Virginia Regulatory Town Hall
Department of Health Professions
Board of Dentistry
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
Action Training and supervision of digital scan technicians
Stage Proposed
Comment Period Ended on 4/1/2022


All comments for this forum
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3/27/22  11:28 am
Commenter: David R. Hughes DDS LLC

Intraoral Scan Technician - public comment submission

As with any intraoral diagnostic record, a licensed dentist must be involved with the evaluation and delivery of oral appliances and restorations produced from an intraoral digital scan.  This standard has been in place to protect patients for generations of providers.  New technologies have not yet replaced the role of in-person doctor care and expertise in delivery of dental treatments.  Respectfully submitted, - David R. Hughes, DDS

CommentID: 120872

3/28/22  9:58 am
Commenter: Herb Hughes

Dental/ Orthodontic Scans need to be actively monitored by a doctor

When an orthodontic scan has been captured with the intent of fabricating an appliance that will alter the position of teeth and/or jaws it is imperative that a licenced dentist/ orthodontist perform an in-person exam to avoid missing data and to make the proper diagnosis to deliver the correct treatment plan. I've witness too many times when a doctor is not an active part of the equation and the result is the wrong diagnosis and irreversible harm to the patient. 



CommentID: 120879

3/28/22  12:00 pm
Commenter: Peter Wendell

VA Dental Scan Technician survey

I agree with all the comments and suggestions made by the Virginia Association of Orthodontists.  These provisions will help the public by making sure that all digital scans for orthodontic appliances will be treated by a licensed Dentist in Virginia.

CommentID: 120891

3/30/22  11:38 am
Commenter: David Jones

digital scan technician

The taking of a digital scan (3D scan/iTero scan), if used for the purpose of creating an orthodontic appliance, is the practice of dentistry. Any appliance created from a digital scan taken by a digital scan technician should be inspected by the dentist before being dispensed to the patient. Any patient treated with an appliance created from a digital scan should be seen in-person by a dentist within six months of the scan.

Thank you for your support,

Dr. David L. Jones

CommentID: 120995

3/30/22  11:57 am
Commenter: Eser Tufekci VCU

Dental Scan Technician

A licensed dentist must be involved when intraoral appliances or restorations are fabricated from an intraoral scan. This is a must to protect patients. I fully support the provisions suggested by the American Association of Orthodontists. Digital technology is great, but a dentist must deliver any dental treatment generated by a digital scan. Respectfully submitted, 

Eser Tufekci DDS, Ms, PhD, MSHA


CommentID: 120996

3/30/22  11:59 am
Commenter: Christine Stang

Dental scan is practicing dentistry

The taking of a digital scan (3D scan/iTero scan), if used for the purpose of creating an orthodontic appliance, is the practice of dentistry. Any appliance created from a digital scan taken by a digital scan technician should be inspected by the dentist before being dispensed to the patient. Any patient treated with an appliance created from a digital scan should be seen in-person by a dentist or orthodontist within six months.

 I’ve personally seen multiple patients in my office that experienced negative results to their occlusion due to the complete lack of oversight of their Orthodontic treatment by a licensed dental professional. Patients do not have the knowledge base to monitor their own Orthodontic treatment and unfortunately they are the ones being negatively impacted in the long run. 

 Thank you!

Dr. Christine Stang 

CommentID: 120998

3/30/22  1:28 pm
Commenter: AAO

Need more regulations

We have increasingly encountered patients who had undergone "internet DIY treatment" and are seeking out professional help to reverse course.  The majority of cases that turned up in our office were not properly diagnosed.  It is impossible to check a patient's periodontal status without xrays and a peridontal probe.  Digital scans or photography absolutely can not detect underlying bone loss or infections.  Furthermore, many individuals seeking a "quick fix" do not have routine dental checkups and do not have professional resources to verify what they read on the Internet.   Consequently, they are more likely to present with more complex dental and periodontal issues.  For example, a patient had so much calculus that fully covered all the spaces in between the front teeth.  It was difficult to decern where each tooth started and the next ended.  The x-ray showed more than 75% bone loss.  It is unethical and irresponsible to start orthodontic treatment without first referring the patient to a dentist and a periodontist.  Second, such products are unsupervised.  We have been told that patients could not reach anyone for help (ie, call to speak to a live person for questions) when they run into problems.  Orthodontic treatment modalities need to start with a diagnosis.  Moving teeth is not like moving furniture around in a room; rather, it involves individual biology and physiology.  Finally, especially in this era where Internet and Social Media postings run rampant.  Professional medical/dental organizations need to implement regulations to protect the Virginia constituents from harm.  Thank you for your understanding and consideration.

CommentID: 121003

3/30/22  3:13 pm
Commenter: Banafsheh Hosseinian

digital impression

digital impression is part of the techniques in modern dentistry. we can utilize digital impression to fabricate aligners, different appliances and  crowns . hence impression taking should be under supervision of the dentist as well as delivery of any dental appliance.


CommentID: 121006

3/30/22  4:40 pm
Commenter: Anonymous

VA Dental Scan Technician survey

There are many issues that can occur to the long-term stability of teeth is not monitored by an orthodontic or dental provider. These direct to consumer methods of orthodontic treatment could be disastrous to long-term dental health since they are not being monitored in person. They really need to be seen within six months of the scan.

CommentID: 121008

3/30/22  5:16 pm
Commenter: Kevin Toms

Dental Scan Technician/More regulations needed for patient safety

The dental scan technician is an alternative dental assistant position, that should be regulated similar to a dental assistant and should operate under the supervision of Virginia licensed dentist who is regulated by the board.  They will be using scanning technology to create and provide dental devices to citizens of the state of Virginia, which is the practice of dentistry.  Appliances/devices should be inspected prior to delivery to patients.   Without an actual clinical/in person exam for proper diagnosis and treatment planning irreparable harm could be done to the patients of Virginia.  This created position will need significant rules/regulations to prevent misuse by non-dentist/dentist not regulated by the board of VA.

I just saw a patient today that was treated orthodontically by mail/no exam/diagnosis and is now seeking retreatment to fix other problems created.

Thank you for your time.

CommentID: 121011

4/1/22  1:55 pm
Commenter: Steven J Lindauer, Chair, VCU Department of Orthodontics

Dental Scan Techs should operate under a licensed dentist

If a dental scan is being used to produce an appliance that will be in the mouth, then the scan should be conducted under the supervision of a licensed dentist and no appliance should be prescribed except by a dentist licensed in Virginia who is treating the patient. No treatment should be provided for a patient unless the treating dentist has examined the patient. This is for the safety of the patient and is common sense.

CommentID: 121059