8/27/2018

RE: NOIRA concerning Amendment to restriction on advertising dental specialties

Dear Virginia Board of Dentistry Members,

My name is Edward P. Snyder. I previously served on the Board of Dentistry and I truly appreciate your time and efforts spent as you continue to monitor the practice of dentistry in the Commonwealth of Virginia.

I strongly oppose the proposed language in the NOIRA removing an essential public protection. Removing a definition of specialist would allow individual dentists to advertise as a ‘specialist’ when they have not completed at least 2 years of full time ‘approved’ education and training in the specialty.  

The citizens of Virginia deserve the ability to easily distinguish dentists who have completed 2+ years of full time specialty education/training in their field from those dentists who have not.  The regulation, 54.1-2718 and 54.1-2720, G., 3 and 4, recognize that specialties exist and this recognition should be maintained to protect the citizens of Virginia by providing appropriate information about the advertising dentist’s educational background, or lack thereof.  

I understand that questions have been raised concerning how the current specialties are designated by CODA. However, work is currently in progress to create a board independent of the ADA to certify what a specialty is and what a dentist must do, in terms of education, to achieve a specialty designation. 

If the Virginia Board of Dentistry eliminates section 3 and 4 and relies only on sections 1 and 2 to govern advertising, then how will the Board determine what qualifies as appropriate education/training for a specialist.  I do not believe the Board would want to spend the time necessary to determine each individual case of an individual dentist who claims ‘specialty’ status.

I fully support the comments and suggestions that the American Association of Orthodontist recently submitted to the Virginia Board of Dentistry.  

Finally, the state of Louisiana has adopted language that I believe the State of Virginia should consider. The state of Louisiana has developed language essentially defining a specialist as one who has completed 2+ years of full time post-doctorial education and is accredited by an accreditation agency that is recognized by the United States Department of Education.

Sincerely,  

Edward P. Snyder, DDS