As a practicing dental hygienist, I have concerns about the implementation of dental assistants performing supragingival scaling and the potential unintended consequences of this change.

While I understand that this legislation is intended to address workforce shortages and improve access to care, I believe the Board should consider whether it could also create an unintended financial incentive for practices to use dental assistants for scaling rather than hiring or replacing licensed dental hygienists. If the reimbursement for a preventive service remains the same or similar regardless of whether the scaling is performed by a dental hygienist or dental assistant, practices may have a financial incentive to utilize personnel with lower staffing costs. I believe safeguards are important to ensure that expanded duties are used to improve access to care rather than primarily as a substitute for licensed hygienists.

I also believe there should be very clear criteria regarding which patients are appropriate for dental assistant scaling. Not every patient scheduled for a routine “cleaning” is clinically the same. How will patients with significant calculus, periodontal disease, a history of periodontal treatment, or other findings requiring additional assessment be handled? There should be clear guidance regarding when a patient is appropriate for dental assistant scaling and when the patient should be treated by a licensed dental hygienist.

Patient transparency is equally important. Most patients scheduling a “cleaning” may not understand what “supragingival scaling” means or realize that the individual scaling their teeth is a dental assistant rather than a licensed dental hygienist. I believe patients should be clearly informed, in language they understand, before treatment and given the opportunity to make an informed choice about their care.

Dental assistants are valuable members of the dental team, and these concerns are not meant to diminish their role. However, there is a substantial difference in the education, clinical training, examination, and licensure requirements of dental assistants performing this expanded function and licensed dental hygienists.

I respectfully ask the Board to consider clear patient-selection criteria, patient-notification requirements, appropriate oversight, and the potential financial incentives created by this change. These safeguards would help ensure that expanded duties are used to improve access to quality dental care while protecting patients and preserving the appropriate roles of all members of the dental team.