The Scan-Only Work Order and the Out-of-State Lab
Dr. K prepares a 3-unit zirconia bridge on teeth 13–15. She emails an intraoral scan to a dental laboratory in Georgia that is not registered in Florida, writing: "Please fabricate; I'll send the written prescription later." The lab emails back that (a) the finished bridge can be mailed directly to the patient's home to save a visit, (b) a technician will "adjust the contacts" at the patient's home, and (c) the lab needs a signed work authorization but can "just fill in the details ourselves" if Dr. K signs a blank form. Dr. K likes the price and asks her assistant to approve it.
1. Is a written work authorization required, and when and in what form?
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Yes, and it must precede fabrication. Under the dental laboratory provisions of Chapter 466, F.S., a laboratory may fabricate an appliance only pursuant to a written work authorization (prescription) issued and signed by a licensed dentist. It must identify the patient or case, the tooth/teeth, the appliance and materials, design and shade details, and the date.
- An intraoral scan is clinical data, not an authorization. Emailing a scan with a promise to send the paperwork later does not comply.
- Signing a blank authorization for the lab to complete is improper - the dentist is the one certifying the prescription.
- A compliant electronic work order with an authenticated signature is acceptable; the point is that the dentist authored and signed it before the lab started work.
Why: the statute exists so that laboratory work is traceable to a dentist's diagnosis and prescription, which is what protects the patient and makes the appliance defensible in the chart.
2. Must a Georgia laboratory be registered in Florida? What is Dr. K's obligation?
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Yes. A dental laboratory performing services for Florida dentists and Florida patients must be registered with the Department/Board, and that requirement is not avoided by locating across state lines. Registration is the mechanism by which the Board exercises jurisdiction over laboratory practice.
Dr. K's obligations:
- Verify the registration before sending work; keep the registration number with the case file.
- Using an unregistered laboratory exposes the dentist to discipline under s. 466.028, F.S., for aiding or participating in a violation, quite apart from the laboratory's own exposure to penalties.
- If the laboratory will not register, the work goes elsewhere. "The price was good" is not a defense.
Judgment point: the dentist's license is the regulated object here. The laboratory's compliance failure becomes the dentist's problem the moment the case is sent.
3. May the lab mail the bridge to the patient and send a technician to the patient's home?
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No. Dental laboratories may not provide services directly to the public or deal directly with patients. Fabricating and fitting a restoration, adjusting contacts, and verifying the occlusion are the practice of dentistry, reserved to the licensed dentist. Direct-to-patient delivery and in-home technician adjustments would place an unlicensed person in a clinical role with the patient and remove the dentist's own responsibility to verify fit, margins, and occlusion before the restoration is cemented.
Correct sequence: the laboratory delivers to Dr. K's office; Dr. K verifies the fit intraorally, adjusts as needed, and documents the try-in. The signed work authorization and the laboratory invoice belong in the patient's record, retained for the period required by Board rule.
If the lab has already mailed the bridge: do not let the patient seat or "try" it unverified; have it returned to the office, inspect and adjust it, and document what happened.