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.”