The Recognition That Should Not Have Happened

A Documentary History of the 2020 ADA Orofacial Pain Specialty Decision

By Clayton A. Chan, D.D.S. — Founder and Director, Occlusion Connections | Las Vegas, Nevada

Last Updated: May 7, 2026

On March 31, 2020, the National Commission on Recognition of Dental Specialties and Certifying Boards announced that Orofacial Pain had been granted recognition as a dental specialty, sponsored by the American Academy of Orofacial Pain.

What the public announcement did not say is that, twenty-eight days earlier, the same Commission had formally denied the same application — by a vote that failed to reach the required two-thirds majority — on the grounds that the AAOP Bylaws did not meet Requirement 1(b) of the Requirements for Recognition of Dental Specialties.

What followed in those twenty-eight days was an appeal process that violated the Commission’s own published Policy and Procedure Manual in multiple specific ways. Five anonymous Appeal Board members, hand-selected by the Commission Director, reversed the Commission’s substantive denial behind closed doors. The names of those five individuals were never disclosed despite repeated formal requests. The minutes of the appeal hearing were never made public, in violation of the Manual’s own requirement that “minutes of the meetings shall be posted and available for public viewing.” The Director refused, in writing, to answer detailed procedural questions submitted by ADA members. Dentists who had submitted substantive opposition during the official public comment period received either single-sentence acknowledgments or no response at all.

II. The 2019 Application and the Substantive Opposition

The AAOP application document of 2019 made claims that, on inspection of the document itself, established the substantive grounds on which the application would be opposed.

On page 22 of the application, AAOP asserted:

“Use of electronic surface EMG, jaw tracking and other untested diagnostic tests that have no evidence of reliability and validity for TMD and orofacial pain conditions have been promoted to increase revenue for the provider.”

On page 91 of the application, the same characterization appears in expanded form. Surface electromyography, jaw tracking, and Doppler/sonography are framed as practices to be discouraged rather than tools used by clinicians to make objective neuromuscular measurements.

This language matters because of what was already on file at the FDA, the ADA, and the peer-reviewed scientific literature. The K7 Evaluation System (which combines EMG, jaw tracking, and electrosonography) had held the ADA Seal of Recognition from 1986 to 1994 and the ADA Seal of Acceptance from 1995 to 2007 as an aid for the diagnosis of TMD. The J5 Dental TENS held FDA-approved indications for use. More than ninety peer-reviewed studies — across decades, multiple research groups, and multiple continents — had established the reliability of these instruments and documented elevated resting EMG, asymmetrical functional EMG, and consistent EMG abnormalities in TMD patients compared to controls.

The AAOP application did not engage with this evidentiary base. It dismissed the instruments wholesale and characterized their clinical use as revenue-driven.

It is on this substantive ground — and on the question of whether AAOP met the six Requirements for Recognition — that the 2019 opposition was organized.

The Coordinated Public Comment Response

On Monday, September 30, 2019, Fray Adib, CEO of Myotronics-Noromed, distributed a “Call to Action” to the broader neuromuscular dental community. The communication included a template letter authored primarily by Dr. Barry Cooper, on the editorial board of CRANIO and past international president of the International College of CranioMandibular Orthopedics, with input from Adib and other senior ICCMO members. The template walked through each of the six Requirements and concluded NOT FULFILLED for each, drawing on language previously published by the Alliance of TMD Organizations across prior application cycles.

The Call to Action was specific and procedural. It identified the public comment period deadline (October 28, 2019). It provided Director Catherine Baumann’s mailing address and email at the National Commission. It listed the Commissioners by name and address in case any opposition writer had personal contact with them. It requested that copies of submitted letters be sent to Myotronics for institutional records.

The community responded.

Across October 2019, dentists from across North America submitted substantive opposition letters to Director Baumann at the Commission. Each letter was independently authored, reflecting the writer’s own clinical experience and professional credentials. Each walked through the six Requirements. Each concluded NOT FULFILLED.

