I have concerns about how supragingival scaling is being added to Guidance Document

60-7. The proposed document simply lists “Supragingival Scaling with hand and ultrasonic scalers” and refers the reader to the statute. I think the guidance should be more specific.

At a minimum, the document should state that a dental assistant must meet all of the requirements in § 54.1-2729.01 before performing this procedure, including the required clinical experience, training, supervised scaling procedures, dentist certification, and supervision.

I am also concerned that the guidance does not clearly distinguish supragingival scaling from subgingival instrumentation or periodontal therapy. That distinction is especially important when hand and ultrasonic scalers are being used.

There should also be clarification regarding patient selection. A patient may have visible supragingival calculus and also have periodontal disease requiring treatment beyond the permitted scope of a dental assistant. The guidance should make clear that the supervising dentist is responsible for determining whether the patient is appropriate for this limited procedure.

The General Assembly has authorized this duty. The guidance should now make the boundaries of that duty very clear for the dentists and dental assistants who will be expected to follow it.