I agree that a digital intraoral scan used to make a dental appliance should be deemed the same as a final impression and require direct doctor supervision.  Additionally a doctor patient relationship should be established, prior to scanning,  with a face to face meeting of the treating doctor and patient and should include a through health history, examination and diagnosis including all necessary diagnostic records required to treat to stand of care.  This is the only way that patients health and safety can be adequately protected and all viable treatment options discussed so proper informed consent can be obtained.  Direct to consumer (DTC) companies are delegating the health history, examination and diagnosis to salespersons who are not adequately trained and not licensed  to obtain informed consent.  This presents a serious risk to the public and it is the Board Dentistry's job to protect the health and welfare of the citizens of Virginia.