The writers included clinicians of varying credentials, geographic locations, and clinical specialties. What they shared was a sustained professional engagement with TMD diagnosis and treatment, and a sustained professional concern that recognizing a single sponsoring organization with an explicitly anti-occlusion philosophy would harm the patients they were trying to help.

This document preserves several of those letters as primary-source archival records. They are linked below.

Primary-Source Opposition Letters Submitted to NCRDSCB, October 2019

The Cooper CRANIO Editorial

In addition to the letter campaign, Dr. Barry Cooper published a substantive editorial in CRANIO: The Journal of Craniomandibular and Sleep Practice, Volume 37, Number 6, online October 3, 2019, titled “An orofacial pain specialty: An asset or liability to dentistry and the public.”

The editorial walked through each of the six Requirements and explained, in peer-reviewed publication format, why each was not fulfilled. It documented the Alliance of TMD Organizations’ multi-decade analysis of prior AAOP applications. It quoted directly from the ADA’s own Requirements for Recognition document. It observed that the broad “Standard of Care” AAOP would inevitably establish “includes treatment currently provided by medical providers of various specialties and general practitioners in both medicine and dentistry” — a fact that, by ADA’s own Requirements, disqualifies an application.

This editorial is on the public record in the peer-reviewed literature. It is citable. It cannot be erased.

By the close of the October 28, 2019 public comment period, the Commission had received an organized, substantive, professionally credentialed opposition record. Multiple senior figures in the field had filed substantive letters. A peer-reviewed editorial had been published. Hundreds of practicing dentists had participated in the official public comment process.

The opposition was on file. The receipts were submitted. The procedure had been followed.

III. The Commission’s Denial — March 2-3, 2020

The National Commission convened in the Executive Board Room of the ADA Headquarters Building in Chicago on Monday, March 2, 2020 at 8:29 AM. Dr. James Boyle, chair, called the meeting to order.

The roll call showed twenty-one Commissioners present, including Dr. Wayne Aldredge, Dr. Don Altman, Dr. Joseph Battaglia, Dr. James Benz, Dr. James Boyle (chair), Dr. Renee Broughten, Dr. Anthony Carroccia, Dr. Ralph Cooley, Dr. Alan Friedel (vice-chair), Dr. Steven Ganzberg, Dr. Anita Gohel, Dr. Denise Hering, Dr. William Johnson, Dr. Roger Kiesling, Dr. Andrew Kwasny, Dr. Brian McAllister, Dr. Edward Moody, Dr. Susan Muller, Dr. Charles Norman, Dr. Frank Tuminelli, and Dr. Mara Catey-Williams.

Trustee Liaison: Dr. Richard Rosato, First District Trustee, American Dental Association.

Commission Staff: Ms. Cathy Baumann, director; Mr. Nicholas Salerno, manager.

The Commissioners disclosed conflicts of interest as required. Notably, Dr. Steven Ganzberg disclosed that he was a “Past member American Academy of Orofacial Pain.” Based on this disclosure, when the AAOP application came forward, Dr. Ganzberg “participated in the discussion; however, he was recused from voting.” Twenty Commissioners would vote on the application.

The Commission considered the AAOP application alongside an application from the American Academy of Oral Medicine. The two applications were reviewed by the same Commission, in the same session, against the same six Requirements.

The Commission’s review of the AAOP application is recorded in the official meeting minutes, posted on the ADA website. The relevant portion reads as follows:

“Consideration of Applicant Response to the Requirements for Recognition of Dental Specialties Requirement 1: Through discussion, the Board of Commissioners determined that the application met Requirement 1(a) and Requirement 1(c); however, Requirement 1(b) had not been met. The commission noted that Requirement 1(b) states that the privileges to hold office and to vote on any issue related to the specialty are reserved for dentists who have either completed an advanced education program accredited by the Commission on Dental Accreditation in the proposed specialty or have sufficient experiences in that specialty as deemed appropriate by the sponsoring organization and certifying board. The commission further noted that in CHAPTER 1. MEMBERSHIP, SECTION 2. ACTIVE MEMBERS, the AAOP Bylaws allows non-dentists to be Active Members, hold office and vote, which does not meet Requirement 1(b).”

