The proposed change to Guidance Document 60-7 raises an important issue that deserves more attention: accountability.

The authority for dental assistants to perform supragingival scaling was created by the General Assembly. It was not a scope expansion initiated or approved by the Board of Dentistry. That distinction matters, particularly when the Board appears to be receiving criticism for a policy decision it did not make.

Dental assistants are not licensed health care practitioners under the Board in the same manner as dentists and dental hygienists. The Board therefore does not have the same direct licensing and disciplinary authority over the dental assistant performing the procedure. Yet the procedure being delegated involves hand and ultrasonic scaling instruments and carries very real clinical responsibilities.

That leaves the licensed dentist in an extremely important position. The dentist must verify that the assistant has satisfied the statutory requirements, determine that the assistant is competent, select an appropriate patient, delegate the procedure, provide the required supervision, and ultimately remain responsible for care provided in the practice.

Guidance Document 60-7 should make this chain of responsibility much clearer.

It should also clearly state what happens at the clinical boundary. What is expected when supragingival calculus extends subgingivally? What happens when bleeding, pocketing, attachment loss, significant inflammation, or other evidence of periodontal disease is encountered? When must the assistant stop and the patient be referred to the dentist or dental hygienist for appropriate care?

Simply stating that a dental assistant may perform “Supragingival Scaling with hand and ultrasonic scalers” does not answer these questions.

The General Assembly has already determined what the law will permit. The Board now has the much harder task of making that law workable in actual dental practices while protecting patients. Since the individual performing this newly authorized procedure is not independently licensed by the Board, the guidance should leave as little room for ambiguity as possible regarding scope, competency, supervision, patient selection, and the responsibility of the delegating dentist.