Dear Distinguished Members of the Board,

I am writing regarding the pending NOIRA for Training and Supervision Requirements for Digital Scan Technicians.  I would like to comment from the perspective of a dental specialist in dental public health and orthodontics. I fully support a prior comment made by another clinician, Dr. Julie Staggers, namely that:

“ The Board's primary function is to protect the public from unlicensed and/or poor dentistry.  The public does not know the quality of unregulated online/direct to consumer dentistry, they are only focused on convenience and price.  The Board should be protecting patients from online, do it yourself dentistry. “

I support a dentist being a necessary part of the training and supervision process, but in what exact manner is the question that needs clarification. Quality care also needs to be reasonably accessible and affordable for the public.

In order to help ensure reasonable treatment costs and availability, I hope the Board will also permit dentists to have maximum flexibility in terms of delegating teledentistry related procedures. This would include scanning as well as the final seating of appliances, as long as some form of final check for quality of care, either directly or remotely, is available from a licensed dentist.

As teledentistry continue to expand in fields other than orthodontics, many traditionally under served populations, including Medicaid patients, will benefit from regulations that offer wide freedom to delegate procedures. As has been already dramatically demonstrated in Alaska, remote dentist supervision of dental auxiliaries has been shown to be a safe and clinically successful means of providing often complex dental services.

To summarize, as the Board promulgates regulations for the training and supervision of digital scan technicians, I believe it is quite reasonable that the role of the dentist could be integrated in either a remote or direct manner. In this way the public will benefit from both quality assurance of services rendered, and increased availability and affordability. 

Paul Supan, DDS, MA, MPH

Diplomate, American Board of Orthodontics