While I may agree with some of the "in favor" comments held in this comment section regarding specialties not recognized by the ADA/CODA, the board does have a responsibility to protect the welfare of our patients.  And, while there have been successful litigations against other state boards (duly recognized by other "in favor" comments), that does not mean that our state board should not have to address this problem.  After reading this legal brief (https://www.aae.org/specialty/wp-content/uploads/sites/2/2018/09/bierigspecialtyadvpaper0818-002.pdf) outlining what could be constructed, it seems obvious that our state board can still protect the welfare of its patients while still acknowledging dentist's First Amendment rights in constructing a blended regulation that would use the existing ADA/CODA specialty requirements and also allow for an alternative pathway to specialty designation by establishing (and requiring proof) of a similar accepted didactic / clinical equivalent or more stringent (not less) strandard.  Please read the legal brief.  It clearly articulates the course that needs to be taken.