In its response to the EIA, the Board concludes that removal of the ratio would decrease access to care and threaten patient safety.  Among the many assumptions made, all of which fail to address DPB’s arguments about economic fairness, the Agency Response claims that a hygiene program may be closing, a less restrictive limit or no limit would result in a mass exodus of hygienists from rural areas, the restrictive ratio prevents “hygiene mill(s)”, and that the current average salary for Virginia hygienists is “respectable”.  The Board goes a step further to speculate on the reasons an individual hygienist may work part time.

To respond briefly to these assumptions:

Ø      We have no knowledge of any imminent closings of dental hygiene programs.  In fact, Northern Virginia Community College plans to increase their next class by 50% and Central Virginia Community College is taking steps to establish a new program. .  In addition, the implementation of distance dental hygiene education through compressed video technology has increased the number of dental hygienists in rural and underserved areas of Virginia.  Germanna Community College distancing with Northern Virginia Community College has completed two dental hygiene cycles; Danville Community College distancing with Virginia Western Community College has completed three cycles and is beginning a fourth; and Lord Fairfax Community College distancing with Virginia Western Community College is in its second cycle of operation.

Ø      It has been demonstrated that dental hygienists, and most other professionals, are likely to locate and practice in or near their home communities.  If more opportunities exist in rural communities, more hygienists will locate there.

Ø      VDHA does not support the idea of a “hygiene mill”, which is an undefined term.  However, in the 42 jurisdictions with no dentist-hygienist restrictions there is limited or no evidence to suggest that patients in other states receive sub-standard care.

Ø      Regarding dental hygienists’ income, it is not the business of the Board of Dentistry to determine what a “high” or fair salary is for any licensees.  And, the suggestion that hygienists contribute to barriers to care by “choosing to work part-time” is unfounded.  It could just as easily be suggested that if dentists who offered competitive compensation and desirable work environments could supervise more than two hygienists at a time, then hygienists would have more attractive opportunities to work, in all areas of the Commonwealth.

For your consideration, VDHA suggests one specific change to the 18-VAC 60-20.  In 18-VAC 60-20-200 Employment of Dental Hygienists, we recommend striking the “Employment of Dental Hygienists” and inserting “Restrictions for Direction and General Supervision”.  This section no longer refers to an employer-employee relationship between dentists and dental hygienists. 

To avoid disruption of service under general supervision, we support moving forward with the proposed regulations.  Bringing general supervision to Virginia’s dental health system has taken too long to allow one existing aspect of the regulations to hold up progress.  However, we strongly believe that the Department of Planning and Budget EIA has afforded us an opportunity to have an open discussion about the reasons behind the current 2:1 ratio.  I would respectfully request that the Board establish a task force to study whether a ratio is necessary for the safety of patients and, if so, what an acceptable ratio would be.

Please contact me with questions or for additional information.

Sincerely,

Misty Sissom, BSHS, RDH

President