Operative Dentistry Comment Log. Log Date

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Operative Dentistry Comment Log Log 10.20.2014 Date # Name/Organization Rec'd 1 Conaway, Frank DMD 7.17.14 2 Evers, Thomas DMD 8.6.14 3 Verzosa, Chris DDS 8.25.14 4 Reinhardt, John, DDS, MS, MPH 8.23.14 5 Jones, Gordon K. DDS, MS 8.20.14 6 Yaman, Peter, DDS, MS 10.6.14 7 AAOMS: Nelson, William, DDS 10.20.14 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 1

From: To: Subject: Date: Hart, Karen Koziec, Karolina; Monehen, Rosemary FW: operative dentistry Thursday, July 17, 2014 2:05:37 PM Please log this comment. Thanks. Karen M. Hart hartk@ada.org Director Council on Dental Education and Licensure and Education Operations 312.440.2825 800.621.8099 x 2825 Interim Senior Vice-president, Education and Professional Affairs 312.440.2712 800.621.8099 x 2712 American Dental Association 211 E. Chicago Ave. Chicago, IL 60611 www.ada.org From: Frank Conaway [mailto:drc@drfconaway.com] Sent: Thursday, July 17, 2014 10:57 AM To: Hart, Karen Subject: operative dentistry I do NOT support more separation of the profession. There is no reason to single out operative dentistry from other areas. Frank Conaway DMD ADA #181890255

From: To: Subject: Date: Hart, Karen Monehen, Rosemary FW: Comments on Operative Dentistry Proposal Wednesday, August 06, 2014 6:40:28 PM Please log this comment. Karen M. Hart hartk@ada.org Director Council on Dental Education and Licensure and Education Operations 312.440.2825 800.621.8099 x 2825 American Dental Association 211 E. Chicago Ave. Chicago, IL 60611 www.ada.org From: Thomas Evers [mailto:tbeasbury@yahoo.com] Sent: Wednesday, August 06, 2014 3:11 PM To: Hart, Karen Subject: Comments on Operative Dentistry Proposal Ms. Hart, I find the idea of creating "advanced educational programs for accreditation" in Operative Dentistry absurd. What is the goal of this proposal? To create another level of training for Dental Schools to gouge students with the blessing of the ADA? To create an "Operative" specialty? In this dawning era of Mid-level providers why would we want to further stratify our profession? It's hard to remain an ADA member when this is the type of nonsense the Board of Delegates wastes their time on. Thomas Evers DMD ADA# 152910644

From: To: Subject: Date: Hart, Karen Monehen, Rosemary FW: Comments on operative dentistry proposal Tuesday, August 26, 2014 8:25:49 AM Please log the comment below. Thanks. Karen M. Hart hartk@ada.org Director Council on Dental Education and Licensure and Education Operations 312.440.2825 800.621.8099 x 2825 American Dental Association 211 E. Chicago Ave. Chicago, IL 60611 www.ada.org -----Original Message----- From: Verzosa, Christopher E. LT, FHCC Lovell [mailto:christopher.verzosa@med.navy.mil] Sent: Monday, August 25, 2014 1:40 PM To: Hart, Karen Cc: Jones, Gordon K. GS, FHCC Lovell Subject: Comments on operative dentistry proposal Director Karen Hart, I am writing to you in regards to a request concerning the accreditation for operative dentistry. I believe that an accreditation standard would be highly beneficial for all of dentistry based on the following: 1) An accredited program would offer a universal guideline for all those taking the operative specialty, thus raising the level of education and proficiency to a standardized/required level. 2) For all entities that recognize the specialty, such as the military and government service, they could finally establish a standard to base scope of practice credentials for certain job positions. 3) This accreditation would help to give credibility to those who already have the education and further specific research topics in relation to operative dentistry. I appreciate your time and attention to this matter. Sincerely, Dr. Chris Verzosa, D.D.S.

October 20, 2014 Karen Hart, Director Council of Dental Education and Licensure American Dental Association 211 E. Chicago Avenue Chicago, IL 60611 Dear Ms. Hart, The American Association of Oral and Maxillofacial Surgeons appreciates the opportunity to review the Application for Recognition of Operative Dentistry as an Interest Area of General Dentistry as submitted by the Academy of Operative Dentistry (AOD). We understand that the application has been disseminated for review to the communities of interest with a request that comments be submitted by October 20, 2014, and that all comments will be considered by the Council on Dental Education and Licensure (CDEL) with a report to the 2015 ADA House of Delegates. The AAOMS has carefully reviewed the application and its appendices. It is our opinion that the information provided by the AOD does not adequately support all CDEL requirements necessary for recognition as a special interest area of general dentistry. In particular, we believe the scope of the proposed interest area in operative dentistry is not separate and distinct from any recognized specialty or accredited postdoctoral experience in general practice residency. Criterion 1: An interest area in general dentistry must be a well-defined body of established evidence-based scientific and clinical dental knowledge underlying the general dentistry area-knowledge that is in large part distinct from, or more detailed than, that of other areas of general dentistry education and practice and any of the ADA recognized specialities. As defined in the application, operative dentistry is that area of general dentistry concerned with the treatment of diseases and/or defects of the hard tissues of teeth, specifically the restoration of the form, function and esthetics of those hard tissues. These entities fall within the scope of a general practice residency, as well as existing specialties. Criterion 3: The existence of established advanced educational programs with structured curricula, qualified faculty and enrolled individuals for which accreditation by the Commission on Dental Accreditation can be a viable method of quality assurance. The application indicates that there is a small number of dentists with advanced training and experience who have been deemed capable of teaching, conducting research, developing materials and providing expert advice in the restoration of hard tooth structure to form, function and esthesics. The application further states that operative dentistry is specifically focused on one component of the masticatory system: the hard tissues of the teeth. The general dentist must be able to prevent, diagnose and treat, to the level of his or her competency, diseases and defects of all tissues of the masticatory system, and yet there are currently only 7 graduate programs in operative dentistry with approximately 80 dentists in the world who have been certified by an examining board as having a superior proficiency in operative dentistry.

Given the small number of graduate programs presently established in operative dentistry, the number of practitioners that would graduate annually could not begin to address access to care issues. Resources targeted toward existing programs, such as predoctoral training, postdoctoral training through the general practice residency, and/or toward existing dental specialties, would be more cost-effective in serving the needs of the public. In summary, it is our belief that the application for a special area of interest in operative dentistry lacks sufficient evidence to support the need for a separate and distinct general dentistry interest area in operative dentistry. The best interests of the public will not be served by the creation of an additional dental interest area, and could, in fact, increase confusion as to where to seek dental assistance and counter current efforts to control costs. Thank you for the opportunity to comment upon this application. Sincerely, William J. Nelson, DDS President cc: AAOMS Board of Trustees Dr. Robert C. Rinaldi, Executive Director Ms. Mary Allaire-Schnitzer, Associate Executive Director, Advanced Education and Professional Affairs