Public Comments for Events Organized by the FTC's Economic Liberty Task Force #00030

Submission Number:
Karen Sealander
American Dental Hygienists' Association
Initiative Name:
Public Comments for Events Organized by the FTC's Economic Liberty Task Force
The American Dental Hygienists' Association (ADHA) applauds the FTC for convening the Economic Liberty Taskforce July 27, 2017 Roundtable entitled "Streamlining Licensing Across State Lines: Initiatives to Enhance Occupational License Portability". The Roundtable effectively highlighted on a national level vital issues relating to the portability of occupational licenses across state lines. License portability is an issue of extreme importance to ADHA and to the dental hygiene profession. Indeed, ADHA regularly hears from frustrated dental hygienists about license portability restrictions that impede qualified dental hygienists from practicing their profession when they move to a new state or seek to provide dental hygiene services across state lines. ADHA appreciates the long history of leadership that the FTC has demonstrated in urging policymakers to reduce or eliminate unnecessary occupational licensing requirements imposed by state law or rules. ADHA also appreciates that the dental hygiene profession and the dental therapist profession are among the occupations listed on the Economic Liberty website, which enumerates occupations on which the FTC has commented with respect to licensing issues. ADHA urges the FTC to continue to draw attention to the important issues surrounding portability of occupational licenses, including those impacting licensed dental hygienists. Given the plethora of anti-competitive restrictions on the dental hygiene and dental therapist professions, ADHA urges the FTC to undertake a "Policy Perspectives" report on competition and regulation of dental hygienists and dental therapists. Please find attached the comments of the ADHA in connection with the Roundtable. Thank you for the opportunity to comment on this important matter and we welcome further dialogue with the FTC and the Economic Liberty Task Force. Please do not hesitate to contact Ann Battrell, MSDH, ADHA CEO; Ann Lynch, ADHA Director of Education Professional Advocacy (312-440-8942/; or Karen Sealander (202-756-8024/, with questions, or if we may be of assistance to FTC efforts to promote competition in the oral health sector. Kind regards, Karen Karen Sealander Washington Counsel American Dental Hygienists' Association Karen S. Sealander Partner McDermott Will Emery LLP The McDermott Building 500 North Capitol Street, N.W. Washington, DC 20001 Tel +1 202 756 8024 Fax +1 202 756 8087 Biography Website vCard Email Twitter LinkedIn Blog Secretarial Team 6N, Assistant to Karen S. Sealander Tel + 1 202 756 8744