G ove r n men t Re lat ions
October 31, 2019
Dr. John Erhard, Chair
Pennsylvania State Board of Dentistry
PO Box 2649
Harrisburg, PA 17105-2649
RE: Do-It-Yourself Dentistry and Teledentistry
Dear Dr. Erhard:
On behalf of the more than 5,000 members of the Pennsylvania Dental Association (PDA), I am writing to share our concerns
regarding the non-traditional delivery of dental services through do-it-yourself and teledentistry models. We respectfully request
that the State Board of Dentistry (SBOD) begin to more fully investigate these alternative models to ensure compliance with
the Dental Practice Act and regulations. We also ask that the SBOD consider amending current regulations should it become
necessary to ensure standards of care are met and to protect the public’s health and well-being.
PDA believes that teledentistry services and online do-it-yourself dentistry businesses are problematic and potentially harmful to the
public. They are not meeting the standard of care for an oral examination, which includes the use of an explorer, periodontal probe,
inspection and palpation, as well as a dentist’s review of radiographs. Though telemedicine is gaining in popularity nationwide,
dentistry is different. It is incumbent on the profession and the SBOD to safeguard the public by requiring in-person examinations
by board approved licensed dentists for all patients treated through these non-traditional delivery models.
Several telemedicine/teledentistry bills have been introduced in the Pennsylvania General Assembly. One of these bills, SB 857, is
gaining traction and has already passed the Senate. At least one teledentistry model which is about to be launched in Pennsylvania
allows hygienists in workplaces to provide “diagnostic and preventive services typically performed at a dentist’s office” to its
employees. The press release regarding this program explicitly states that the services provided by these hygienists include a
“complete oral health exam,” which is not permissible under the SBOD’s regulations. Rendering oral health care screenings through
teledentistry may be inevitable, but PDA believes that the public’s safety is at risk unless several loopholes in the regulations are
closed. One of these loopholes relates to the circumstances in which dentists properly examine and diagnose patients.
PDA is also aware of several online businesses offering do-it-yourself appliances to the public. Patients have the option of taking
their own impressions or having it done by a 3D imaging machine at a non-dental facility. Either way, dentists are usually not
examining these patients in person in advance to diagnose and develop a treatment plan, something that we believe is required
under the Federal Drug Administration’s policy on prescribing medical devices. These companies claim that they employ licensed
dentists who provide virtual exams before fabricating devices, but PDA does not believe that this practice meets the standard of
care for oral examinations.
To address teledentistry models, PDA suggests that the SBOD strengthen its definition of general supervision, defined in Section
33.1., by first striking out the words “In a dental facility” and adding the words “in person,” so that the definition reads:
General supervision—Supervision by a dentist who examines the patient in person, develops a treatment plan, authorizes the performance
of dental hygiene services to be performed within 1 year of the examination, and takes full professional responsibility for the performance
of the dental hygienist.
PDA suggests that the SBOD consider adding a similar definition to address the need for dentists to first provide an in-person exam
and diagnose patients before they engage with non-traditional businesses for do-it-yourself services. Standards are met only when
an in-person examination takes place before prescriptions for appliances are prescribed.
We thank you for your attention to this important issue. As these non-traditional oral health delivery models gain in popularity, we
urge the SBOD to act expeditiously to address these concerns in order that there is full compliance with the SBOD’s regulations and
so that all patients benefit from the same standards of care. Please contact me at (610) 867-8251 or [email protected], if you wish to
discuss this further.
Sincerely,
Charles I. Incalcaterra, DMD
President
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NOV E M B E R/DE CE M BER 2019 | P EN N S YLVA N IA D EN TA L J O UR NAL