The following is the text
from a letter sent to the Kentucky Board of Dentistry from Robert S. Clark,
D.M.D., President of the Kentucky Society of Oral & Maxillofacial Surgeons:
"June 9, 1999
Mr. Gary Munsie
Executive Director
Kentucky Board of Dentistry
10101 Linn Station Road #420
Louisville, KY 40223
Dear Mr. Munsie:
The Kentucky Society of Oral & Maxillofacial Surgeons (KSOMS) hereby requests
the Board of Dentistry make a ruling and render advice concerning the authorized
scope of practice of persons licensed to practice the specialty of periodontics.
KSOMS is concerned that the current trends among some periodontists are inconsistent
with KRS Chapter 313 and may threaten public safety. Rather than name individuals
who appear to be practicing beyond the scope of their authorized specialty,
KSOMS believes it is more constructive to ask the Board to issue a general statement
clarifying the permitted scope of periodontal practice.
As you are aware, KRS 313.400 specifically lists the types of specialty licensing
available under Kentucky law, and KRS 313.410 requires a dentist to have a specialty
license in order to hold himself out to the public as a specialist. Furthermore,
one who obtains a specialty license is required to limit his practice to that
specialty, or lose the specialty designation.
KSOMS is concerned that periodontic specialists are increasingly performing
dentoalveolar surgical procedures such as apicoectomies, and removal of teeth,
exposure, bonding and ligation of teeth and dental implantology, and are holding
themselves out to the public as specialists in some of these procedures. These
procedures appear to be outside the accepted scope of practice of periodontics.
The American Dental Association definition of periodontics is:
That the specialty of dentistry which encompasses prevention, diagnosis
and treatment of disease of the supporting and surrounding tissues of the
teeth or their substitutes and the maintenance of the health, function and
esthetics of these structures and tissues.
The scope of this definition is clearly about matters related to the diseases
of the tissues surrounding the teeth. To a lay person, the definition suggests
that periodontics involves matters related to diseases of the gums. The Society
for Oral and Maxillofacial Surgery therefore believes that periodontics embraces
only a limited range of dentoalveolar procedures, and then only in connection
with periodontal treatment.
Consistent with this interpretation, in August of 1995, your office issued an
opinion to Bruce R. Nicol, then the President of this Society, that tooth extractions
performed at the time of periodontal surgery are within the scope of periodontal
practice, but otherwise would be outside the scope of the specialty. (Similarly,
in May of 1996, the Board determined that exposure and ligation of impacted
teeth is outside the scope of orthodontics.) Clearly, this opinion reflects
the profession's belief that specialties within dentistry should not be expansively
construed, in order to protect the public.
There are other materials that indicate that periodontics does not include dentoalveolar
surgery, except in some cases incidental to periodontal disease.
The ADA's Commission on Dental Accreditation has recently released new Accreditation
Standards for Advanced Specialty Education Programs in Periodontics, which will
be effective January 1, 2000, (Copy attached.) The curriculum standards for
clinical sciences do not include competency standards relating to impactions,
extractions, impaction exposure, molar ligation or sinus surgery with grafting.
Instruction and clinical training in root resection is covered only to the extent
it relates to "management of periodontal disease." The curriculum is required
to include didactic instruction and clinical training only to the level of competency
(rather than proficiency) in dental implants. Thus, it is clear that dental
implants are not a focal point in periodontic training and that other dentoalveolar
procedures are not appropriately included at all.
Similarly, the attached Guidelines to Periodontal Therapy published by the American
Academy of Periodontology "are designed to give guidance to state legislatures
and agencies that regulate the practice of periodontology." 2 Periodontolol
1998; 69:405. The guidelines relating to "Development of a Treatment Plan" prescribes
"a logical plan of treatment in order to alleviate the signs and symptoms of
periodontal diseases." The section of "Treatment Procedures" discusses various
"means of treating any one or all periodontal diseases," and references "selective
extraction of teeth, roots or implants where indicated performed to facilitate
periodontal therapy or restorative and prosthetic treatment plans." (Emphasis
added.) Significantly, nowhere do these Guidelines reference scaling, bonding,
impactions, impaction exposure, molar bonding ligation or sinus surgery with
grafting. In light of the A.A.P.'s obvious incentive to interpret the scope
of periodontal practice broadly, these limitations and omissions are particularly
informative in assessing the scope of authorized periodontal practice.
Accordingly, KSOMS requests the Board of Dentistry to issue a generalized statement
advising dentists that the authorized scope of the periodontal specialty does
not include dentoalveolar surgery, or implants other than in the course of treatment
for periodontal disease.
In addition, KSOMS requests your guidance on a related issue. It is increasingly
common to see Periodontists advertise their availability to perform implants,
e.g., in advertisements and on office signage. In fact, the web site of the
A.A.P. guides the consumer to a page of "Consumer Information" (copy attached),
which touts "Dental Implants: Teeth at look and feel just like your own." While
the text of the article judiciously refers to a periodontists as "members of
the dental implant team" who will work together with your dentist, the page
contains a prompt to "Find a periodontist in your area." Overall, one interpretation
of this "consumer information" is that periodontists have specialty training
in implants, and that a consumer who is interested in implants should contact
a periodontist directly, without regard to whether he or she also has periodontal
disease.
KSOMS believes these kinds of advertisements not only seek to expand the authorized
scope of periodontal practice, but violates KRS 313.410, which prohibits "holding
oneself out to the public as being especially qualified in any branch of dentistry"
without an appropriate specialty license, and KRS 313.445, which requires licensed
specialists to limit themselves to the area of practice within the licensed
specialty. We therefore seek the Board's opinion concerning periodontists' advertisements
of availability to perform or skill in performing implants.
Please do not hesitate to contact me if I can provide any further assistance
in connection with this request.
Respectfully,
Robert S. Clark, D.M.D.
President, KSOMS"