The Commission proceeded through Requirements 2 through 6, finding them met. But Requirement 1 had a fatal sub-element.

“The National Commission voted via ballot and the application did not achieve the necessary 2/3rds vote for recognition as a dental specialty.”

“Commission Action: The National Commission on Recognition of Dental Specialties and Certifying Boards denies the American Academy of Orofacial Pains request to recognize orofacial pain as a dental specialty.“

The application was denied. By the Commission’s own substantive review, on the merits, in proper procedural form, with proper conflict-of-interest disclosure, after considering the substantive opposition record from the public comment period.

This denial is recorded in the official meeting minutes posted on the ADA website. It is not in dispute. It is documented in the Commission’s own primary-source record.

In the same meeting, the American Academy of Oral Medicine application — reviewed by the same Commission against the same six Requirements — was approved. The Commission found that AAOM met all six Requirements, including Requirement 1, and granted recognition.

The Commission was not refusing to recognize new specialties. It was reviewing applications on their merits and reaching different conclusions for different applications. Oral Medicine met the bar. AAOP did not.

The Commission’s Concerns Beyond Requirement 1(b)

Later in the same meeting, the Commission held a separate discussion under the heading “Discussion Related to the Development of Revised Requirements to be Considered by the Council on Dental Education and Licensure and the American Dental Association House of Delegates.” The minutes record that the Commission expressed concern about applications it had received that raised issues beyond what the existing Requirements addressed. The minutes list these concerns in language that, in context, can only refer to the AAOP application:

“Violation by sponsoring organizations of the National Commission’s core beliefs”

“Use of disparaging language in applications for recognition about the American Dental Association and other sponsoring organizations/disciplines”

“Overlapping scope of practice and fundamental differences in treatment modalities and philosophies between organizations leading to public confusion”

“Animosity between recognized sponsoring organizations and unrecognized sponsoring organizations due to disagreement on standard of care leading to a negative perception of the profession by the public and other health care professions”

The Commission further discussed:

“While some applications for recognition may meet the Requirements for Recognition, these applications violate the core values, beliefs and ethical expectations of the National Commission.”

The Commission, in formal session, was concerned about AAOP not only on the procedural grounds of Requirement 1(b), but on the substantive grounds of professional conduct and ethical expectations. They denied the application. They expressed concerns about its character. They directed the Review Committees to develop policy language addressing “intentionally deceptive practices.”

This is the institutional posture of the duly constituted Commission as of March 3, 2020: substantive denial, with documented concerns about the applicant’s conduct.

Twenty-eight days later, that posture was reversed by five anonymous individuals.

IV. The Twenty-Eight Day Reversal

On March 31, 2020, the National Commission’s website announced:

“After a thorough review of the American Academy of Orofacial Pain application for recognition by the National Commission and a thorough appeal process, on March 31, 2020, the American Academy of Orofacial Pain’s request to recognize orofacial pain as a dental specialty was granted by the National Commission on Recognition of Dental Specialties and Certifying Boards based on compliance with the Requirements for Recognition of Dental Specialties.”

The announcement does not specify when the appeal was filed. It does not specify when the Appeal Board met. It does not name the Appeal Board members. It does not link to the appeal hearing minutes. It does not explain what factual or procedural basis was used to overturn the Commission’s substantive Requirement 1(b) finding.

To understand what should have happened — and what didn’t — the relevant document is the Commission’s own Policy and Procedure Manual, copyright March 2020, posted on the ADA website. The Manual specifies, in detail, how appeals must be conducted.

What the Policy and Procedure Manual Required

The Policy and Procedure Manual is explicit. The relevant provisions are quoted directly below.

