understanding outside of basic implant dentistry (i.e. sinus augmentation, ridge augmentation, soft tissue grafting, management of implant disease, management of implant complications, wound healing, sedation, etc.). 

Of the 174 implant cases I completed in residency, ALL (100%), were completed with on-site, personal supervision from established periodontists and prosthodontists prior to, during, and after surgical and restorative therapy. The ABDS requires 7 years of clinical practice experience in implant dentistry, but it does not specify the amount of supervision and/or expert advice provided to the active practitioner. Furthermore, it does not specify the number of cases that must be completed during those 7 years of experience. Therefore, a dentist who completes 1 case a year for 7 years could apply. Likewise, a dentist that completes 75 cases over 10 years (or only 7.5 cases/year) could also apply. Again, this is in stark comparison to the number of cases (in my case 174) and direct instructional supervision provided to one who completes a CODA certified residency in either Periodontics, Oral Surgery, or prosthodontics. Sadly, this comment focuses on implant dentistry but similar arguments can be made for endodontics and orthodontics. 

Again, I'd like to voice my opposition to this amendment. I urge the governing body to review the above comparative data. With this in mind, please ask yourself two things: (1) who is most qualified to place and manage dental implants? (2) What is in the best interest of the general public, most of whom are unfamiliar with qualitative and quantitative metrics mentioned above?  I appreciate your time and attention.