The staff of the Federal Trade Commission (FTC) has advised the Commission on Dental Accreditation (CODA) that proposed accreditation standards for dental therapy education could impede rather than promote the development of a nationwide dental therapy profession.
The FTC staff, in an advisory letter, said CODA’s Accreditation Standards for Dental Therapy Education Programs include unnecessary statements on supervision, evaluation and treatment planning, language that could have the effect of limiting competition in the supply of dental care services. “We respectfully suggest that CODA consider dropping such statements,” the FTC wrote.
Among the statements singled out by the FTC is one saying that supervising dentists “will be responsible for assessment of the implications of the patient’s medical condition, diagnosis, risk assessment, prognosis and treatment planning.” The FTC letter notes that “such statements ordinarily are not found in the accreditation standards of education programs for other allied dental professionals who are also supervised by dentists” and could “constrain states’ discretion … to define broadly dental therapists’ scope of practice to include oral evaluation and treatment planning.”
The FTC recommended that CODA consider omitting categorical statements on topics that are typically addressed through state licensure and scope-of-practice laws, and that CODA consider developing accreditation standards for graduate-level dental therapy programs.