Composition of the Appeal Board pool:

“The Appeal Board shall consist of one (1) representative selected by each of the recognized specialty sponsoring organizations represented on the Commission, two (2) general dentists selected by the ADA Board of Trustees, and one (1) representative of the public, selected by the Commission and who have previously served on the Commission.”

Selection of the five-member hearing panel:

“When an appeal is initiated, the Commission’s Director selects five (5) individuals two (2) of whom shall be general dentists, two (2) of whom shall be specialists and the public member from the available Appeal Board Members to serve as the hearing panel, adjudicate the appeal and issue a decision which shall be final.”

By the Manual’s own language, the Commission Director — Catherine Baumann — personally selected the five individuals who would adjudicate the appeal.

Timeline:

“The Appeal Board of the Commission shall convene and hold its hearing within thirty (30) days after the appeal is filed.”

Decision threshold:

“The decision rendered by the Appeal Board by a four fifths vote shall be final and binding.”

To overturn the Commission’s denial, four of the five hand-selected Appeal Board members had to vote for reversal.

Scope of the Appeal Board’s inquiry:

“The Appeal Board is limited in its inquiry to review substantive procedural issues raised by the appellants and factual determinations up to the time of the National Commission’s decision regarding the application for recognition. It is not proper for the Appeal Board to either receive or consider facts not previously presented to the National Commission since it does not sit as an initial reviewing body.”

Transparency requirement:

“Section 1. Meeting Minutes: Minutes of the meetings shall be posted and available for public viewing.”

These are the Commission’s own published rules. They were posted on the ADA website. They governed how the appeal of the AAOP denial was supposed to work.

What Actually Happened

The names of the five Appeal Board members who reversed the Commission’s denial were never disclosed.

The minutes of the appeal hearing were never posted publicly, despite the Manual’s requirement that “minutes of the meetings shall be posted.”

The factual basis on which the Appeal Board overturned the Commission’s substantive Requirement 1(b) determination was never made public.

Whether the appeal was held within the required thirty days was never confirmed.

Whether Catherine Baumann, in selecting the five Appeal Board members, disclosed any conflict of interest from her prior role as Manager of Advanced Specialty Education was never disclosed.

When ADA members asked these questions formally, in writing, by email, the answers they received are documented in correspondence that is now part of the historical record.

The AAOP’s February 2020 Communication to Its Membership

There is one further documentary detail that the historical record requires.

In February 2020 — before the Commission’s March 2-3 deliberation — the AAOP communicated to its membership that “if we make a simple change to our Bylaws, we will be awarded the Specialty status.” This statement was reported in subsequent correspondence and quoted in opposition writing.

The Manual is explicit that the Appeal Board “is limited in its inquiry to … factual determinations up to the time of the National Commission’s decision” and that “it is not proper for the Appeal Board to either receive or consider facts not previously presented to the National Commission.”

A bylaws amendment that did not exist at the time of the Commission’s review would, by the Manual’s own language, fall outside the Appeal Board’s proper scope of inquiry. Yet AAOP had publicly told its membership, before the Commission’s review concluded, that such an amendment would be the path to specialty status. The implication is that the path was known in advance — including, presumably, the appeal that would consider it.

Whether the Appeal Board considered post-hoc bylaws amendments has never been disclosed because the Appeal Board’s deliberations were never made public.

V. The Documented Refusal-to-Answer Trail

In April 2020, after the recognition was announced, ADA members began submitting formal written requests to Director Baumann seeking the procedural information that the Manual required to be public.

These requests are documented in correspondence preserved as primary-source records.

Dr. Ira Shapira’s April 7, 2020 Request

On April 7, 2020 at 11:36 AM, Dr. Ira Shapira sent the following email to Director Baumann:

“Dear Catherine,

Who was on the appeal board for the AAOP decision on Specialty?

Was the chair present?

Was the meeting done within 30 days of filing?”

