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Virginia Regulatory Town Hall
Department of Health Professions
Board of Dentistry
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
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7/7/19  10:36 am
Commenter: Dag Zapatero, DDS

Strongly Agree - "digital impression file," equivalent to the analog "final impression"
My petition request to update the definition of a final impression due to technologic advancements and to remain consistent with the statue already in place.  It seeks to define a "digital impression file," equivalent to an analog "final impression" if used to fabricate an appliance to be inserted into a patient's mouth.  It should not matter if the file is produced by scanning a patient's mouth through the use of an intra-oral scanner or scanning a patient's dental cast model by an optical scanner.  Both create a "digital file" containing the patient's personal identifying information which can then be used to fabricate an appliance to be inserted into a patient's mouth just as occurs in the analog equivalent of a "final impression."  

Statutory Authority:  § 54.1-2400 and Chapter 27 of Title 54.1 of the Code of Virginia.  § 54.1-2711. Practice of dentistry. 

  • iv) extracts teeth, corrects malpositions of the teeth or jaws, takes impressions for the fabrication of appliances or dental prosthesis, supplies or repairs artificial teeth as substitutes for natural teeth, or places in the mouth and adjusts such substitutes.”
The health, safety and welfare of a patient should be paramount whether an impression is taken by analog or digital means. An impression is an impression.  The adopted Guidance document: 60-23 indicates that Teledentistry  "should not be construed to alter the scope of practice of any health care provider or authorize the delivery of health care services in a setting, or in a manner, not authorized by law. In fact, these guidelines support a consistent standard of care and scope of practice notwithstanding the delivery tool or business method used to enable practitioner-to- patient communications. For clarity, a practitioner using teledentistry services in the provision of dental services to a patient (whether existing or new) must take appropriate steps to establish the practitioner-patient relationship as defined in Virginia Code § 54.1-3303 and conduct all appropriate evaluations and history of the patient consistent with traditional standards of care for the particular patient presentation."