In December 2019, at the request of the American Dental Association (ADA) Council on Dental Practice, the AGD advocacy councils (Dental Practice and Legislative & Governmental Affairs) submitted comments to a draft ADA policy on the use of sliver diamine fluoride (SDF) for carious lesions. AGD suggested revisions concerning the delegation of the application of SDF to allied dental personnel and caries management.

Consistent with AGD policy, the application of SDF must be predicated by a dentist’s prescription or order of a dentist. AGD policy considers the removal of decay a surgical, irreversible procedure that should only be performed by a licensed dentist. 

Additionally, AGD commented that the initial policy draft did not align with ADA’s Code on Dental Procedures and Nomenclature (CDT Code). AGD opined that ADA’s clinical policy and the CDT Code must always align. 

Lastly, AGD provided commentary on the Food and Drug Administration’s regulatory status of SDF as a Class II medical device and the tremendous hurdles to achieve approval of a pharmaceutical drug. Because of the inherent regulatory obstacles and costs of bringing a drug to market, use of SDF for caries management is often considered an off-label use.

Working with the ADA is an integral focus of AGD’s advocacy efforts. We thank the ADA Council on Dental Practice for the opportunity to comment and provide input to develop policy language aligned with AGD policies, thereby providing the AGD advocacy councils an opportunity to support the final draft language.

The AGD advocacy councils work on behalf of general dentists whenever and wherever it is appropriate to comment on federal and state regulatory and statutory issues, align affiliated professional organizational policy with AGD policy, and address the dental practice concerns of our members. Help us help you by letting us know what impacts you and your practice. Reach us at practice@agd.org. 

For more information read the letter here.