Dr. Shapira’s letter was signed with his credentials including “Past Chair, Alliance of TMD Organizations” and “Life Member, American Dental Association.”

Director Baumann’s response, sent the same day at 2:47 PM CDT, in full:

“Hi Dr. Shapiro-

Thank you for contacting the National Commission.

All available information related to this issue has been posted on the National Commission’s website at the following link: https://www.ada.org/en/ncrdscb”

The website did not contain the requested information.

Dr. Shapira’s April 9, 2020 Follow-Up

On April 9, 2020 at 1:36 PM, Dr. Shapira responded:

“You stated ‘All available information related to this issue has been posted on the National Commission’s website at the following link: https://www.ada.org/en/ncrdscb’

UNFORTUNATELY THAT IS NOT TRUE. ALL AVAILABLE INFORMATION IS BEING KEPT SECRET.

Does this mean that the official position of the American Dental Association and the National Commission on Recognition Of Dental Specialties and Certifying Boards is that the ADA has no intention of revealing the name of the 5 individuals who have created a new specialty in orofacial pain?

Please clearly explain the due diligence that was done in the appointing of these individuals that they meet 100% of the qualifications required to be in these positions.

Would you positively state that ‘You are refusing to divulge this information?’

Was the appeal completed within 30 days of the denial?

When was the appeal board picked? Who picked the members of the appeal board?

Does the public member of the board have any affiliation with the TMJ Association?

Are there minutes and/or recordings of the appeal board meeting? Are these available?

This is an official request that no records be destroyed pending legal actions that may be forthcoming both from members and possibly federal authority.

Was the AAOP allowed to make changes to their by-laws after initial review and appeal? This is a clear violation, correct.

Do you refuse to answer these questions?

No response will be taken as a refusal.”

Director Baumann’s response, sent April 9, 2020 at 3:01 PM:

“Thank you for contacting the National Commission.

All available information related to this issue has been posted on the National Commission’s website at the following link: https://www.ada.org/en/ncrdscb”

The same response. No answer to any of the specific questions.

Dr. Chan’s April 10, 2020 Letter

On April 10, 2020, Dr. Clayton A. Chan submitted a formal letter to Director Baumann with ten specific procedural questions:

1. Where on the ADA website does it officially announce these new overturned appealed decisions after the March 2-3, 2020 Meeting Minutes?
2. ADA has not revealed the names of the 5 individuals who have created a new specialty in orofacial pain. They are supposed to. Why not?
3. Please clearly explain the due diligence that was done in the appointing of these individuals that they meet 100% of the qualifications required to be in these positions.
4. Why has the ADA thus far not posted or divulged this information on the ADA website?
5. Was the appeal completed within the 30 days of the denial?
6. When was the appeal board chosen?
7. Who picked the members of the appeal board?
8. Does the public member of the board have any affiliation with the TMJ Association?
9. Where are the minutes and or recordings of the appeal board meeting?
10. Where are these pieces of information available to see on the ADA website?

Dr. Chan’s letter received no response. Four days later, on April 14, 2020, he wrote to Fray Adib:

“Fray, I still haven’t received a response back from Catherine Baumann regarding my email on April 10th with the 10 questions.”

Adib’s reply on April 15, 2020:

“Hi Clayton, She will not respond. She does not have to! Ira Shapira is also writing to her asking for explanation but she is ignoring him as well. The ADA and Baumann will only respond to an attorney at this point.”

Dr. Shapira’s April 15, 2020 Notice to the ADA

On April 15, 2020, Dr. Shapira sent a more formal letter that put the ADA on notice. The letter is preserved in the archival record and quoted here in part:

“I have asked on numerous occasions for the secret minutes of the Appeal Board on AAOP Specialty which you have refused to release.

I have asked for the names of the 5 anonymous members of the Appeal Board on AAOP Specialty, who were personally picked by you. You have refused to answer.

Were all of the letters sent in concerning specialty reviewed by this so-called unbiased panel? Were they even sent to them?

