The December 2 comment letter by the staffs of the FTC Office of Policy Planning, Bureau of Economics, and Bureau of Competition called dental therapists a "new type" of midlevel provider that offers some of the same basic dental services offered by dentists.
"Expanding the supply of dental therapists by facilitating the creation of new dental therapy training programs, therefore, is likely to increase the availability of basic dental services, enhance competition, reduce costs, and expand access to dental care, especially for underserved populations," according to the statement.
The comments pointed out that dental therapists are trained and licensed to provide some services traditionally done only by licensed dentists.
The FTC also recognized that states have the authority to determine their own rules regarding the supervision and scope of practice limitations for dental therapists.
But the agency warned that the proposed standards may "unnecessarily constrain" the states' discretion in determining the scope of practice and authority of dental therapists while also stifling innovation in dental education.
The FTC encouraged CODA to consider the following changes:
- Omit categorical statements regarding a supervising dentist's responsibility for diagnosis and treatment planning, topics that are typically addressed by individual states in their licensure and scope of practice laws.
- Develop accreditation standards for master's- or graduate-level programs that train dental therapists to perform oral evaluations and develop treatment plans without requiring an onsite supervising dentist or other supervisory levels that have been adopted by states.
Leon Assael, DMD, dean of the University of Minnesota School of Dentistry, which has the first and only dental therapy program in a U.S. dental school, said he was "very pleased" about the FTC's support of the standards.
“National standards will facilitate the development of a nationwide dental therapy profession.”
— Leon Assael, DMD, dean, University
of Minnesota School of Dentistry
Dr. Assael noted that dental therapist students often take the same courses as dental students and treat patients in the same clinics side by side with dental students. He also pointed out that dental therapist students "are examined to the same standards for the procedures for which they will gain competency as DDS students."
"Dental therapists are proving themselves to be of great value in Minnesota, impacting positively in a variety of settings where they are needed. We agree that national standards will facilitate the development of a nationwide dental therapy profession," Dr. Assael said in a statement to DrBicuspid.com.
Minnesota, the only state that licenses dental therapists in addition to Alaska, requires dental therapists to complete a two-year program to perform basic preventive and restorative procedures and primary extractions with the onsite supervision of a dentist.
North Dakota is moving forward with a study to assess using MLPs after legislators concluded that not enough dentists in the state are available to provide dental care, especially for the poor and Native Americans on reservations. The measure passed the state's House of Representatives and the Senate last summer but faces stiff opposition from the North Dakota Dental Association.
And dental care advocates in Maine have been trying to get a bill passed that would create a new license for dental hygiene therapists, allowing them to do restorations and extractions. It would require 1,000 hours of clinical training supervised by a dentist, and the dental therapists would be allowed to practice as long as they had a supervisory agreement with a licensed dentist.
Approximately 20 states are pursuing or exploring licensed MLP guidelines. Dental hygiene therapists have been practicing for decades in 53 other countries.
Midlevel providers are key to increasing kids' access to dental care, according to a Pew Charitable Trusts report released last summer. MLPs can improve the ability of safety-net systems to reach low-income communities and save states money on emergency room care, Pew concluded.
Dental therapists worldwide now offer safe, effective dental care, especially for children, according to a 2012 report by the W.K. Kellogg Foundation.
The ADA and most state dental associations have steadfastly opposed allowing MLPs to do restorations and extractions due to concerns about nondentists performing surgical/irreversible procedures. The ADA has released reports that concluded the MLP model is not economically realistic or sustainable.
The ADA declined to comment on the FTC's endorsement of the CODA accreditation standards for dental therapists.
"We believe that, like dental hygiene, dental therapists will not only be good for the public, it will be of inestimable benefit, where needed, to the practicing dentist," Dr. Assael said.
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