I am writing to express my deep disappointment with the Virginia Board of Dentistry’s decision not to initiate a formal regulatory process following the passage of legislation permitting dental assistants to perform supragingival scaling.

As a dental hygiene educator and licensed dental hygienist, I believe this issue deserves careful, transparent, and formal consideration by the Board. Supragingival scaling is not simply the mechanical removal of visible calculus. It requires knowledge of oral and dental anatomy, periodontal health and disease, instrumentation, infection control, patient assessment, and the ability to recognize when treatment may be inappropriate or when additional care is necessary.

Dental hygienists receive extensive education, laboratory instruction, supervised clinical training, competency assessment, and licensure examination before being permitted to provide scaling services to the public. When a procedure traditionally associated with the licensed practice of dental hygiene is expanded to individuals with substantially different education and clinical preparation, the regulatory details matter greatly.

My concern is not an unwillingness to recognize the important role of dental assistants. Dental assistants are essential members of the dental team. Rather, my concern is ensuring that any expansion of duties is accompanied by clearly defined and enforceable standards designed to protect patients and provide consistency throughout the Commonwealth.

A formal regulatory process would provide an opportunity to address critical questions regarding required education and training, clinical competency, supervision, documentation, patient selection, contraindications, continuing education, and accountability. It would also allow dental hygienists, dental assistants, dentists, educators, professional organizations, and members of the public to provide meaningful input into how this new authority should be implemented.

The passage of legislation does not eliminate the Board's responsibility to carefully consider how that legislation affects patient safety and the delivery of dental care. In my view, it makes thoughtful regulatory oversight even more important.

I am especially concerned about the precedent created when an expanded clinical function is implemented without a formal process to establish consistent educational and competency standards. Without clear statewide requirements, there is the potential for significant variation in how individuals are trained and evaluated before performing supragingival scaling on patients.

Virginia's patients deserve assurance that anyone performing an irreversible or potentially tissue-altering clinical procedure has demonstrated appropriate knowledge and competency. Virginia's dental professionals also deserve clear standards that define expectations, responsibilities, and limitations.

I respectfully urge the Virginia Board of Dentistry to reconsider its decision and initiate a formal regulatory process addressing the implementation of supragingival scaling by dental assistants. Doing so would not undermine the legislation passed by the General Assembly. Rather, it would help ensure that the law is implemented responsibly, consistently, transparently, and with patient safety as the foremost priority.

Thank you for considering my comments.