I have asked for information in any and all interactions between you and the members of the Orofacial Pain Group which you may have had as Manager, Advanced Specialty Education. Which you have refused to answer.

I am asking now did you disclose your possible conflicts of interest to the Board of Specialty Recognition from your work as Manager, Advanced Specialty Education?”

The same letter put the ADA on notice regarding a separate legal matter:

“Please also inform them that there is still a legal restraining order against the American Dental Association that while they can have secret meetings they cannot act on them to make changes which will affect ADA members without first holding open meetings. This order has never been vacated and the actions on Specialty may constitute Contempt of Court.

I was a named plaintiff in that case.”

To this letter, no substantive response is documented.

Pattern

The pattern is consistent across multiple submitters, multiple letters, multiple specific questions, and multiple weeks. Director Baumann did not provide the names of the Appeal Board members. She did not provide the appeal hearing minutes. She did not confirm whether the appeal occurred within the required thirty days. She did not address the question of her own potential conflict of interest from her prior role as Manager of Advanced Specialty Education. She did not respond to Dr. Chan’s ten questions at all. Her responses to Dr. Shapira consisted of two identical sentences referring him to a website that did not contain the information he requested.

The Commission’s own Manual required that “minutes of the meetings shall be posted and available for public viewing.” They were not posted. They are still not posted, six years later.

VI. The Dental Specialty Group’s Pre-Existing Procedural Warning

There is one further piece of documentary evidence that bears directly on whether the appeal process was structurally sound.

At the same March 2-3, 2020 meeting where the Commission denied the AAOP application, the Commission also considered a formal communication from the Dental Specialty Group (DSG). The minutes record:

“The Board of Commissioners noted the DSG proposed revisions to Article III. Appeal Board, of the National Commission Rules to eliminate the discretionary selection of a five (5) member Hearing Panel, suggesting that all members of the Appeal Board should participate in the hearing. The Board of Commissioners noted the correspondence further proposed revision to Article III. Appeal Board that would eliminate the ability of the Director of the National Commission to make the appointments of appeal board members to the hearing panel.”

The DSG, in other words, had formally identified — before the AAOP appeal occurred — that the Director’s discretionary authority to hand-select the five-member Appeal Board panel created a structural concern. They proposed that the entire Appeal Board pool participate in hearings, removing the Director’s discretionary power to select which members would adjudicate.

The Commission denied the DSG’s proposal at the same March 2-3 meeting:

“The Board of Commissioners discussed that DSG’s proposed revision to Article III, Appeal Board, Section 2, Composition, creates a supermajority of specialist’s verses general dentists and significantly weakens the control for conflict of interest. The commission discussed that the proposed revision related to the Director’s appointment of hearing panel members, once again, significantly weakens the control for conflict of interest.”

“Commission Action: The National Commission on Recognition of Dental Specialties and Certifying Boards directs staff to send correspondence to the Dental Specialty Group denying the Dental Specialty’s Groups request to revise the policies and processes in question at this time, as they represent best practices in Commission governance.”

The Commission characterized the existing structure as “best practices” and rejected the DSG’s reform.

Within twenty-eight days, exactly the structural concern the DSG had warned about was instantiated. The Director, exercising her discretionary authority to hand-select the five-member panel, presided over an appeal process that overturned the Commission’s substantive denial behind closed doors with no public minutes and no disclosure of the panel’s composition.

The DSG warned, formally, that this structure would produce exactly this outcome. The Commission rejected the warning. The outcome followed.

VII. The Substantive Critique: What the Cooper Editorial Already Said

While the procedural failures of the appeal process are documented in the primary-source record, the substantive case against the AAOP application also bears preservation. Dr. Barry Cooper’s October 2019 editorial in CRANIO is now part of the peer-reviewed literature and cannot be erased. Its analysis of the six Requirements is summarized here for the documentary record.

