I strongly agree that a digital scan is the equivalent to an (analog) final impression - when being used to fabricate an intra-oral appliance.  A face to face encounter/evaluation with a dentist licensed in the state of Virginia should be required when using these scans to fabricate appliances. A comprehensive workup, both radiographically and clinically, has always been the standard of care before prescribing any intra-oral appliance to intercept potential complications associated with treatment (periodontal issues, caries, etc).  I believe that failing to have a proper face-to-face evaluation when using digital scans to fabricate intra-oral appliances is performing below the standard of care, is not in the best interest of the patient, and is not providing the patient with the comprehensive care that our profession has pledged to provide them.