American Dental Association
1111 14th Street N.W.
Washington DC 2005

January 11, 2011

Honorable Kathleen Sebelius
Office of the Secretary
U.S. Department of Health and Human Services
Hubert H. Humphrey Building 200 Independence Avenue, SW
Washington, DC 20201

Dear Secretary Sebelius:

The American Dental Association (ADA) is very disturbed to learn that the Division of Oral Health (DOH) of the Centers for Disease Control and Prevention (CDC) is to be folded into the Division of Adult and Community Health within the CDC. The ADA strongly opposes eliminating the DOH as an identifiable division focused on oral health and making it merely a branch of another division. We strongly urge that this decision be reconsidered and reversed.

For many years, the ADA’s close collaborative relationship with the CDC has been greatly facilitated by having a separate division with which to work. The ADA has come to value its relationship with the DOH as a collaborator on some of the most important initiatives benefitting the public’s oral health over the past decade.

These include:

• Water fluoridation. The CDC has recognized community water fluoridation as one of 10 great achievements in public health of the 20th century and acknowledged the DOH and ADA’s importance in achieving this accomplishment. The DOH was a key player in the January 7, 2011 announcement regarding recommended community water fluoridation levels. Their decision was based on on-going scientific review that the DOH had conducted with the full knowledge of the dental community for many years. It is hard to imagine how another non-dental CDC division could be capable of handling such responsibilities.

• Infection control in dental offices. The DOH was instrumental in developing recommendations for dental offices in the aftermath of the Kimberly Bergalis HIV infection case that, as disseminated by the ADA, addressed public concerns about the safety of dental offices. The Division continues to play a critical role in updating these recommendations as well as recommendations for other infectious diseases like Hepatitis which can be transmitted from dentist to patient and vice versa.

• Recommendations for evidence-based care. DOH staff has been key participants in expert panels convened by the ADA to develop evidence-based clinical recommendations on dental sealants, fluoride supplements and exposure to fluoride through infant formula.

The current organizational structure promotes clear dental leadership, unity of purpose and responsiveness that will be undermined if the DOH is subsumed into a division with a larger public health mission focused on adults.

• Dental caries remains the most common chronic disease of childhood – five times more common than asthma. Moving the oral health division into the adult program area would be inconsistent with addressing this widely recognized access problem and the department’s own message regarding oral health.

• Prevention is the hallmark public health approach to addressing dental caries and periodontal disease. This is also the approach being taken by other Divisions within the Chronic Disease Center. Like the DOH, all strive to prevent diseases across the lifespan from inception to very old age. Placing oral health in the Division of Adult and Community Health would greatly reduce and alter the DOH’s prevention message for all ages.

• A Director level position held by a dentist credentialed in dental public health is critical to assuring that dentistry maintains equal footing with the other chronic disease program directors who would be his or her peers. Furthermore, retaining the DOH as a separate division will help assure that the division attracts top notch candidates.

• Building state oral health program infrastructure and capacity for prevention and control of oral disease, assuring that surveillance systems are in place to monitor disease burden, and building the science base are responsibilities that merit Division rather than branch status.

In 2010 the Department of Health and Human Services announced the “HHS Oral Health Initiative.” A document announcing this initiative posted on the HHS website states that the department “currently supports a broad spectrum of oral health activities that has had a significant and positive impact on the nation’s oral health financing, research, workforce development, public health action, quality initiatives and technology.” The document describes various department programs including CDC’s DOH. We do not understand having made that announcement less than a year ago, how the Department can now consider eliminating one of its few dental divisions. Dissolving one of the separate dental divisions from the Department would only seem to decrease and take away from highlighting the importance of preventing and treating oral disease.

The National Center for Chronic Disease Prevention and Health Promotion focuses on several diseases – diabetes, cancer, cardiovascular, and obesity. It also strives to address tobacco use and improve reproductive health. All of these diseases or conditions are “chronic” and have an oral health connection that can be eliminated or reduced. But we know from past experience with other federal agencies that if dental is not included as an identifiable entity that the connection to oral health is overlooked, if not forgotten.

We strongly urge you to maintain the CDC’s Division of Oral health as a separate entity within the chronic disease center so that they can continue to improve the oral health of Americans from inception to old age.

Sincerely,

Raymond Gist, D.D.S.
President

Kathleen T. O’Loughlin, D.M.D., M.P.H.
Executive Director

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