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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9/5/18  4:25 pm
Commenter: A. Scott Anderson, III, DDS

Strongly oppose

                This is comment is written concerning the “Amendment to restriction on advertising dental specialties”.   I strongly oppose making a change which would put the public at a severe disadvantage when they are seeking a competent level of specialty dental care for themselves or their family.

                I support the Virginia Board of Dentistry in its efforts to ensure that the dental care provided in Virginia is safe and effective for the public.  A significant part of that effort is to ensure that the information to which the public is exposed is not misleading and cannot be easily misconstrued.

                I am writing to share my observations of a few circumstances which often develop when families believe they are presenting for healthcare services with a provider who they mistakenly believe is a pediatric dental specialist.  All too often, I have observed the consequences facing families who have sought pediatric dental care from a general dental provider who the family believed was a pediatric dental specialist, a pediatric dentist, or a children’s dentist. Not only have the families often depleted much of their insurance benefits, but the families may also have spent significant “out of pocket” funds.  At times, their children have reportedly been “worn out” physically and mentally.  Not uncommonly, the treatment has been not only incomplete, but often the treatment may have also been inappropriate for their child at his or her present stage of development.  In many situations, the child’s previous experiences with the general dental provider(s) may have led to the formation of an unfortunate lasting first impression and may also have resulted in the positive reinforcement of inappropriate behavior and/or responses which may not be conducive to safe and effective dental care for the child outside of a surgical care center.  Therefore, the families may be exposed to additional costs for correcting the dental care which has been inappropriately provided, and the children may require additional hospital and/or medical services associated with management of their response to the dental care setting. Had many of these families been aware preoperatively of the fact that they were not in a specialty care practice, untold headaches could have been avoided.

                I understand that some individuals believe that dentists should have the First Amendment right to express their feelings and present themselves as they see themselves:  as specialists.  I won’t say that some dentists may not be supremely qualified to provide a whole array of dental services.  The concern in this particular situation is to ensure that the public is protected from potentially unscrupulous providers who are aware that the public may be unable to professionally evaluate the skills of a particular dentist.  Therefore, the Virginia Board of Dentistry must be able to depend on an organization, such as the American Dental Association, that is beyond reproach in order to provide for the public’s safety.   

                I strongly believe that only those dentists with recognized and appropriate advanced specialty education and training should be allowed to present themselves as specialists in their recognized specialties.   I also strongly support that all specialty advertising be explicit, open, and honest in order to protect the public in the healthcare setting.  Misleading advertising of a specialty level of care, either intentional or unintentional, is not likely to lead to the safe and effective dental care that should be expected by the citizens of Virginia.


                A. Scott Anderson, III, D.D.S.

                Pediatric Dentist

                Diplomate of the American Board of Pediatric Dentistry,  Life Status

                Fellow of the American Academy of Pediatric Dentistry