Dear Dr. Taylor:

On behalf of the Virginia Dental Hygienists’ Association (VDHA), it is my pleasure to offer comments on the proposed amendments relating to general supervision of dental hygienists by dentists (18 VAC 60-20).  VDHA is committed to the uninterrupted implementation of general supervision in Virginia.

For reasons stated numerous times before, VDHA believes that the implementation of general supervision will safely expand patient access to oral health care services.  We continue to see great success in the private practice setting as dentists use the flexibility of general supervision to increase office hours and improve patient scheduling.  With the recent passage of SB 1090 (Bolling), which allows dentists to prescribe the administration of certain topical drugs by a hygienist, the safe delivery of dental care under general supervision will be further improved.

Overall, we support the proposed changes to the 18-VAC 60-20 and encourage the Board of Dentistry to work closely with licensees and other stakeholders to continuously monitor and improve oral health care under general supervision.  VDHA’s primary goal is to ensure continuity and progress with regards to the implementation of general supervision.  However, in response to the Economic Impact Analysis (EIA) submitted by the Virginia Department of Planning and Budget (DPB) and to the Agency Response submitted by the Board, VDHA desires to highlight some areas of concern.

VDHA concurs with the DPB charge that the current “two hygienists per dentist” restriction is not only set at an arbitrary ratio, but it is anti-competitive, deters innovative practice management, and increases costs.  This restriction, as noted by current members of the Board of Dentistry in public meetings, is based on economics and the desire of dentists to prevent competitors from luring hygienists away.  It is workforce manipulation and restraint of free trade.  According to the American Dental Hygienists’ Association (ADHA), Virginia is one of only nine jurisdictions with limitations on the number of hygienists that a dentist may supervise at one time. 

(please see part 2)