Requirement #1 (community of interest): The AAOP, with approximately four hundred members at the time, did not represent the thousands of dentists who treated TMD across the broader dental community of interest. Cooper noted that AAOP’s denial of the role of occlusion in TMD placed it in opposition to the mainstream position of the practicing dental community.

Requirements #2 and #3 (distinct and well-defined field): The proposed specialty did not delineate a distinct field separate from existing recognized specialties or combinations of specialties. The Alliance of TMD Organizations had argued, and the ADA Council on Dental Education and Licensure had previously opined, that AAOP described a medical, not a dental, specialty.

Requirement #4 (substantial public need): A public need not adequately met by existing general practitioners or dental specialists had not been documented. Medical and dental professionals collectively possessing the required skills were already serving the public.

Requirement #5 (direct benefit to clinical patient care): Recognition would result in a reduction, not an expansion, of available clinical care by diminishing the credentials of practicing dentists who use bio-physiologic and instrumented approaches.

Requirement #6 (formal advanced education programs): Absent a universally accepted delineation of the specialty, the necessity of two-year post-graduate programs to provide unique knowledge and skills could not be demonstrated. Undergraduate dental students could be adequately trained to provide initial TMD treatment.

The substantive case was on the public record. The Commission considered it. The Commission denied the application.

The Appeal Board’s reversal did not address Cooper’s substantive critique because the Appeal Board’s deliberations were never published.

VIII. The Pattern Across Borders

The 2020 ADA recognition did not occur in isolation. The same dismissal of objective neuromuscular instrumentation appears in the Royal College of Dental Surgeons of Ontario’s 2018 Draft TMD Guidelines, which characterized EMG as producing inconsistent findings and TENS-based therapy as lacking evidence of efficacy. The RCDSO Draft Guidelines were issued one year before the AAOP filed its 2019 application.

The institutional language is consistent across the two regulatory bodies. The peer-reviewed literature contradicting that language — including more than ninety studies documenting consistent EMG abnormalities in TMD patients across decades, multiple research groups, and multiple continents — appears in neither regulatory document.

The implication is that the framework dismissing objective neuromuscular instrumentation is not a Canadian framework or an American framework. It is a posture organized dentistry has assumed across jurisdictions, codified in regulatory language, and made into “standard of care” by institutional declaration rather than by reference to the evidentiary record.

The 2020 ADA recognition gave that framework formal specialty status in the United States. The procedural irregularities documented above are how that recognition was achieved.

IX. What This Means for Patients and Clinicians

The recognition that should not have happened is now five and a half years old. Its institutional consequences are visible in standard-of-care language, in insurance reimbursement coding, in malpractice exposure for clinicians who use objective neuromuscular instrumentation, in dental school curricula that no longer teach occlusion as foundational to TMD diagnosis, and in patient outcomes documented in clinical practice and on patient support forums.

Patients who present with structural malocclusion and masticatory dysfunction are increasingly directed toward chronic pain management protocols — pharmaceutical, behavioral, cognitive — rather than toward objective measurement of mandibular position and bio-physiologic correction of occlusal pathology. Patients who fail those protocols accumulate failed dental work over years before encountering, often by chance, a clinician trained to measure what the AAOP framework dismisses.

The clinicians who do measure are increasingly characterized within the regulatory framework as outliers, as practitioners of unproven techniques, as deviating from the standard of care. The Standard of Care that defines them this way was established by an institutional process whose foundational decision was, on the record, procedurally compromised.

This document is preserved so that future patients can know that what they were told was the standard of care was a contested institutional position, not a settled scientific consensus. So that future clinicians can know that the framework limiting their freedom of practice was not built by neutral application of evidence but by a regulatory decision made behind closed doors by five anonymous individuals whose names have never been disclosed. So that future researchers and historians can know that the documentary record of what happened in the twenty-eight days between March 3 and March 31, 2020 was preserved while it was still preservable.

The receipts are on file. The pattern is documented. The decision can no longer be unmade. But it can be remembered correctly.

