The ADA submitted a response to the Department of Health and Human Services’ request for information on artificial intelligence adoption in clinical care. The Association emphasized that while AI offers transformative potential, its adoption in dental practices requires investments, particularly to support small and rural offices.  

In a Feb. 20 letter signed by ADA President Richard Rosato, D.M.D., and Interim Executive Director Elizabeth Shapiro, D.D.S., J.D., and submitted in response to an HHS Health Sector AI request for information issued by the Assistant Secretary for Technology Policy and the Office of the National Coordinator for Health Information Technology, the Association highlighted the unique challenges facing rural practices, including limited technology infrastructure, workforce readiness gaps, high upfront costs and regulatory uncertainties.

It urged HHS to provide incentives and support for these practices to adopt modern electronic dental records systems, strengthen interoperability and support clinical documentation improvement activities. Such measures are essential to ensure equitable access to advanced dental care and reduce administrative burdens that can block innovation, according to the letter. 

“Despite the potential benefits of AI, adoption across dental practices remains uneven, particularly among small and mid-sized practices. Adoption decisions are most influenced by practice owners/clinical leadership, in coordination with IT/informatics, compliance/privacy, and legal/risk management, especially when regulatory status is unclear. The need for such coordination places undue burden on small and rural practices,” the ADA said.   

The Association also emphasized that dentistry’s data environment presents distinct barriers to meaningful AI adoption. Dental records often vary widely in structure and content, and consistent use of standardized clinical terminology is limited, which can hinder the development, validation and deployment of AI tools. The ADA encouraged federal efforts that improve data capture and exchange so that AI can be integrated into existing dental workflows. 

The letter also pointed to ongoing progress on dental data standards, including CDT’s inclusion in the United States Core Data for Interoperability (USCDI) v5, as an example of steps that can strengthen dental documentation and reporting to support AI-enabled care. 

Another key focus of the letter is the need for a standardized definition of “Non-Medical Devices.” The ADA emphasized that inconsistent definitions across agencies and industry create uncertainty around liability, patient consent, privacy and security. Clear guidance from HHS would help practices safely integrate AI tools into care delivery while protecting both patients and clinicians, according to the Association.  

The ADA encouraged HHS to strengthen vendor accountability, emphasizing that dentists and dental teams should be able to rely on technology vendors to deliver secure, compliant systems by default, and that clearer expectations around privacy and security responsibilities would reduce confusion and risk for practices. The ADA also encouraged the use of gold-standard synthetic datasets and independent validation frameworks to ensure that AI solutions are reliable, unbiased and compatible with existing dental workflows. The letter also references ADA Technical Report No. 1109, which outlines methods to evaluate dental image-based AI systems. The full letter outlines additional recommendations on regulatory, interoperability and evaluation approaches for AI in clinical dentistry.  

The response also highlighted opportunities for AI to reduce administrative burden, citing credentialing as a persistent challenge and pointing to emerging tools that can help streamline primary source verification.