FTC Staff Submits Comment to the Commission on Dental Accreditation Regarding its Proposed Standards for Dental Therapy Education Programs

Federal Trade Commission staff 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 staff comment states that 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, but unnecessary language on supervision and scope of practice could undermine that goal. The comment suggests that CODA consider omitting such language. The staff comment also encourages CODA to consider developing more expansive accreditation standards that would reach master’s or graduate level programs, as well as the baccalaureate programs currently addressed.  CODA is recognized by the U.S. Department of Education as the sole body to accredit dental and dental-related education programs at the post-secondary level. 

Dental therapists are a relatively new type of provider that offers some of the same basic dental services offered by dentists. They differ from other allied dental health professionals, such as dental hygienists, in that they are trained and licensed to provide some, but not all, services traditionally carried out only by licensed dentists.

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, the comment states.

Recognizing this potential, a number of state legislatures have considered enacting legislation providing for the licensure of dental therapists, and at least one state, Minnesota, has enacted such legislation and created dental therapy educational and training programs. The FTC staff comment recognizes that patient health and safety concerns are of critical importance when states regulate health care professionals, and that each state will need to determine its own supervision and scope of practice limitations for dental therapists.

The staff comment notes, however, 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 comment explains that the language may deter innovation in dental care education.

Therefore, to preserve state-level flexibility and promote innovation in dental care education and delivery models, the staff comment encourages CODA to consider:

• omitting 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; and
• developing accreditation standards for master’s or graduate level programs that train dental therapists to conduct oral evaluations and develop treatment plans without requirements for an on-site supervising dentist or at other supervisory levels that have been adopted by states.

The Commission vote approving the comment was 4-0. (FTC File No. V140000; the staff contact is Karen A. Goldman, 202-326-2574.)

Copies of the documents mentioned in this release are available from the FTC’s website and from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, DC 20580. Call toll-free: 1-877-FTC-HELP.