Documentary Archive: Primary Sources

The following primary-source documents anchor this historical record. All quotations in this document are drawn from these sources.

Substantive opposition letters submitted October 2019 during the public comment period:

• Dr. Clayton A. Chan, D.D.S. — Letter to NCRDSCB — October 1, 2019 (PDF)
• Dr. Mariela K. Lung-Compton, DMD — Letter to NCRDSCB — October 18, 2019 (PDF)
• Dr. Gregg R. Melfi, DDS — Letter to NCRDSCB — October 2019 (PDF)
• Dr. Jay B. Terrell, DDS — Letter to NCRDSCB — October 17, 2019 (PDF)
• Dr. Ira L. Shapira, DDS — Letter to NCRDSCB — October 10, 2019 (PDF)

Peer-reviewed publications:

• Cooper BC. “An orofacial pain specialty: An asset or liability to dentistry and the public.” CRANIO: The Journal of Craniomandibular and Sleep Practice. 2019;37(6):344-346. DOI: 10.1080/08869634.2019.1664813.

Commission primary-source documents:

• National Commission on Recognition of Dental Specialties and Certifying Boards Policy and Procedure Manual, Copyright March 2020.
• Minutes of the National Commission on Recognition of Dental Specialties and Certifying Boards, March 2-3, 2020 Meeting, ADA Headquarters Building, Chicago.

AAOP primary-source documents:

• American Academy of Orofacial Pain. Application for Recognition of Orofacial Pain as a Dental Specialty (2019 application document, full text).

Correspondence trail (April 2020):

• Email exchange: Dr. Ira Shapira to Catherine Baumann, April 7-9, 2020.
• Email: Dr. Clayton A. Chan to Catherine Baumann, April 10, 2020 (ten procedural questions; no response received).
• Email: Dr. Ira Shapira to Catherine Baumann, April 15, 2020 (formal notice including reference to standing legal restraining order against the ADA).
• Email exchange: Dr. Clayton A. Chan and Fray Adib (CEO, Myotronics-Noromed), April 9-15, 2020.

Coordination materials:

• Email: Fray Adib (CEO, Myotronics-Noromed), September 30, 2019. “Call to Action — Opposition to AAOP’s Application for Specialty,” distributed to the broader neuromuscular dental community with template letter authored primarily by Dr. Barry Cooper.

Related historical documentation:

• Dr. Gary Heir, DMD. Statement to the International UCLA Facial Pain Discussions Forum (2006-2010), discussing the institutional position of orofacial pain academics on EMG-based instrumentation and “specialty status.”

A Note on Authorship and Standing

This document is authored by Dr. Clayton A. Chan, D.D.S., Founder and Director of Occlusion Connections. Dr. Chan submitted his own substantive opposition letter to the National Commission on October 1, 2019 (preserved in the archive linked above), submitted ten formal procedural questions to Director Catherine Baumann on April 10, 2020 (no response received), and is one of the primary witnesses to the documented refusal-to-answer correspondence trail described in Section V.

Dr. Chan was not, in 2019-2020, an active member of the International College of CranioMandibular Orthopedics, having departed from ICCMO in prior years. The substantive opposition to the AAOP application was led by Dr. Barry Cooper, Dr. Ira Shapira, ICCMO, and the Alliance of TMD Organizations, with broad participation from independently practicing dentists across North America. Dr. Chan’s participation reflected his own assessment of the substantive merits and his own clinical concern for patients, not a representational role.

This document was prepared in May 2026, six years after the events it describes, with the express purpose of preserving the historical record before institutional memory and primary-source documentation are further at risk of loss. The archive of opposition correspondence is held in parallel by Myotronics-Noromed, whose CEO Fray Adib coordinated the public comment campaign and requested copies of submitted letters for institutional records. Dr. Ira L. Shapira passed away in October 2025; his contributions to this record are preserved here through his correspondence and through his lifelong professional advocacy, which deserves to be remembered.