Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Dentistry
 
chapter
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
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9/8/20  2:52 pm
Commenter: Rob Strauss

Cannot support facial cosmetic injections of Meds
 

I cannot support the extraoral administration of neuromodulators and fillers for cosmetic purposes by non-Board Certified and credentialled OMS providers. I say that based on the following:

1.  It is incumbent on any practitioner to perform procedures for which they have not only been trained to perform, but also to manage the complications that invariably present. I have personally seen tragic results from the use of these agents. As the professor who teaches cosmetic surgery (and management of complications) to the dental students at VCU, I can say that this is NOT taught to any level of competency (only to familiarity). Non-surgeons do not have any experience managing deep fascial space infections, eyelid lagophthalmos, avascular necrosis, etc (all of which can and do occur from these agents even when performed properly). I myself will only perform cosmetic procedures that I am confident I can handle the complications of (which is not all of them). I must add that these experiences certainly cannot be taught in weekend courses!

2. As a member of the committee appointed by the Board of Dentistry some years ago to negotiate with the Board of Medicine the ability of Board Certified and properly experienced OMSs to perform cosmetic procedures, it was their greatest concern that dentists with no formal surgical or medical training would perform these procedures and be unable to manage the inevitable complications. It was agreed by both Boards at that time that only Board Certified OMSs (and further, only those who were trained in residency to perform these procedures and manage their complications) would be credentialled and then only after they registered with the Board. Changing the rules and regulations at this point is in direct contradiction to the agreement reached by the BOD and the BOM.

3. It has been pointed out that Botox can also be used intraorally for a variety of conditions. To my knowledge this has never been prohibited for any dentist to perform. I support that entirely as every dentist has training and experience in intraoral procedure and their complications. My concern is extraoral use on the face where there is no training in dental schools and where the complications can be devastating and required surgical intervention.

4. It has also been pointed out that some non-physicians such as nurses are able to give these injections.  Nurses are not independent practitioners. They can only give these injections under the auspices of a licensed physician or OMS with appropriate credentials. Nurse practitioners are independent but  work under care agreements with physicians who accept the responsibility for managing their complications.

CommentID: 84520