August 29, 2018

Ms. Sandra Reen
Executive Director
Virginia Board of Dentistry
9960 Mayland Drive, Suite 300
Richmond, Virginia 23233
E-mail: sandra.reen@dhp.virginia.gov

Subject: Title 18. Professional and Occupational Licensing

Dear Ms. Reen:

The Virginia Society of Pediatric Dentistry (VSPD) and the American Academy of Pediatric Dentistry (AAPD) are writing to express our concern that the Virginia Board of Dentistry (VBD) is considering amending the regulations governing the practice of dentistry by replacing the regulatory provisions specific to advertising.
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As organizations supporting optimal children’s oral health whose members have received additional training to treat young children and adolescents, including those with special healthcare needs, we feel it is important to retain and update the current provision to prohibit advertising a claim of dental specialty status without having approval by the National Commission on Recognition of Dental Specialties and Certifying Boards (NCRDSCB). Otherwise families who may already have some confusion over the various dental specialties could receive additional misleading or ambiguous advertising by providers who claim they are dental specialists yet do not have the adequate training necessary to successfully treat patients who have complex dental or behavioral/medical needs. The VSPD and the AAPD believes this is an ethical obligation to ensure the best care for this vulnerable population and is a valid regulation by the VBD that protects the public. 

The VSPD and AAPD respectfully ask that VBD reconsider this proposal, as it is clearly not in the best interest of the patients we serve.

Sincerely yours,

Joseph B. Castellano, DDS
President, American Academy of Pediatric Dentistry

Barrett W. R. Peters, DDS, MSD (Charlottesville, VA)
President, Virginia Society of Pediatric Dentistry
Affiliate Professor, VCU Department of Pediatric Dentistry
Owner-Operator, Piedmont Pediatric Dentistry

Patrice B. Wunsch, DDS, MS  (Richmond, VA)
Secretary/Treasurer, Virginia Society of Pediatric Dentistry
Public Policy Advocate, Virginia Society of Pediatric Dentistry
Professor, VCU Department of Pediatric Dentistry

Note: The American Academy of Pediatric Dentistry (AAPD) is the recognized authority on children’s oral health. As advocates for children’s oral health, the AAPD promotes evidence-based policies and clinical guidelines; educates and informs policymakers, parents and guardians, and other health care professionals; fosters research; and provides continuing professional education for pediatric dentists and general dentists who treat children. Founded in 1947, the AAPD is a not-for-profit professional membership association representing the specialty of pediatric dentistry. Its 10,000 members provide primary care and comprehensive dental specialty treatments for infants, children, adolescents and individuals with special health care needs