ADEA State Update

FTC Submits Comment on the Proposed CODA Dental Therapy Standards

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On November 21, the Federal Trade Commission (FTC) submitted comments in response to the Commission on Dental Accreditation’s (CODA’s) request for public comments on the 2014 version of its proposed accreditation standards for dental therapy education programs. Overall, the FTC urged CODA to move ahead with its proposed standards.

Specifically, in its comments, the FTC referred back to its December 2013 comments in which the FTC staff documented its “support [of] CODA’s efforts to facilitate the creation of new dental therapy education programs and to expand the supply of dental therapists because these initiatives are likely to increase the output of basic dental services, enhance competition, reduce costs, and expand access to dental care.” However, in 2013 the FTC recommended several revisions to address portions of the standards that in their view, “could have been interpreted to impede competition.” For example, the FTC was concerned that “categorical statements regarding a supervising dentist’s responsibility for diagnosis and treatment planning could limit the competitive benefits of an expansion of the supply of providers of basic dental services. In particular, these statements might discourage state-level legislation allowing dental therapists to conduct evaluations and formulate treatment plans in the absence of an on-site dentist…” 

However, in its November 2014 comment, the FTC states that many of its previous concerns have been addressed. For example, “[t]he 2014 Accreditation Standards appear to have addressed this issue [of categorical statements regarding a supervising dentist’s responsibility for diagnosis and treatment planning] by deleting statements about supervision of dental therapists by dentists and a dentists responsibility for diagnosis and treatment planning, and by acknowledging that a 'dental therapist provides care with supervision at a level specified by the state dental practice act.'”

The FTC goes on to say, that “we write to urge CODA to finalize and adopt proposed standards without unnecessary delay, so that the development of this emerging service model can proceed, and consumers may reap the likely benefits of increased competition.” 

Duggan Dental