Agencies | Governor
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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7/8/19  5:25 pm
Commenter: Scott Frey

Strongly disagree

This amendment as worded is a significant step backward for patient education and access to care. It creates artificial barriers which prevent doctors from being able to use digital simulation software to educate patients on the possibilities for their care. 

A clinical exam and clinical radiographs are important to high quality patient care, but it should not be mandated that these pre-empt the collection of digital images in the form of an intra-oral scan. Rather they are important prior to the start of active portion treatment. This amendment establishes a rigid order that makes little sense.

Furthermore, the timing and context of this amendment create a high likelihood of this amendment being ruled as anti-competitive in nature towards DTC aligner companies such as smile direct club down the road and being thrown out on such grounds down the road.