The Federal Trade Commission (FTC) announced that members of its staff have submitted a comment to the American Dental Association’s Commission on Dental Accreditation (CODA) regarding CODA’s proposed Accreditation Standards for Dental Therapy Education Programs. The FTC states that while the proposed accreditation standards may encourage the development of a nationwide dental therapy profession that could improve access to, and enhance competition for, dental care services, there is unnecessary language on supervision and scope of practice that could undermine the goal. The FTC suggests that CODA consider omitting such language.
The comment submitted by the FTC also encourages CODA to consider developing more expansive accreditation standards that would reach masters or graduate level programs, as well as the baccalaureate programs currently addressed.
According to the FTC, expanding the supply of dental therapists by facilitating the creation of new dental therapy training programs is likely to increase the availability of basic dental services, enhance competition, reduce costs, and expand access to dental care, especially for underserved populations. Recognizing this potential, a number of state legislatures have considered enacting legislation providing for the licensure of dental therapists. Minnesota, for example, has created dental therapy educational and training programs throughout the state.
The FTC argues that the proposed CODA accreditation standards include language that may unnecessarily constrain the discretion of states to determine dental therapists’ scope of practice and authority. In addition, the Commission explains that the language may deter innovation in dental care education.
To preserve state-level flexibility and promote innovation in dental care education and delivery models, the FTC encourages CODA to consider omitting categorical statements regarding a supervising dentist’s responsibility for diagnosis and treatment planning. These are topics that are typically addressed by individual states in their licensure and scope of practice laws.
What’s more, the FTC encourages the development of accreditation standards for masters or graduate-level programs that train dental therapists to conduct oral evaluations and develop treatment plans without an on-site supervising dentist.
